Performance audit, Department of Weights and Measures

              DOUGLAS R. NORTON. CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
October 20, 1992
Members of the Arizona Legislature
The Honorable F i f e Symington, Governor
Mr. John Hays, Director
Department of Weights and Measures
Transmitted herewith i s a report of the Auditor General, A Performance
Audit of the Department of Weights and Measures. This report is in
response to a December 13, 1991, resolution of the Joint Legislative
Oversight Committee.
The report presents a new approach to regulating commercial transactions
involving weights and measures in Arizona. Rather than inspecting a l l
devices or establ ishments once each year, the Department can promote
greater compliance and reduce inspection costs by using sampling
strategies to identify and target v i o l a t o r s . Combined with the
Department's new authority to impose c i v i l sanctions, t h i s approach
enables the Department to e f f e c t i v e l y regulate with fewer s t a f f than at
present.
We also found that the Department has experienced much turmoil and s t a f f
dissension, largely due to the actions of the former management. In
addition, the audit presents information showing that the Department's
used o i l program a c t i v i t i e s are not self- supported from program revenues.
My s t a f f and I w i l l be pleased to discuss or c l a r i f y items in the report.
This report w i l l be released to the public on Octobza 21, 1992.
Sincerely,
DRN: lmn
2700 NORTH CENTRAL AVENUE SUITE 700 PHOENIX, ARIZONA 85004 ( 602) 255- 4385 ' FAX ( 602) 255- 1251
SUMMARY
The Office of the Auditor General has conducted a performance audit and
Sunset Review of the Department of Weights and Measures, pursuant to a
December 13, 1991, resolution of the Joint Legislative Oversight
Committee. The audit was conducted as part of the Sunset Review set
forth in Arizona Revised Statutes $ 541- 2951 through 41- 2957.
The Department is a smal l agency that has grown rapidly in recent
years. The number of s t a f f grew from 26 in fiscal year 1986- 87, to 66
in fiscal year 1992- 93 and appropriations increased from $ 1 mi I lion to
$ 2.4 m i l l i o n during that same period. The audit addresses concerns
raised by Joint Legistive Budget Committee s t a f f about the need for some
Department a c t i v i t i e s , s t a f f turnover, and revenues generated by the
used o i l program.
The Department Of Wei~ hts And Measures
Could Improve Its Effectiveness
And Reduce Staffing ( see pages 5 through 10)
The Department's practice o f relying on frequent inspections to
discourage noncompliance with weights and measures statutes and
regulations i s not a cost- effective use of State resources. A
s t a t i s t i c a l analysis of approximately 27,000 Department inspections
conducted during 1989- 1991 revealed that the majority o f vendors comply
with regulations. Our analysis also shows that most vendors w i l l comply
regardless of the inspection frequency. However, the r e l a t i v e l y few
vendors that do tend to violate are not deterred by the threat of annual
inspections or the r e l a t i v e l y limited enforcement options previously
available to the Department. Moreover, the Department does not appear
to target violators for inspection any more frequently than i t does
vendors that are in compliance.
The Department can improve i t s effectiveness and reduce operating costs
by using an inspection strategy based on s t a t i s t i c a l sampling coupled
with i t s new c i v i l penalty authority. This strategy i s based on the
premise that those vendors that currently violate the law w i l l comply if
they believe there is a reasonable chance that noncompliance w i l l be
detected that the penalties for noncompliance outweigh the potential
benefits. The strategy has three components: 1) inspecting a large
random sample of vendors each year, 2) imposing c i v i l penalties for
violations, and 3) following up each v i o l a t i o n in the year detected as
well as conducting additional follow- up inspections over a five- year
period fol lowing the v i o l a t ion.
This sampling and follow- up inspection strategy could reduce the number
of Weights and Measures inspections from approximately 9,000 to 3,000
per year, which we estimate would enable the Department to eliminate 19
positions, including three supervisors, and save an estimated $ 480,000
annually. However, at least some of t h i s saving would be needed t o h i r e
a data analyst with experience in sampling, to design, manage, and
analyze the data base needed to implement the sampling strategy.
Former Manasement At Weishts And Measures
Created Turmoil Amonq
Aaencv Staff ( see pages 11 through 16)
In recent years the Department has been plagued by dissension and low
morale. Our interviews with former and current s t a f f i d e n t i f i e d t h i s
low morale as a major cause for s t a f f turnover. A survey of current
employees and follow- up interviews revealed an angry and frustrated work
force, deeply divided over the quality and i n t e g r i t y of the Department's
former management team. Some s t a f f were extremely c r i t i c a l of the
former management for being biased and showing favoritism or behaving in
what they considered to be an insensitive manner. Other s t a f f were
highly supportive of the former management and regarded those that
raised concerns as disloyal.
The administrators that were the focus of much of the s t a f f discord l e f t
the agency during our audit. Since that time, the new Director has
taken steps to refocus s t a f f attention on the agency's functions and
away from the issues involving former management. Although these steps
appear appropriate, the Department needs to continue monitoring the
i ssue .
Other Pertinent Information -
The Used Oil Prwram Does Not Support
Itself Throuah F& S And Penalties
( see pages 17 through 23)
The Department of Weights and Measures used oi l program does not
generate s u f f i c i e n t revenue to support program a c t i v i t i e s . Although the
Legislature intended the program to be s e l f - s u f f i c i e n t , our analysis of
revenues and expenditures indicates that the $ 65 fee for used o i l tests
i s far less than the amount needed to fund the program. I f the fees for
a l l tests were paid on time, the Department would s t i l l need to collect
$ 106 for each test to cover i t s costs. However, many fees are not paid
on time and i f the agency's costs were assessed only against the fees
col lected for used o i l tests, the test fee would have to be increased to
$ 157.
TABLE OF CONTENTS
INTRODUCTION ANDBACKGROUND. . . . . . . . . . . . . . . . . .
FINDING I : THE MPARTUENT OF WEIGHTS AND MEASURES
CWU) IYPROVE ITS EFFECTIVENESS ! MI REDUCESTAFFING. . . . . . . . . . . . . . . . . . . . . .
Current Enforcement E f f o r t s Are Not Cost Effective . . . . . . . . . . . . . . . . . .
Staff Reductions And More
Effective Regulation Could Be
Achieved By The Department . . . . . . . . . . . . . . . .
Recommendations. . . . . . . . . . . . . . . . . . . . . .
FINDING I I : FOWER MANAGEMENT AT WEIGHTS AH) MEASURES
CREATED TUIF( UOIL AYONG AGENCY STAFF . . . . . . . . . . . .
Alleged Mismanagement By Former Administrator
Angered, Frustrated, And Divided Staff . . . . . . . . . .
New Agency Management Is Attempting
To Rebuild S t a f f S o l i d a r i t y And Morale . . . . . . . . . .
Recommendation . . . . . . . . . . . . . . . . . . . . . .
OTHER PERTINENT INFWUATION. . . . . . . . . . . . . . . . . .
Legislature Intended Program
ToBeSelf- Supporting. . . . . . . . . . . . . . . . . . .
Program Costs Exceeded Program
Revenues In Fiscal Year 1991 . . . . . . . . . . . . . . .
Barriers To A Self- supporting Program. . . . . . . . . . .
SUNSETFACT O R S . . . . . . . . . . . . . . . . . . . . . . . .
TECHNICAL APPENDIX . . . . . . . . . . . . . . . . . . . . . .
AGENCY RESPONSE
LIST OF TABLES
TABLE 1 USED OIL PROWU COST ANALYSIS
JULY 1, 1991 MROUW APRl L 30, 1992
( Unaudited). . . . . . . . . . . . . . . . . . . 19
TABLE 2 USED OIL FEE COLLECTIONS
FISCAL YEAR 1991- 92
( Unaudited). . . . . . . . . . . . . . . . . . . 2 1
TABLE 3 ESTIMATED FIVE- YEAR WKLOAD
USING SAMPLING STRATEGY. . . . . . . . . . . . . A- i i i
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a performance audit and
Sunset Review of the Department of Weights and Measures, pursuant to a
December 13, 1991, resolution of the J o i n t Legislative Oversight
Committee. The audit was conducted as part of the Sunset Review set
forth in Arizona Revised Statutes $ 541- 2951 through 41- 2957.
Based on concerns raised by the Joint Legislative Budget Committee
s t a f f , the Joint Legislative Oversight Committee instructed our Office
to review operations at the Department of Weights and Measures. What we
found was an agency in turmoil as a result of i t s poor handling of
personnel matters and an agency unable to e f f e c t i v e l y handle i t s
regulatory responsibilities despite s i g n i f i c a n t increases in budget and
s t a f f in recent years.
The Department Has Broad Res~ onsibi lities
And A Growina Budaet
The Department i s a small agency that has grown rapidly over the last
several years in an e f f o r t t o meet i t s broad regulatory mandate.
Weights and measures regulatory functions began in 1912 and were
transferred to the Department of Administration in 1974. In 1987, the
Department of Weights and Measures was established as an independent
State agency, and is currently organized into four sections: an
Enforcement division, a Petroleum Quality Control division, an
Administration division, and the State's metrology lab.
