February 18, 2022

Allegation Regarding Contractor Misrepresentation on Occupational Safety and Health Administration Documentation

The East Tennessee Technology Park, formerly known as the Oak Ridge Gaseous Diffusion Plant, began operations during World War II as part of the Manhattan Project.  As the Department of Energy’s mission changed, operations at the plant ceased, and the Department began a massive environmental remediation effort.  In 2011, the Department contracted with URS|CH2M Oak Ridge LLC (UCOR) for the completion of the decontamination, demolition, and environmental remediation work at the East Tennessee Technology Park under a Cost-Plus-Award-Fee contract, with award fee earned based on performance in various areas, including safety.  UCOR’s work is overseen by the Oak Ridge Office of Environmental Management, which is part of the Office of Environmental Management.

The Office of Inspector General received an allegation regarding contractor misrepresentation regarding classifications on injuries or illnesses reporting.  The complaint alleged that UCOR committed fraud by intentionally misrepresenting the date and classification of employee injuries or illnesses on Occupational Safety and Health Administration (OSHA) recordkeeping logs to increase contract fees and improve the likelihood of being awarded another contract.  We initiated this inspection to determine the facts and circumstances regarding the allegation concerning contractor misrepresentation on OSHA documentation.

We did not substantiate the allegation that UCOR committed fraud by intentionally misrepresenting the date and classification of employee injuries or illnesses on OSHA documentation to increase fees and improve the likelihood of being awarded another contract.  Even though the allegation was unsubstantiated, we found that UCOR and the Department of Energy’s Office of Oak Ridge Environmental Management had differing interpretations of requirements regarding occupational injury and illness reporting.  Specifically, the Department’s Office of Oak Ridge Environmental Management directed UCOR to ensure the information that UCOR reports in the Department’s Computerized Accident/Incident Reporting System matched the information reported on the UCOR OSHA Form No. 300, Log of Work-Related Injuries and Illnesses (recordkeeping log).  UCOR declined to do so, stating that while the Department can direct classification in the Department’s Computerized Accident/Incident Reporting System, it does not have the authority to direct classification in OSHA’s recordkeeping logs.  Accurate reporting of accidents and incidents is critical so that the Department receives information in a timely manner regarding events that have affected or could adversely affect the health, safety, and security of the public or workers, the environment, the operations of Department facilities, or the credibility of the Department. 

To address the issue identified in this report, we have made two recommendations that, if fully implemented, should help ensure that the issue identified during our inspection is corrected.