Report 2007-114 Recommendation 3 Responses

Report 2007-114: Low-Level Radioactive Waste: The State Has Limited Information That Hampers Its Ability to Assess the Need for a Disposal Facility and Must Improve Its Oversight to Better Protect the Public (Release Date: June 2008)

Recommendation #3 To: Public Health, Department of

To make certain that it can identify and address existing work backlogs and comply with all of its federal and state obligations, the department should develop a staffing plan for the branch based on current, reliable data. The plan should involve a reevaluation of the branch's assumptions about workload factors, such as how many inspections an inspector can perform annually. The plan should also include the following components:
• An assessment of all backlogged work and the human resources necessary to eliminate that backlog within a reasonable amount of time.
• An assessment of all currently required work and the human resources necessary to accomplish it.

Annual Follow-Up Agency Response From June 2018

The Radiological Health Branch (RHB) completed an independent study of existing workload time expectancies, the sustainability of current fees linked to these time expectancies, and recommendations for changes to future staffing levels. This study analyzed the work being done by non-management positions in 15 functional units located across six programmatic sections of RHB. The study reviewed current program work backlogs and developed and validated reasonable time expectancies for required work in each program unit as related to the work outputs by utilizing historical work records, structured task measurements, and supplemental time/data collection tools. Based on this data collection and validation methodology, actual staffing levels needed across the entire program were developed. The outcome of the study demonstrates the program staffing needs, assesses the quantity of backlogged work, and the human resources needed to accomplish that work as well as all routine program work. The RHB will evaluate the results of the study.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented


Annual Follow-Up Agency Response From May 2017

The Radiologic Health Branch (RHB) has contracted with a professional organization to perform a workload quantitative analysis (QA) on all of the programs operations. The scope of work for this project includes reasonable time expectancies for each program task including inspections, application processing and other vital program workloads. Estimated completion time and issuance of the report is October 2017.

California State Auditor's Assessment of Annual Follow-Up Status: Pending


Annual Follow-Up Agency Response From May 2016

In 2015, the X-Ray Inspection, Compliance, and Enforcement program completed a staffing review. This review shows that by July 1, 2016, assuming that no current staff are lost through retirement or transfer, inspection staffing levels will be sufficient to meet workload demands. In addition, the Radioactive Health Branch will perform a branch workload and staffing quantitative analysis.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented


Annual Follow-Up Agency Response From October 2014

The status of this recommendation is unchanged.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented


Annual Follow-Up Agency Response From October 2013

The Radiologic Health Branch (RHB) continues to measure backlogs and ensure compliance with federal and state inspection frequency and quality requirements.

In September 2009, RHB completed a data backlog correction plan. Managers and staff conduct data quality checks using independent and computerized data edit checks. Management evaluates error rates and the need for new procedures to ensure we maintain an error rate of less than 5%.

The Radiation & Certification Section (RCS) found the registration workload was beyond the skills of the staff assigned and upgraded two positions to complete complex registrations. RCS uses a registration procedure known as "Making the Facility Whole." Staff addresses all outstanding requests associated with a facility. This reduces error and rework. RCS tracked all unprocessed registration forms to create an accurate registration inventory. RCS tracked expedites separately from the backlogged work and reduced portions of the backlog that could be addressed quickly.

The X-Ray Inspection, Compliance, and Enforcement (ICE) program crosschecks federal Mammography Quality Standards Act inspection due dates with the US FDA database. The analyst who does all data entry for ICE Inspection performs the cross check, minimizing the opportunity for error. The two inspection reports are checked by the Senior Health Physicist. X-Ray ICE tracks non-mammographic state inspection workload independently from the Health Applications Licensing (HAL) database and cross checks the X-Ray inspection database with HAL. RHB will digitize inspection files to increase reliability and save time. In 2012, RHB hired 3 new X-ray inspection staff. Funding for the new staff resulted from an analysis of the X-ray inspection workload. The X-ray inspection section also implemented a remote inspection program called CARRD that allows an individual facility to perform its own test and return the test kit via mail.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

The department's response claims that it developed a data backlog correction plan in September 2009. However, the department did not include this plan with its response.


Annual Follow-Up Agency Response From September 2012

The California Department of Public Health (CDPH) disagrees with the auditor's determination that this recommendation is not fully implemented. CDPH believes it has fully implemented this recommendation and resubmits its response from last year.

CDPH Radiologic Health Branch (RHB) implemented and continues to use a plan that identifies existing backlogs. The plan ensures that CDPH measures and validates compliance with federal and state inspection frequency and quality requirements. Furthermore, the implementation of an on-line licensing system will provide a timelier, more accurate, and more complete data analysis. CDPH is currently able to review production and staffing information that reflects monthly management program inspection activities.

In September 2009, CDPH completed its data backlog correction plan and continues to resolve backlog associated with the Health Applications Licensing (HAL) system. Both managers and staff continue to conduct data quality checks using independent and computerized data edit checks. Management routinely evaluates error rates and the need for new procedures or quality assurance checks to ensure an error rate of less than five percent. Using information technology tools and procedures, this error rate reduction has been achieved.

In addition, CDPH-RHB has completed a reevaluation of the X-Ray Inspection, Compliance, and Enforcement (ICE) program. As part of this reevaluation, the existing inspection database was modified to allow real time tracking of each inspector's inspection history (HAL does not track inspector workload).

CDPH-RHB has implemented procedures that routinely evaluate workload and staff resources.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented


All Recommendations in 2007-114

Agency responses received after June 2013 are posted verbatim.