Statutes governing the Department have h i s t o r i c a l l y made the agency
responsible for the following:
insuring the accuracy of a l l commercial weighing and measuring
devices operating in the State, including 1) small and large scales
( with weigh capacities ranging from less than a pound to more than
60,000 pounds), 2) petroleum dispensers, 3) propane meters, and 4)
taxi meters.
regulating commodity prices based on weight
operating the State's metrology lab, which maintains custody of the
State's standards of weight and measure from which a l l other
standards of weight and measure used in the State are derived
licensing and regulating performance o f p u b l i c weighmasters and
registered service agencies ( RSA's)(')
Weights and Measures has also been given additional responsibilities
since being restructured as a stand- alone agency. Beginning in 1987,
the Department became responsible for insuring that petroleum octane and
oxygenate levels meet standards and used o i l stored and sold statewide
is properly labeled and not hazardous waste.
Weights and Measures' broad mandate has led to the substantial growth of
the agency since fiscal 1986- 87 in an e f f o r t t o meet i t s
r e s p o n s i b i l i t i e s . In 1986- 87, the Department was authorized 26 FTEs
compared to the 66 FTEs authorized for fiscal year 1991- 92. The
agency's appropriations have also increased from $ 1 m i l l i o n in fiscal
year 1986- 87, to $ 2.4 mi l l ion in fiscal year 1991- 92.
The increase in the number of employees can be a t t r i b u t e d t o both
program area expansion and the addition of new program areas. The agency
has added 19 FTEs to operate i t s new petroleum qua1 i t y control and used
o i l programs. In addition, since 1987, the Department's Enforcement
division, which oversees al l of i t s older inspection programs, has
increased s t a f f i n g from 20 to 33 FTEs.
( 1) Weighmasters are licensed t o weigh any object and c e r t i f y t h a t the weight of the
object i s c o r r e c t ; RSAs are licensed t o i n s t a l l and r e p a i r comnercial weighing and
measuring devices and c e r t i f y that devices are accurately c a l i b r a t e d .
Audit Sco~ e
Our audit objectives were developed in response to the concerns raised by
JLBC s t a f f relating to the efficiency and effectiveness of agency
inspections, inspector turnover, and the revenue generated by the
Department's used o i l program. These concerns are covered in the
report's three sections that address the fol lowing:
Methods for reducing s t a f f and improving performance in the
Department's Enforcement division
Staff turmoil created by former agency administrators
The Department's i n a b i l i t y to support i t s used o i l program through
fees and penalties
The audit was conducted in accordance with government auditing standards.
The Auditor General and s t a f f express appreciation to the Director,
Deputy Director, and s t a f f of the Department for their cooperation and
assistance throughout the audit.
FINDING I
THE DEPARTMENT OF WEIGHTS AND MEASURES
COULD IMPROVE ITS EFFECTIVENESS AND REDUCE STAFFING
A new strategy for inspection and enforcement could reduce s t a f f i n g
costs by $ 480,000 a year and improve the Department's performance.
Weights and Measures' current enforcement strategy, which relies
primarily on frequent inspection a c t i v i t y , does not deter v i o l a t o r s , and
results in an i n e f f i c i e n t use of resources. Staff reductions and more
effective regulation could be achieved by selecting inspections using
s t a t i s t i c a l sampling, and by using the agency's new c i v i l penalty
authority in instances of noncompliance.
Current Enforcement E f f o r t s
Are Not Cost Effective
The Department's practice o f relying on frequent inspections to
discourage noncompliance is not a cost- effective use of State
resources. Although the agency's strategy may seem practical at f i r s t
glance, our review shows that inspections alone do not deter vendors
from violating weights and measures regulations. Moreover, the agency's
overreliance on inspections has resulted in an i n e f f i c i e n t use of
manpower .
Current enforcement strateav r e l i e s on frequent ins~ ections - Weights
and Measures has t r i e d to enforce vendor compliance with State
regulations through intense inspection a c t i v i t i e s . The agency's
approach is simple and appears practical: inspect as many vendors as
possible, as often as possible, and vendors w i l l tend to stay in
compliance with State regulations.
. The agency's strategy i s reflected in the number of inspections i t
performs. For example, the Department's Enforcement division conducted
approximately 27,000 inspections during a three- year period at more than
10,000 business locations. These figures include inspections of over
84,000 we i gh i ng and measu r i ng dev i ces and over 35,000 comod i t i es . ( ' )
When inspectors find violations, enforcement actions are generally
limited to placing defective devices out of service unti I they are
repaired or, in cases where commodities are short- weight, having vendors
reweigh the merchandise at the time of the inspection. The agency does
not generally pursue criminal prosecution as prosecutors often do not
consider weights and measures violations serious enough to warrant
pursuing. However, the Department now has more enforcement options. In
1992, the Legislature provided the Department with c i v i l penalty
authority that allows i t to assess penalties of up to $ 500 per
infraction.
Freauent ins~ ections do not deter violations - We found that frequent
inspections and limited enforcement actions alone do not deter vendors
from v i o l a t i n g State regulations. Our Office analyzed a l l inspections
performed by the agency's Enforcement division from 1989 through 1991
and found that the majority of vendors tend to comply with State
regulations. For example, we found that 92 percent of the businesses
inspected complied with State laws and regulations. However, the
r e l a t i v e l y few vendors that do tend to violate do so regardless of the
frequency of inspections. For example:
A supermarket was inspected 13 times in less than three years.
During that time, inspectors found violations on nine different
occasions and almost 4,100 overpriced packages.
Another supermarket was inspected 17 times in almost three years and
inspectors found violations twelve times including more than 400
overpriced packages.
( 1) The Enforcement d i v i s i o n i s the Department's l a r g e s t section, w i t h 34 f u l l - t i m e
employees, and oversees most of the agency s program areas, i n c l u d i n g i nspecti ons of
small and 1 arge scales , p e t r o l eum d i spensers, propane and t a x i meters, and packaged
comnodities such as meat, p o u l t r y , m i l k , and eggs.
A gas station was inspected eight times between January 1989 and
October 1991, and inspectors found instances of consumer overcharges
on five occasions.
Inspectors found violations at an o i l company during seven of ten
inspections conducted over a two and one- half year period. During
the last inspection, 15 devices were found to be in v i o l a t i o n of
State regulations.
Further, the Department does not appear to target i t s inspection e f f o r t s
against serious offenders. By using the data base we developed from
over 30,000 inspection reports, we were able to identify approximately
900 vendors that could be considered potentiallv serious offenders.(')
While not a l l vendors in this group are serious offenders, the past
performance of these vendors indicates a need for greater agency
scrutiny.
Our analysis revealed that the agency does not focus any greater
attention on this group, however. We found that potentially serious
violators are inspected no more frequently than vendors that are
generally in compliance.
Overreliance on inspections i s i n e f f i c i e n t - The Department's extensive
inspection program i s not e f f i c i e n t . By substituting frequent
inspections for meaningful enforcement, Weights and Measures has
committed i t s e l f to a strategy that results in an i n e f f i c i e n t use of
manpower .
As noted e a r l i e r , most vendors regulated by the Department tend to
remain in compliance with State regulations. For example, Weights and
( 1) We i d e n t i f i e d p o t e n t i a l l y serious v i o l a t o r s as those vendors w i t h devices t h a t were
tagged as f a u l t y more than 50 percent of the time and were not reported as repaired
50 percent of the time.
Measures inspected more than 8,000 vendors over 19,000 times without
finding one incident of consumer overcharge. Our s t a t i s t i c a l analysis
showed that current inspection practices do not encourage this high
level of vendor compliance and most vendors comply with State
regulations regardless of the inspection frequency,
Staff Reductions And More Effective Recrulation
Could Be Achieved By The De~ artment
We believe the Department could improve i t s effectiveness and reduce
operating costs by over $ 480,000 in i t s Enforcement division by using an
inspection strategy based on s t a t i s t i c a l sampling and by using i t s new
c i v i l penalty authority.
A strategy of using s t a t i s t i c a l sampling to select inspections i s based
on the premise that an acceptable compliance rate can be maintained if
persons believe there is a reasonable chance of noncompliance being
detected a d the penalties for noncompliance outweigh the potential
benefits. Therefore, our proposed s t a t i s t i c a l sampling strategy for
inspections i s based on the following three components.
Random Sampling - Instead of inspecting a l l vendors each year, random
sampling would be used to select vendors for an i n i t i a l inspection.
Although most vendors are in compliance, each vendor would s t i l l face
the potential of being inspected. However, the number of actual
inspections would be reduced from approximately 9,000 to
approximately 3,000 annually.
C i v i l Penalties - I f an i n i t i a l inspection finds a consumer
overcharge, the vendor could receive a c i v i l penalty of an amount
varying according to the nature of the infraction. ( Statutes provide
for penalties of up to $ 500 per infraction.) This would establish a
stronger compliance incentive for vendors tempted to overcharge than
simply placing devices out of service and/ or reweighing goods.
llow u~ - Vendors found to be overcharging would also receive a
Ilow- up inspection to insure compliance, and they would be subject
further follow- up inspections for five years after their i n i t i a l
fraction.(')
Fewer inspections would result in the agency being able to operate i t s
Enforcement division with fewer s t a f f . Using current inspector
productivity levels, we estimate the division could eliminate 19 s t a f f ,
from 34 to 15 employees, including three unit supervisors. Eliminating
19 positions would result in a saving of $ 480,000 based on average s t a f f
salaries and employee- related expenses. For a detailed presentation of
the proposed inspection strategy and savings estimates, please see the
Technical Appendix.
Our analysis and recommendations are very conservative. We purposeful ly
proposed a very large sample size for inspections. We also based our
calculations on the Department's current productivity levels. However,
as the Department compiles i t s own data and gains experience in using the
proposed inspection strategy, i t should be able to reduce s t a f f even
further without affecting i t s a b i l i t y to monitor Arizona vendors.
A t least some of the savings realized by reducing s t a f f in the
Enforcement division should be reinvesred in the agency. Weights and
Measures lacks s t a f f with the expertise to develop, implement, monitor,
and update an inspection strategy such as the one we suggest. The agency
w i l l have to hire a data analyst with experience in sampling to design
and manage the s t a t i s t i c a l data base necessary to identify and track
serious v i o l a t o r s .
( 1) Our review suggests Weights and Measures has not i d e n t i f i e d p o t e n t i a l 1 y problem
vendors. The Department does not maintain case f i l e s on vendor performance, and has
not taken the steps necessary t o i d e n t i f y serious v i o l a t o r s . We found t h a t follow- up
inspections are an e x c e l l e n t way f o r i d e n t i f y i n g problem vendors.
RECOMMENDATIONS
1. The Department of Weights and Measures should develop a new
inspection strategy with the following components:
a) s t a t i s t i c a l sampling procedures and a reduction of t o t a l
inspections by approximately 66 percent
b) provisions for conducting follow- up inspections to identify and
target serious offenders
c) provisions for assessing c i v i l penalties to deter continued
noncompliance
2. The Legislature should consider reducing s t a f f in the agency's
Enforcement division by 19 employees, including 16 inspectors and 3
supervisors.
3. The Legislature should consider allowing Weights and Measures to
expend a portion o f the saving accrued through s t a f f reductions to
hire an experienced data analyst.
FINDING II
FORMER MANAGEMENT AT WEIGHTS AND MEASURES
CREATED TURMOIL AMONG AGENCY STAFF
Former agency management created turmoil among s t a f f a t the Department of
Weights and Measures. A variety of alleged incidents of agency
mismanagement angered, frustrated, and polarized Department s t a f f . The
o f f i c i a l s primarily responsible for the discord l e f t the agency during
our audit, and the Department's new Deputy Director has taken positive
steps to rebuild s t a f f s o l i d a r i t y and morale.
Alleqed Mismanas- ement Bv Former Administrators
Ansered, Frustrated, And Divided Staff
Incidents of alleged mismanagement by former administrators at Weights
and Measures disrupted the agency's work environment. In reviewing
agency turnover, we i d e n t i f i e d poor agency morale as one reason for
recent s t a f f turnover. Our follow up with current agency s t a f f revealed
an embittered and frustrated work force, deeply divided over the quality
and i n t e g r i t y of the agency's former management team.
Turnover linked to Door morale - A t the request of the JLBC s t a f f , our
Office reviewed agency turnover. Although we determined that turnover
was only somewhat higher than most other regulatory agencies of
comparable size('), we surveyed former employees as part o f our
investigation and i d e n t i f i e d poor morale at Weights and Measures as a
serious problem.( 2) Although former employees l e f t the agency for a
( 1 ) Between f i s c a l years 1989 and 1991, turnover a t Weights and Measures was 20 percent.
I n comparison, the turnover r a t e during the same time period was 22 percent a t the
Department of Insurance; 17 percent a t the Department of Racing; 15 percent a t the
Board of Medical Examiners; 6 percent a t the Department o f B u i l d i n g and F i r e Safety;
14 percent a t the Department of Real Estate; and 23 percent a t the Department of
Liquor Licenses and Control.
( 2 ) We were able to contact 22 of the 37 employees t h a t l e f t the Department since t h e
beginning o f f i s c a l year 1989.
variety of reasons ( retirement, higher paying jobs, poor health, e t c . ) ,
more than one- third of those we contacted indicated that the agency's
poor organizational climate influenced them to leave.
Our survey also found that most former employees contacted believed the
agency suffered from poor morale. These former employees attributed the
poor morale to a variety of management practices, including employee
harassment and favoritism. In l i g h t o f the survey results, we decided
to follow up with current agency s t a f f .
Incidents and alleaations - Our investigation, which included a
confidential employee survey, follow up with former employees and a
review of available documentation, revealed that the agency's work
environment had been disrupted by a variety of incidents and allegations
involving agency management, including employee harassment, malfeasance,
and discrimination. F Q e~ xa mple:
Five inspectors and a supervisor were caught playing golf while
reporting to be at work during May, June, and July of 1991.
Although the five inspectors were suspended for a week ( the unit
supervisor involved was reprimanded), agency o f f i c i a l s gave some
s t a f f the impression they approved of the misconduct when, several
months after the incident, these temporarily suspended employees
posed with golf clubs and six cases of beer for a photograph in
front of a go1 f course. The photograph shows the employees in
uniform in front of a State vehicle. Copies of t h i s photograph were
displayed for months in the offices of the Director, Chief
Enforcement Officer, and three of the employees involved. Referring
to the photograph one employee noted, " That i s what they think of
the seriousness of the matter."
Some s t a f f believe the incident was not f u l l y investigated by the
Department. One inspector, for example, stated that management
" could have caught them at least a hundred times." A former
employee, that claims to have been part of the " golf team," cited
four other occasions in which he played golf with various members of
the group during work hours.
Some s t a f f also believe the employees continued to play golf on
State time, even after being caught and disciplined. One al legation
that circulated among s t a f f after the incident was that the Director
stated the " golf team" should register under the names of the two
investigating supervisors or the name of the Deputy Director in the
future.
The two investigating supervisors in the case described above claim
they were harassed after the incident. According to one s t a f f
member, the Director and Chief Enforcement Officer made i t look l i k e
the supervisors that investigated the incident were the " bad guys."
Another s t a f f member claims that several inspectors were asked to
spy on one of the supervisors in order to " get something on him . . .
so they could f i r e him."
The Former Director did help employees compile a complaint against
one supervisor shortly before the supervisor q u i t . After declining
to sign the complaint, one employee claims she was rudely accosted
by the Director. A second employee claims he was encouraged to sign
the complaint even after explaining he had no knowledge of any
wrongdoing on the part of the supervisor. A t h i r d employee
reportedly confided to other s t a f f that she signed the complaint out
of fear.
After the supervisor l e f t the agency, the Former Director placed a
memo in his personnel f i le stating that this supervisor " i s not
e l i g i b l e for rehi re by this agency.''
Following t h i s incident one employee stated that the Former Director
said " Now I've got to get r i d of that other one."
In April 1992, one of the inspectors suspended for playing golf on
State time was observed siphoning propane from a State- owned propane
tester into the fuel tank of his personal vehicle.
In a memo to the Director, the inspector explained that the high
temperature outside had caused the propane to expand dangerously,
and his action was a safety measure intended to relieve the pressure
in the test apparatus. The Director accepted the inspector's
explanation and dismissed the allegation.
Further investigation by Weights and Measures would have shown this
was not the only instance in which the same inspector was observed
siphoning propane from the test device. He was also observed
f i l l i n g the tank of his personal vehicle with propane two weeks
before the incident described above, and again in February 1992,
with the help of a second inspector.
Current and former agency s t a f f claim i t i s not uncommon for agency
personnel to use the propane tester to f i l l their personal propane
tanks. I n f a c t , two former employees admitted to doing so.
In August 1991, the Chief Enforcement Officer recommended
transferring a female and male inspector to the agency's Large Scale
u n i t . The male inspector was transferred; the female inspector was
not.
Following t h i s incident, an eyewitness reports that the Former
Director said he would not transfer the female inspector because no
work would get done: people would be standing in line trying to have
sex with her. According to t h i s same eyewitness, the Former
Director also said he was never going to have a female drive one of
the agency's big trucks.
Due to religious beliefs, a lab technician hired by the agency was
apparently reluctant to sign the State loyalty oath required of al l
new employees. According to some s t a f f , this so angered the Former
Director that he purchased a number of small American flags and had
o f f i c e personnel display them on their desks.
Some s t a f f be1 ieve this was to embarrass or intimidate the new lab
technician, who was eventually f i r e d prior to completing his
probationary period.
Numerous other accounts of insensitive behavior on the part of
agency administrators and supervisors offended agency s t a f f . For
exarnp l e :
- Various s t a f f cited occasions on which the Former Director
accused female workers of having a f f a i r s with male employees.
- After one female inspector quit the Department, the Former
Director t o l d t h i s inspector's supervisor -- over the agency's
public address system-- that he would no longer have to i n s t a l l
a tampon dispenser in his o f f i c e .
- While viewing a video training tape, a female inspector claims
that the Chief Enforcement Officer twice asked her i f she
wanted to see a " d i r t y movie."
- An Hispanic inspector claims that one supervisor continually
makes racist comments about him and an Afro- American inspector.
Allegations such as those described above have e f f e c t i v e l y fractured
s t a f f s o l i d a r i t y . The agency's work force appears to be divided into at
least two groups, those that were extremely c r i t i c a l of former agency
management and those that st rong l y supported the agency ' s f o rrne r
administration. This division of s t a f f has been extremely disruptive.
As one employee pointed out, " When there are inspectors against
inspectors and supervisors against supervisors ..., i t does take i t s
t o l l on the effectiveness of this agency.''
Unless s t a f f tension is e f f e c t i v e l y addressed, i t is l i k e l y the agency's
poor organizational climate w i l l continue to influence turnover. One
employee warned that " Job dissatisfaction ( i s ) very high. . . . Present
economic times are the main reason many are s t i l l with Weights and
Measures. These people, including myself, w i l l leave at the f i r s t
opportunity i f conditions don't improve." According to our s t a f f
survey, 43 percent of the agency's nonsupervisory full- time personnel
( 20 of 46 employees) were currently seeking other employment. Most
listed the agency's poor work environment as a motivating factor in
wanting to leave.
New Aaencv Manaqement Is Attempting
To Rebuild Staff Solidaritv And Morale
During our audit three of the agency's top administrators l e f t . Two of
these o f f i c i a l s , the Former Director and Chief Enforcement Officer, were
focal points for much of the s t a f f discord.
Since that time, the agency's new management has taken several steps to
help s t a f f refocus their attention on agency objectives and their
responsibilities, and away from preoccupation with former administrators
and each other. For example, the new Deputy Director has taken the
following steps to rebuild s t a f f morale:
Introduced a more participative decision- making process, in which
s t a f f are involved in the planning and implementation of agency
a c t i v i t i e s
Emphasized the need for supervisors to administer agency rules, such
as the disbursement of overtime compensation, in a consistent and
equitable manner to avoid the appearance of favoritism
Started to revise the time reporting system to ensure more accurate
oversight of s t a f f a c t i v i t i e s
In addition to these positive steps, the agency needs to continue
monitoring s t a f f behavior and attitudes. The anger and h o s t i l i t y that
developed among s t a f f may not easily dissipate and may yet find ways to
manifest i t s e l f to the detriment of the agency.
I f s t a f f discord persists, the agency w i l l have to consider i t s options
and develop a more formal team- building strategy to address i t s
personnel problems. The agency may even wish to s o l i c i t outside
assistance. The Department of Administration's Personnel Division, for
example, has offered i t s services to help the agency develop an
effective strategy.
RECOMMENDATION
The Department of Weights and Measures should monitor s t a f f behavior and
a t t i t u d e s t o ensure that the steps taken to relieve s t a f f discord result
in a more effective work environment. I f s t a f f dissension persists, the
agency should consider i t s options and develop a more formal team- building
strategy to address i t s personnel problems.
OTHER PERTINENT INFORMATION
During our audit we developed information on the Department of Weights
and Measures used oi l program revenues in response to concerns about
s h o r t f a l l s in the amount of revenues collected to support program costs.
The Legislature created the used oi l program in 1990 to promote used o i l
as an energy resource and to protect the env i ronment . Used o i l i s
generated in a variety of ways. Large industrial and commercial
enterprises may use o i l in their processing a c t i v i t i e s . People generate
used o i l when they change the motor o i l in their vehicles. Disposing of
used o i l properly is an environmental concern and the 1990 legislation i s
an attempt to address this concern.
The Department of Weights and Measures and the Department of
Environmental Quality ( DEQ) share responsibility f o r Arizona's used o i l
program. Weights and Measures samples and tests used oi l for a variety
of contaminants and n o t i f i e s DEQ i f the o i l does not comply with
statutory requirements. DEQ approves the method of disposal for used
o i l , and Weights and Measures supervises removal to ensure i t is disposed
of as required by DEQ.
Leqislature Intended Proqram
To Be Self- Supporting
Weight and Measures' used o i l act i v i t i es are supposed to be supported by
fees for testing. A. R. S. $ 41- 2065( A)( 26) di rects the Department to
Establish by rule fees, including late charges, i f any, to be
paid by a transporter, generator, marketer, or burher of used
o i l fuel to cover the f u l l cost of each test ....
The Department has established a fee of $ 65 for each used o i l test
conducted. In addition, DEQ remits one- half of the used o i l fees i t
c o l l e c t s t o Weights and Measures, which may use funds for used o i l
compliance monitoring, testing, investigation, and enforcement
a c t i v i t i e s . ( ' )
Although the statutory language specifies only that Weight and Measures
w i l l recover test costs, the Former Deputy Director and l e g i s l a t i v e s t a f f
report that legislators intended the program to be f u l l y
self- supporting. Thus, a l l Weights and Measures' used o i l program
a c t i v i t i e s should be funded through the program's fees and penalties.
Pro~ rarn Costs Exceeded Program
Revenues In Fiscal Year 1992
The used o i l program did not generate s u f f i c i e n t revenues to meet i t s
costs during the f i r s t ten months of fiscal year 1991- 92. Our analysis
of program costs and receipts indicates that the $ 65 test fee is too low
to support current program a c t i v i t i e s , even i f Weights and Measures were
able to collect fees for a l l tests performed. This revenue s h o r t f a l l
appears to be the result o f overly optimistic assumptions about program
a c t i v i t y levels.
A t the request of the Joint Legislative Budget Committee s t a f f , we
reviewed the used o i l program to determine why revenue collections were
not meeting expectations. Our review covered the period July 1, 1991 to
April 30, 1992. According to Department s t a f f , t h i s ten month period
represents typical a c t i v i t y ; Department s t a f f do not expect any
aberrations in the remaining two months.
Proqram costs and revenues - The cost of the Department's used o i l
program a c t i v i t i e s exceeded the $ 65 per sample fee by $ 41 to $ 92 during
our review period. We calculated the per sample cost ( as shown on Table
1, page 19) by compiling costs for a l l a c t i v i t i e s related to the used o i l
program for July 1, 1991 to April 30, 1992. We then subtracted DEQ
payments to the Weights and Measures during that period to obtain the net
( 1 ) Persons or operators of f a c i l i t i e s burning used o i l must pay 6 o r 20 cents, depending
on the composition of the o i l , f o r each gallon burned. A. R. S. $ 49- 814( D)( 2) d i r e c t s
DEQ t o remit one- half of the fees c o l l e c t e d to the Weights and Measures' used o i l fund
established pursuant t o A. R. S. $ 41- 2069.
program cost. We divided the net cost by the 1,980 samples tested during
the period to obtain a cost of $ 106 per sample, or $ 41 above the $ 65
fee. However, because the Department had d i f f i c u l t y collecting the fees
b i l l e d , we also divided the net cost by the 1,340 samples for which fees
were paid, to obtain a cost of $ 157 per sample.
TABLE 1
USED OIL PROGRAM COST ANALYSIS
JULY 1,1991 THROUGH APRIL 30,1992
( Unaud i t ed )
Pe rsonne l
Operating Costs
Indirect Operating Costs
Total
Less: DEQ Payments ( est.)
Net Costs
I f Everyone Paid:
No. Samples B i l l e d
Cost per Sample B i l l e d
Less: revenue per sample
Revenue Shortfall
I f Cost Fell Onlv To Those Who Paid:
No. Samples Paid
Cost per Sample Paid
Less: revenue per sample
Revenue Shortfall
Total Costs
Source: Auditor General s t a f f analysis of Department of Weights and
Measures Used O i l Program data, July 1, 1991 through Apri l 30,
1992.
Oriainal assumotions - The Department's experience with the used o i l
program during the f i r s t ten months of fiscal year 1991- 92 d i f f e r s
markedly from the agency's i n i t i a l assumptions. According to the Former
Deputy Director, the $ 65 fee was established by dividing the program's
f i r s t year appropriation by an anticipated 5,400 samples during the
year. Our review of ten months' data clearly shows that the 5,400 sample
estimate was very optimistic. Weights and Measures averaged just under
200 samples per month during our review period, less than one- half the
amount expected. According to Department o f f i c i a l s , sample co ction is
a more time- consuming process than i n i t i a l l y expected. In ddition,
Weights and Measures inspectors supervise the removal of o i l containing
hazardous wastes, an a c t i v i t y that generates no revenues.
DEQ pavments - A major variable in projecting future costs i s the
uncertainty about the level of used o i l fees that DEQ w i l l pay to the
Department of Weights and Measures. The used o i l fund supports a portion
of the Department's program cost.
During our review period, payments to Weights and Measures were
approximately $ 75,000, or 26 percent of the total program cost. However,
neither DEQ nor Weights and Measures s t a f f were able to estimate future
penalty amounts. Moreover, s t a f f at the two agencies predicted very
different future scenarios for program revenues. DEQ s t a f f suggested
that revenues w i l l decline as burners switch to other fuels not subject
to regulation, and Weights and Measures s t a f f indicated that the lower
cost of used oi l compared to other fuels w i l l encourage greater use and
thus steady revenue generation.
Barriers To A
Self- Su~ portinq Proqram
The comparison of costs and revenues i d e n t i f i e s two b a r r i e r s t o meeting
the objective of a self- supporting program. F i r s t , the low collection
rate prevents the Department from receiving revenue i t i s e n t i t l e d to
receive under the current regulations. Second, the $ 65 fee is not
s u f f i c i e n t to meet present costs. Thus, a self- supporting program may
require a combination of increased collections and higher testing fees.
However, future costs may increase i f more extensive used o i l monitoring
is needed.
Collection rate - Although the Department has d i f f i c u l t y collecting
used- oil test fees, i t makes several attempts to collect these fees. The
Department mails notices to individuals and enterprises that f a i l to pay
within 30 days and doubles the amount of the fee due. I f payment is not
received after the notice i s sent, the Department turns the account over
to the Attorney General's Office for collection.
Despite these attempts, during fiscal year 1991- 92 the Department
collected only 70 percent of the test fees b i l l e d to users ( see
Table 2). Approximately 59 percent of the fees collected were paid on
time; another 8 percent were paid after Weights and Measures sent 30- day
notices. Final ly, 3 percent of the fees were collected by the Attorney
General's Off ice. Although the Department col lected almost $ 104,000, the
30 percent default rate represents a loss of $ 42,900. In addition, the
Department did not collect approximately $ 10,700 in penalties due from
delinquent parties paying more than 30 days late. According to the
Department's fiscal technician, the reduced payments resulted from
negotiations with the delinquent parties.
TABLE 2
USED OIL FEE COLLECTIONS
FISCAL YEAR 1991- 92
( unaudited)
Payment
Status
Number i n
Payment Status
Paid On Time 1 ,309
30- Day Not i ce 18 1
Attorney General Collection 74
Subtotal 1 ,564
Not Paid 660
Total
N& er i n
Payment Status
As Percent of
Total B i l l e d
Revenue
Cot lected
( a) Net amount a f t e r deducting 35 percent c o l l e c t i o n fee charged by the Attorney General.
( b) Although a t o t a l of 2,380 t e s t s were performed during f i s c a l year 1991- 92, 156 were
not b i l l e d . The remaining 156 t e s t s w i l l be b i l l e d during f i s c a l year 1992- 93. A l l
subsequent estimates of revenue f o r f i s c a l year 1991- 92 assume t h a t c o l l e c t i o n
r e s u l t s f o r the u n b i l l e d t e s t s w i l l be s i m i l a r t o the r e s u l t s of the t e s t s t h a t were
b i 11 ed.
Source: Department of Weights and Measures
The Department's overall collection rate may improve in the future.
According to the d i r e c t o r o f the Attorney General's collection u n i t ,
numerous accounts for paymen t of de l i nquent used o i l fees have been
settled recently, and he indicated that these settlements w i l l not only
add revenue to the program but w i l l also provide an incentive for prompt
payment. Even a modest increase in collection rates w i l l increase
program revenue. For example, increasing the t o t a l collection rate from
70 percent to 86 percent(') increases fiscal year 1991- 92 revenues by
approximately $ 25,000. Collecting a l l late fees without Weights and
Measures negotiating lower settlements increases receipts by another
$ 15,000.
Legislation enacted in 1992 w i l l also strengthen the Department's a b i l i t y
to ensure collections. Laws 1992, Chapter 176 clearly authorizes the
Department to impose late fees and charges and to issue stop- use and
stop- sale orders for fai lure to pay fees and late charges.
Increased test fee - Even i f the Department collects fees as suggested
above, program revenues would not support program a c t i v i t i e s as currently
structured. With the additional revenues generated by an 86 percent
collection rate, there would s t i l l be an estimated shortfal l of $ 101,240,
or $ 42.54 per test, for fiscal year 1991- 92. However, increasing the
test fee by $ 42 to $ 107, attaining an 86 percent collection rate and
collecting a l l delinquent fees would make the program largely
self- supporting during fiscal year 1991- 92.(~)
The estimated fee of $ 107 compares favorably to fees charged by private
laboratories for similar analyses. Prices quoted to the Department in
( 1) An 86 percent c o l l e c t i o n r a t e assumes an on- time payment r a t e of 70 percent, a 30- day
n o t i c e c o l l e c t i o n r a t e o f 10 percent, and a 6 percent c o l l e c t i o n r a t e by the Attorney
General's O f f i c e . These rates were selected t o i l l u s t r a t e the impact of a s m a l l ,
r e a l i s t i c a l l y achievable increase i n c o l l e c t i n g .
( 2 ) I f the Department continues t o negotiate delinquent fees a t the same r a t e as i n
f i s c a l year 1991- 92, the estimated t e s t fee needed t o make the program
self- supporting increases t o approximate1 y $ 120.
1990 for used oi I analyses ranged from $ 191 to $ 440. We contacted the
two Phoenix area laboratories and obtained current quotes of $ 202 and
$ 310 for the analyses. Moreover, the private laboratory prices are for
sample analysis &, and do not include costs for sample collection and
monitoring of hazardous wastes as do the costs for Weights and Measures'
tests.
Increasing the used o i l test fee could affect the industry. According to
one industry representative, used o i l i s characterized by fluctuating
prices and market conditions; higher test fees could create additional
financial d i f f i c u l t i e s for the industry. A DEQ o f f i c i a l also noted that
higher fees would be s i g n i f i c a n t for large f a c i l i t i e s with multiple
tanks, each of which would be sampled during an inspection.
Future orouram needs - Program costs could increase in the future because
of the need for more extensive monitoring of used o i l . Currently, the
Department plans to monitor i d e n t i f i e d used o i l generators, transporters,
and burners annual ly and follow up on violations as needed. However,
such limited oversight may be inadequate to monitor the movement and use
of such potential ly hazardous wastes throughout the year.
SUNSET FACTORS
In accordance with A. R. S. 541- 2954, the Legislature should consider the
following 12 factors in determining whether the Department of Weights and
Measures should be continued or terminated.
1. Obiective and purpose in establishinq the Department.
The purpose of the Department of Weights and Measures i s to promote
equity and fairness in transactions involving weighing or
measuring. The Department carries out i t s purpose by maintaining
State standards of weight and measure based on national standards
maintained by the Federal government, by licensing weighing and
measuring devices used within Arizona, and by inspecting those
devices, and enforcing the statutes, rules, and regulations
governing their use. In addition, the Department has also been
assigned responsibility f o r ensuring that 1) motor fuels meet
national standards of quality, 2) oxygenated fuels are properly
blended to meet Environmental Protection Agency requirements, and 3)
used o i l and used o i l fuels meet State health and environmental
standards.
2. The effectiveness with which the Department has met i t s objectives
and purpose and the efficiencv with which the aaency has operated.
The Department has not been e f f i c i e n t in using resources to meet i t s
objective and purpose. The Department attempts to inspect licensed
devices and vendors of packaged commodities at least once each year,
and approximately 92 percent of a l l such devices and packaged
commodities inspected are found to be in compliance with State laws
and regulations. However, the frequency of inspection appears to
have l i t t l e to do with compliance. We found that frequent
inspections and limited enforcement actions alone do not deter
vendors from violating State regulations. Our analysis suggests
that the Department can achieve current compliance levels by
routinely inspecting a sample of licensees and focusing i t s
attention on the r e l a t i v e l y few licensees that do not comply with
applicable statutes and regulations. Changing to a
sampling/ targeting approach would enable the Department to reduce
i t s inspection s t a f f by 19 positions, saving over $ 480,000
annually. ( See Finding I, page 4)
3. The extent to which the De~ artment has o~ erated within the public
interest
The Department's regulatory a c t i v i t i e s serve the public interest by
ensuring that devices used for commercial weighing and measuring in
Arizona are accurate and packaged goods are accurately labeled as to
weight, volume, and count. The Department also serves the public
interest by ensuring that motor fuels are properly oxygenated and
the octane level is correctly label led.
4. The extent that rules and resulations ~ romulaated bv the Department
are consistent with the l e q i s l a t i v e mandate.
The rules and regulations promulgated by the Department of Weights
and Measures appear to be consistent with i t s l e g i s l a t i v e mandate.
Arizona law authorizes the Department to regulate a wide variety o f
commercial transactions that involve weighing, measuring, and
counting, In addition, the Department i s authorized to regulate
public weighmasters and registered service agents, to test used o i l
and oxygenated fuels, and to make rules and regulations to carry out
i t s statutory responsibilities. A review of the Department's
current rules and regulations shows that a l l address various aspects
of the Department's statutory authority and none appear to be
inconsistent with that authority.
. The extent to which the Department has encouraged input from the
public before promulaatinq i t s rules and recrulations and the extent
to which i t has informed the public as to i t s actions and their
ex~ ected im~ act on the ~ u b l i c .
The Department informed the public o f i t s actions by complying with
the requirements of the Administrative Procedures Act for rules in
development during fiscal year 1991- 92. The Department was in the
process of promulgating rules in three areas: 1) metrology
laboratory testing and c e r t i f i c a t i o n fees, 2) unit pricing and
universal price scanners, and 3) motor fuels and petroleum
products. Documentation provided by the Department indicates that
appropriate not ices were f i led with the Secretary of State, not ices
were published in the Arizona Administrative Register, and public
meetings were held for the rules in each of the three areas.
6. The extent to which the Deoartment has been able to investiqate and
resolve comolaints that are within i t s iurisdiction.
The Department receives numerous complaints. During 1991, 446
complaints were reported to the Department. Most ( 304) of the
complaints alleged problems with scales, gasoline pumps, and other
devices for weighing and measuring. Another 142 complaints
concerned the quality of petroleum products sold or used oi I. Most
complaints were dismissed as invalid; only 53 of the 367 disposed
complaints were found to be valid.
The average time to investigate and resolve complaints ( based on a
judgmental sample of 24 complaints) was approximately three days in
1991. However, no disposition was indicated for about 18 percent,
or 79 complaints during 1991. Although these complaints may have
been investigated and no disposition recorded, our analysis
indicates that at least 35 cases assigned to the Enforcement
division were not investigated. Thirty- four of these 35 cases were
assigned to one supervisor who was unable to provide any information
about the lack of inspection records or disposition.
7. The extent to which the Attorney General or any other applicable
aqencv of State qovernment has the authority to prosecute actions
under enablinq leqislation.
A. R. S $ 41- 2113( D) authorizes the Attorney General and county
attorneys to prosecute violations of the Department's enabling
statutes. However, few cases are prosecuted. Our review of
investigations conducted by the Department's Special Investigations
Unit during the period 1989- 1991 found that the unit targeted only
nine cases for prosecution. Five of these cases rqdre prosecuted and
four resulted in convictions or plea agreements.
Recent legislation could streng pen the Depar: ~ t ' s a b i l i t y to
enforce the weights and measures' statutes. Laws 1992, Chapter 176
authorizes the Department to impose c i v i l penalties of $ 500 per
infraction ( up to $ 5,000 per month) for violations of agency laws or
rules. According to Department o f f i c i a l s , the lack of c i v i l penalty
authority has limited i t s a b i l i t y to take action against violators
and has forced the Department to rely on the Attorney General and
county attorneys for prosecut ion. Agency records indicate that
these o f f i c i a l s often do not consider weights and measures' cases to
be serious enough to pursue.
8. The extent to which the De~ artment has addressed deficiencies i n the
enablina statutes which re vent it from f u l f i l l i n a i t s statutorv
mandate.
During the 1992 Legislative Session, the Department requested
l e g i s l a t i o n to make administrative changes to the weights and
measures statutes. House B i l l 2359, which was enacted by the
Legislature and signed by the Governor, changes the Department's
statutes in three ways. F i r s t , i t authorizes the Department to
impose c i v i l penalties up to $ 500 for violations of the weights and
measures' statutes. Second, the law authorizes the Director to
impose late charges and penalties on used oi I or used oi l fuel
transporters, burners, or marketers. Third, the Department may
issue stop- use and stop- sale orders for violations of the used o i l
laws, including f a i l u r e to pay fees and late charges.
9. The extent to which chanaes are necessary in the laws of the
Department to comply with the factors l i s t e d in the subsection.
We did not identify any changes needed in the Department's enabling
legislation.
10. The extent to which the termination of the acjency would
s i ~- n i f i c a n t l vh arm the public health, safetv or welfare.
Terminating the Department of Weights and Measures would harm public
health, safety, and welfare. The Department's role in ensuring the
accuracy of weighing and measuring devices contributes to the public
welfare by ensuring equity in commercial transactions involving
weight, measure and count, According to the chief Federal weights
and measures o f f i c i a l , the loss of State regulation would mean that
such transactions in Arizona would not be based on national
standards of weight and measure. Without such standards and State
regulation, businesses could take advantage of consumers because
consumers would have no assurances of the accuracy of devices used
in transactions. Even honest businesses might be forced to engage
in i l l e g a l practices to remain competitive under such
circumstances. The importance of weights and measures regulation i s
recognized in a l l of the other 49 states, each of which also
regulates weights and measures a c t i v i t i e s .
In addition to protecting consumers in transactions involving weight
and measure, the Department contributes to the public welfare
through i t s petroleum qua1 i t y program. Under t h i s program, the
agency tests and c e r t i f i e s the q u a l i t y o f gasoline and petroleum
products. Without the program, consumers are l i k e l y to unknowingly
purchase lower quality fuels, resulting in losses through repairs
and reduced fuel economy.
Weights and Measures also plays a role in protecting public health
and safety through i ts oxygenated fuels and used o i l programs. The
Department tests the oxygenate content of fuels sold in Maricopa and
Pima Counties during winter months. Oxygenated fuels are a major
strategy for complying with the Federal Clean Air Act in Arizona's
urban areas. The agency used o i l program assists the Department of
Environmental Quality to monitor the movement and disposal of
potentially hazardous wastes.
11. The extent to which the level of reaulation exercised by the
Department i s appropriate and whether less or more strinaent levels
of reaulation would be appropriate.
Our review indicates that the level of regulation exercised by the
Department i s generally appropriate. The Department's primary
regulatory a c t i v i t i e s are licensing and. testing devices used for
commercial weighing and measuring, verifying the accuracy of
packaged commodities, \ icensing public weighmasters and registered
service agents, and testing fuels to ensure t h e i r q u a l i t y . These
a c t i v i t i e s are' based on authority granted by law and appear to be
reasonable means for accomplishing the Department's purposes.
12. The extent to which the Aaency has used private contractors in the
performance of i t s duties and how effective use of private
contractors could be accomplished.
The Depart: ~ t does not use private contractors to perform i t s
regulatory outies. The legislation establishing the Department in
1987 directed the Department to contract with private individuals
and firms to test and inspect weighing and measuring devices. This
legislation also mandated that the Department develop a p i l o t
program for this purpose and submit the program to the Joint
Legislative Budget Committee for approval. However, the Attorney
General ruled that the requirement for JLBC approval violated the
separation of powers provision of the Arizona Constitution.
However, the Department may be able to use registered service agents
( RSA's) to provide some services to licensees that i t currently
provides. Our analysis of inspection reports found nearly 2,000
inspections conducted at the request of the licensee during the last
three years ( 1989- 1991). Since the Attorney General's opinion
addressed only the separation of powers issue, there seems to be no
legal reasons why firms and individuals licensed by the Department
cannot meet vendor requests for services. Relying on RSA's w i l l
free Department personnel for enforcement- related inspections and
a c t i v i t i e s .
TECHNICAL APPENDIX
METHODOLOGY FOR DETERMINING ESTIMATED STAFF REDUCTIONS
The Auditor General recommendation that the Department of Weights and
Measures reduce the number of i t s inspections i s based on the s t a t i s t i c a l
result that the majority of licensees and vendors normally comply with
applicable statutes and regulations. Thus, an inspection system based on
random sampling for routine inspections, follow- up inspections of
violators, and c i v i l penalties when warranted i s a reasonable, economical
a l t e r n a t i v e t o the current system.
We calculated projected staffing levels in two steps. F i r s t , we
determined the workload requirements of the system described above.
Second, we estimated the number of s t a f f needed to address this
workload. This technical appendix describes the two steps.
Workload Reauirements
We estimated workload requirements for three types of inspections that
the Department would need to perform each year: routine inspections,
follow- up inspections, and government agency inspections.
Routine inspections - Weights and Measures performed 26,965 inspections
during calendar years 1989, 1990, and 1991, or an average of
approximately 9,000 inspections per year. Our analysis of inspection
results during that three- year period showed a noncompliance rate of 8
percent. A random sample for a population of 9,000 and 8 percent rate of
occurrence would be 358 ( with precision of plus or minus 4 percent at a
99 percent confidence interval).
However, because we observed numerous problems in Weights and Measures'
data that reduce our confidence in such a small sample, the sample should
be s t r a t i f i e d . Therefore, we expanded the sample and s t r a t i f i e d i t by
program area and population density. The results are v a l i d for large
urban, small urban, and rural areas for a l l types of inspections. The
expanded sample c a l l s for 2,049 routine inspections annually. Sampling
at this level produces results with a precision level of plus or minus
1.5 percent at a 99 percent confidence level. A sample of this size is
extremely large and can provide reasonable assurance to Weights and
Measures that vendors comply with a l l legal requirements: each vendor
w i l l have an almost 25 percent chance of being selected for inspection.
In contrast, the Department of Revenue selects only about 4 percent of
i t s sales tax accounts for review.
Foilow- UD inspections - A key element of the recommended inspection
strategy i s following up on vendors not in compliance at the time of
their routine inspection. Our estimated workload assumes that Weights
and Measures w i l l follow up & I violations. Since the Department does
not currently follow up a l l violations, this assumption i s an improvement
over present practice. We assume a noncompliance rate of 10 percent ( the
actual 8 percent noncompliance rate observed in our analysis plus a 2
percent margin of e r r o r ) , or 205 follow- up inspections.
In addition to following up a l l violations found during routine
inspections, vendors that are not in compliance w i l l be subject to
further follow- up inspections for up to five years. By using a " stop and
go" ~ a m p l i " s~ tr ategy for subsequent follow- up inspections, only a small
sample size is necessary to determine the rate o f noncompliance in the
general population. When the sampler is satisfied that the rate of
noncompliance is s t a t i s t i c a l l y low enough, sampling can " stop," and no
additional inspections need to be conducted. I f too many vendors are
found to accept that their noncompliance may have been discovered by
chance, sampling can " go," ( continue) to ensure an adequate confidence
level. We estimate that from 30 to 90 follow- up inspections w i l l be
needed annually for f i v e years after an i n i t i a l violation is discovered.
Government asencies - Weights and Measures also inspects weighing and
measuring devices for c i t y , county, and State agencies ( concrete scales
on highway construction projects, for example). Our workload assumes
that the Department w i l l continue such inspections at the same rate ( an
average of 355 inspections per year) observed during our three- year
review.
The following table i l l u s t r a t e s the estimated workload for the i n i t i a l
five- year inspection cycle.
TABLE 3
ESTIMATED FIVE- YEAR WORKLOAD USING SAMPLING STRATEGY
Inspecti on
Tvpe Year 1 Year 2 Year 3 Year 4 Year 5
Routine 2,049 2,049 2,049 2,049 2,049
Government 355 355 355 355 355
Year 1 F o l l ow Up 205 0 0 0 0
Year 1 Sample 30- 90 30- 90 30- 90 30- 90 30- 90
Year 2 Follow Up 0 205 0 0 0
Year 2 Sample 0 30- 90 30- 90 30- 90 30- 90
Year 3 Follow Up 0 0 205 0 0
Year 3 Sample 0 0 30- 90 30- 90 30- 90
Year 4 Follow Up 0 0 0 205 0
Year 4 Sample 0 0 0 30- 90 30- 90
Year 5 Follow up 0 0 0 0 205
Year 5 Sample 0 0 0 0 30- 90
Total 2,639- 2.699 2,669- 2.789 2,699- 2.879 2,729- 2,969 2,759- 3.052
Using t h i s strategy, Weights and Measures' inspection workload would
increase to a maximum of 3,052 inspections in the f i f t h year. After the
f i f t h year, the sample from the f i r s t year i s replaced by the follow- up
inspection and sample from the sixth year. However, sample size may
decrease as the level of precision and the confidence interval become
more r e l i a b l e . Thus, the estimated s t a f f i n g requirements we present are
based on the expected number of inspections in the f i f t h year; the
s t a f f i n g requirements could decrease as the sample size diminishes and i f
the Department does not add new regulatory programs.
Staffina Reauirements
We estimated the s t a f f requirements based on the f i f t h year estimate of
3,000 inspections. We assumed that these inspections would be
distributed among Weights and Measures' inspection areas in the same
proportion that we observed in our 1989- 91 data analysis.(') This
d i s t r i b u t i o n i s shown below.
Inspection
TYD~
Package Control
Petroleum
Large Scales
Technical Services
Total
Distribution
In Sample
Because we also assumed that inspector productivity would remain the same
as observed in 1991, we divided the estimated number of inspections in
each area by the 1991 productivity as shown below.
Inspection
Type
Package Control
Petroleum
Large Scales
Technical Services
Total Staff Needed
l nspector Estimated
Product i v i tv( a) Staff
( a) Inspector p r o d u c t i v i t y i s defined as the number of yearly inspections p e r i n s p e c t o r
f o r an inspection program.
( 1 ) We excluded inspections conducted by the Special I n v e s t i g a t i o n s U n i t ( SIU), which
accounts f o r approximately two percent of a l l inspector a c t i v i t y , because these
inspections are p r i m a r i l y follow- up inspections. Thus, SIU inspections overlap w i t h
other u n i t inspections.
We recommend reducing the Enforcement Division s t a f f level from the
current 27 inspector positions to 11. The number of supervisory
positions can also be reduced. The Division has 6 f i r s t - l i n e supervisors
plus the Chief Enforcement Officer. Three supervisors would enable the
Department to maintain offices in Phoenix, Tucson, and Flagstaff. Thus,
the Enforcement Division would consist of 15 s t a f f , including the Chief
Enforcement Officer.
The number of s t a f f recommended by this analysis i s a generous one for
several reasons. F i r s t , at every point where we had a choice between
higher and lower numbers we chose the higher. For example, the random
sample for routine inspections is more than five times the size required
by sampling theory. In addition, when the sampling strategy for follow
up estimated a range between 30 and 90 inspections, we used 90
inspections to calculate workload. Second, the proposed s t a f f i n g level
is based on 3,052 inspections, a level that the Department w i l l not reach
u n t i l the f i f t h year of this approach. Third, we used productivity
levels that may leave room for improvement. During the audit, we
observed practices ( e. g., lack of an adequate inventory of vendors,
equipment breakdowns) that were s u f f i c i e n t l y colmnon as to have a l i k e l y
impact on the number of inspections that each employee can perform. We
also observed wide productivity levels among inspectors. Fourth, the
sampling strategy should become more reliable as data are collected over
a five year period. As a result, the number of inspections should
decrease accordingly.
For these reasons, the recommended s t a f f level is presented as an
indicator of how our proposed sampling strategy can reduce s t a f f . The
Department of Weights and Measures should review i t s operations to
further refine this strategy as i t gains experience with i t and develops
the data base necessary to manage i t more e f f e c t i v e l y and e f f i c i e n t l y .
STATE OF ARIZONA
DEPARTMENT OF WEIGHTS
AND MEASURES
FIFE SYMINGTON
GOVERNOR
DIRECTOR
October 15, 1992
M r . Douglas R. Norton
Arizona A u d i t o r General
2700 North Central Avenue, S u i t e 700
Phoenix, Arizona 85004
Dear Mr. Norton:
Thank you f o r the performance a u d i t o f the Department o f Weights and
Measures. We a p p r e c i a t e the o p p o r t u n i t y t o p r o v i d e a response.
The a u d i t r e p o r t i n d i c a t e s a number o f management areas t h a t r e q u i r e
a t t e n t i o n . For many o f the issues, the department acknowledges the
observations and conclusions i d e n t i f i e d as a basis f o r improved management
o f o p e r a t i o n s and personnel i n t h e f u t u r e . As i n d i c a t e d i n t h e r e p o r t , t h e
d e f i c i e n c i e s discussed occurred d u r i n g t h e p r i o r a d m i n i s t r a t i o n o f t h e
department. Since June 1992, a concerted e f f o r t has been made t o r e c t i f y
the problems t h a t e x i s t e d i n the past, and s i g n i f i c a n t e f f o r t s a r e b e i n g
made t o begin a new era and c r e a t e a new environment f o r t h e department.
Please note t h e f o l l o w i n g a c t i v i t i e s t h a t respond t o the major issue areas
i d e n t i f i e d i n t h e a u d i t .
IMPROVE EFFECTIVENESS AND REDUCE STAFFING.
Current management has evaluated the workload, performance, production,
schedule and o t h e r areas o f a c t i v i t y and conduct by the i n s p e c t i o n
personnel. During FY 93, t h e f o l l o w i n g i n i t i a t i v e s have been completed.
Designed a standard Weekly I n s p e c t i o n Schedule t o i n d i c a t e i n f o r m a t i o n
about s i t e s , c a t e g o r i e s and areas t h a t are planned f o r v i s i t a t i o n .
Begin development o f a new employee o r i e n t a t i o n program t o i n t r o d u c e
new i n s p e c t o r s t o both general and s p e c i f i c r e s p o n s i b i l i t i e s .
Revised the i n s p e c t i o n geographical areas f o r the State t o determine a
more p r o d u c t i v e way t o assign personnel and reduce t r a v e l costs.
Developed a means t o m o n i t o r i n s p e c t i o n s t h a t are conducted t o evaluate
the work performed and t h e compliance w i t h s t a t u t o r y requirements.
NORTHERN DIVISION
' 007 N HWY 89
P 0 BOX 2844
FLAGSTAFF, AZ 86004
1) 774- 7577
FAX 774- 7577
CENTRAL DIVISION
1951 W. NORTH LANE
PHOENIX, ARIZONA 85021
( 602) 255521 1
FAX 255- 1950
SOUTHERN DIVISION
1100E. AIOWAY
SUITE 208
TUCSON. AZ 8571 3
628- 581 0
FAX 628- 5806
October 15, 1992
Page 2
Reassigned the agency's p u b l i c i n s t i t u t i o n and education f a c i l i t y
i n s p e c t i o n d u t i e s and r e s p o n s i b i l i t i e s f o r a more e f f e c t i v e way t o
c a r r y o u t s t a t u t o r y requirements w i t h ; r e s p e c t i v e geographical areas.
- Received a u t h o r i t y by HB 2359 t o impose c i v i l p e n a l t i e s , assess l a t e
charges, and issue stop- use and s t o p - s a l e o r d e r s .
Evaluated the t r a v e l time r e q u i r e d f o r a l l i n s p e c t o r s t o determine a
more e f f i c i e n t , l e s s c o s t l y way t o complete scheduled i n s p e c t i o n s .
Prepared an i n v e n t o r y o f a l l equipment used f o r f i e l d i n s p e c t i o n s .
Reviewed t h e equipment downtime s i t u a t i o n t o improve r e p a i r and
maintenance standards and reduce c o s t s .
Developed a key i n v e n t o r y f o r a l l b u i l d i n g s and equipment f o r Phoenix
and f i e l d o f f i c e s .
- Changed pol i c y f o r more supervisory c o n t r o l o f uniform acqui s i t i o n ,
usage, and replacement f o r the i n s p e c t o r s .
Monitored the usage o f mobile telephones.
Reviewed the absentee records f o r a l l i n s p e c t o r s and developed a format
f o r easy m o n i t o r i n g .
Prepared long- term r e o r g a n i z a t i o n ideas f o r t h e D i v i s i o n .
Reviewed a l l forms used by I n s p e c t i o n D i v i s i o n t o update, r e v i s e , e t c .
i n a n t i c i p a t i o n o f o f f i c e automation.
Reorganized I n s p e c t i o n D i v i s i o n f o r g r e a t e r f l e x i b i l i t y of resources,
increased e f f i c i e n c y , and improved p r o d u c t i v i t y .
- Hired new Chief Enforcement O f f i c e r t o supervise, organize, and manage
I n s p e c t i o n D i v i s i o n .
Reviewed I n s p e c t o r Weekly Reports t o i d e n t i f y i n s p e c t o r time usage
r e q u i r i n g supervisory a t t e n t i o n and c o r r e c t i o n and t o determine
i n s p e c t o r q u a l i t v , e f f e c t i v e n e s s , and image.
Created t h e Package P r i c i n g Committee t o develop a recommendation
regarding enforcement options f o r i n d u s t r y e f f i c i e n c y and consumer
p r o t e c t i o n .
- Begin developing an i n s p e c t i o n system t o t a r g e t and p u b l i c i z e s i t e s and
devices t h a t r e q u i r e g r e a t e r a t t e n t i o n because o f t h e p o t e n t i a l o f
v i o l a t i o n s .
October 15, 1992
Page 3
Developed new overtime/ compensatory p o l i c y t o reduce o r e l i m i n a t e the
need.
Introduced new p u r p l e i n s p e c t i o n seal s w i t h Governor's name t o
d i s t i n g u i s h from p r i o r seal and created a s t a f f committee t o develop a
new seal t h a t f i t s w i t h the Department's goals and p h i l o s o p h i e s . .
Evaluate the assignment o f take- home equipment t o reduce t r a v e l costs
and increase i n s p e c t o r e f f i c i e n c y .
The f o l l o w i n g i n i t i a t i v e s w i l l be completed i n FY 93.
Review the personnel resources expended t o c o l l e c t l i c e n s e fees t o
i d e n t i f y a more p r o d u c t i v e way t o achieve t h e o b j e c t i v e and a more
e f f e c t i v e use o f manpower.
Develop a formal i n q u i r y / c o m p l a i n t procedure t o i d e n t i f y the number,
type, and d i s p o s i t i o n o f a l l c o n t a c t s .
a Review the monthly Department o f Revenue p r i n t o u t o f new businesses t o
i d e n t i f y a d d i t i o n a l i n s p e c t i o n s t h a t need t o be scheduled.
Prepare an annual t r a i n i n g plan f o r the I n s p e c t i o n D i v i s i o n .
- Prepare both short- term and long- term goals and o b j e c t i v e s f o r the
I n s p e c t i o n D i v i s i o n .
Review the r o l e o f R e g i s t e r e d S e r v i c e Agencies and Representatives t o
determine an improved way t o t e s t , monitor, evaluate performance, and
increase f i e l d r e s p o n s i b i l i t y .
Although we agree w i t h the concept t h a t i n s p e c t i o n resources can be m o d i f i e d
t o achieve d i f f e r e n t enforcement goal s, t h e s p e c i f i c recommendati ons
regarding s t a f f r e d u c t i o n s r e q u i r e f u r t h e r e v a l u a t i o n before s t a f f t a r g e t
l e v e l s can be determined. The a u d i t suggests t h e e l i m i n a t i o n o f 19
i n s p e c t o r p o s i t i o n s . Because the department i s i n t r o d u c i n g d i f f e r e n t
approaches t o i n s p e c t o r a c t i v i t i e s ( r e d e f i n e d geographical areas, reassigned
p u b l i c i n s t i t u t i o n a c t i v i t i e s , assigned take- home equipment, e t c . ) , it i s
premature t o commit t o a s p e c i f i c number a t t h i s time. The department w i l l
also need t o study o t h e r f a c t o r s , such as the i n t . r o d u c t i o n o f a d d i t i o n a l
i n s p e c t o r r e s p o n s i b i l i t i e s f o r the Vapor Recovery Program and t h e impact on
revenue.
I n compl iance w i t h the proposal, however, the department i s doing e v e r y t h i n g
p o s s i b l e t o achieve the u l t i m a t e g o a l . S e l e c t e d vacancies i n the I n s p e c t i o n
D i v i s i o n w i l l n o t be f i l l e d u n t i l the need a r i s e s , i f a t a l l . The r e s u l t o f
normal employee a t t r i t i o n ( r e t i r e m e n t , t r a n s f e r , e t c . ) w i l l enable the
department t o achieve t h i s goal w i t h i n t h e next eighteen months.
October 15, 1992
Page 4
TURMOIL AMONG AGENCY STAFF.
The a u d i t c l e a r l y s t a t e d t h a t t h e work environment t h a t impacted s t a f f
morale and performance i s a t h i n g o f t h e p a s t . New management i n i t i a t e d
p h i l o s o p h i e s and p r a c t i c e s t h a t are having a demonstrable impact on employee
a t t i t u d e s , conduct o f business and working c o n d i t i o n s . S p e c i f i c a l l y , t h e
f o l l o w i n g a c t i o n s have been taken.
P a r t i c i p a t o r y Management. Major p r o j e c t s i n which t h e department i s
i n v o l v e d a r e assigned t o teams o f employees t o research, d i s c u s s , and
propose o p t i o n s f o r management t o c o n s i d e r . Examples o f team p r o j e c t s
i n c l u d e budget p r e p a r a t i o n , f a c i l i t y r e l o c a t i o n , vapor r e c o v e r y , and annual
r e p o r t . I n t h e f u t u r e new employee teams w i l l be c r e a t e d t o a s s i s t
management i n o t h e r areas o f department o p e r a t i o n .
I n f o r m a t i o n Systems. I n f o r m a t i o n t h a t i s developed f o r i n t e r n a l and
e x t e r n a l review, a p p r o v a l , and d i ssemination i s now channeled t h r u t h e
Deputy D i r e c t o r f o r c o n s i s t e n c y , c l a r i t y , and accuracy. The i n t r o d u c t i o n of
a more e f f i c i e n t and e f f e c t i v e d a t a management system w i l l p r o v i d e a support
base f o r t h i s i n f o r m a t i o n . Examples o f these areas i n c l u d e i n s p e c t i o n
assignments, d e v i c e l i c e n s i n g , and R e g i s t e r e d S e r v i c e Agency r e g i s t r a t i o n .
P o l i c i e s and Procedures. Both s t a t e and department p o l i c i e s and
procedures r e l a t i n g t o employee conduct and performance are now a p p l i e d
c o n s i s t e n t l y among a l l personnel. Examples o f such p o l i c i e s i n c l u d e
overtime/ compensation t i m e , work assignments, e t c .
Other a c t i o n s o f improved management t h a t have f a v o r a b l y impacted s t a f f
morale i n c l u d e :
I n i t i a t e d b i - w e e k l y s t a f f meetings f o r a l l s u p e r v i s o r s and management
p e r s o n n e l .
I n i t i a t e d r e v i e w o f agency computer needs t o i n t r o d u c e a more e f f i c i e n t
and e f f e c t i v e system.
Required a1 1 employees t o a t t e n d sexual harassment and e t h i c s t r a i n i n g
sessions.
Encouraged a l l employees t o t a k e advantage o f t h e S t a t e ' s c o n t i n u i n g
e d u c a t i o n program t o improve j o b s k i l l s and c a r e e r o p p o r t u n i t i e s .
Arrange team b u i l d i n g sessions t o f a c i l i t a t e communications and
r e l a t i o n s among a l l employees.
Developed new c o l or- coded, mu1 t i - p a g e leave s l i p f o r improved accuracy
and a c c o u n t a b i l i t y o f i n f o r m a t i o n and s u p e r v i s i o n o f r e c o r d system.
Prepared r e c o r d o f a l l mobil telephone/ page assignments f o r p e r s o n n e l .
October 15, 1992
Page 5
E l i m i n a t e d a l l unnecessary b u i l d i n g keys and s e c u r i t y access codes and
assigned new codes t o a l i m i t e d number o f employees.
Redesigned two employee b u l l e t i n boards f o r improved communication o f
i n t e r n a l and e x t e r n a l i n f o r m a t i o n and announcements.
Resolved past- due e v a l u a t i o n grievances t o the s a t i s f a c t i o n o f
employees involved.
Requested study of p o s i t i o n s w i t h i n the department t o determine
a p p r o p r i a t e grades f o r work performed.
USED OIL PROGRAM
It i s the department's u l t i m a t e goal t o a t t a i n a s e l f - s u s t a i n i n g s t a t u s f o r
the Used O i l Program. A r e a l i s t i c approach would a l l o w f o r a three- year
t r a n s i t i o n from t h e c u r r e n t l e v e l t o one t h a t i s more c o m p e t i t i v e i n the
marketplace and produces s u f f i c i e n t revenue f o r the o p e r a t i o n o f the
program. This year, an i n d u s t r y advisory committee w i l l be appointed t o
research and evaluate a l l fees charged t o determine a f a i r , reasonable, and
c o m p e t i t i v e l e v e l .
FISCAL ISSUES
As you know, the Department has been experiencing a management t r a n s i t i o n .
The budget request f o r next f i s c a l year focuses on areas t h a t a l l o w t h e
department t o comply w i t h l e g i s l a t i v e mandates and keep pace w i t h service
growth. The f o l l o w i n g budget requests are necessary f o r the agency t o
c o n t i n u e o p e r a t i o n s i n a responsible, p r o d u c t i v e , safe manner.
1. Vapor Recovery Program support t o avoid the l o s s
o f $ 30 m i l l i o n i n f e d e r a l surface t r a n s p o r t a t i o n
funds.
2. Q u a l i t y Assurance Program funding t o p r o t e c t the
s t a t e ' s i n t e g r i t y i n sampling g a s o l i n e , d i e s e l ,
and used o i l .
3. Metrology Program equipment t o assure complete
and accurate t e s t i n g t o maintain n a t i o n a l
c e r t i f i c a t i o n f o r operations.
As new management continues t o improve the o p e r a t i o n o f the agency,
a d d i t i o n a l needs have been i d e n t i f i e d . Funds are c u r r e n t l y l a c k i n g t o
adequately accommodate the day- to- day a c t i v i t i e s o f the department i n the
new l o c a t i o n . Support equipment i s nonexistent, outdated, o r i n e f f i c i e n t
and r e q u i r e s a c q u i s i t i o n , upgrade, o r m o d i f i c a t i o n . I n a d d i t i o n , funds f o r
ins. pector t r a i n i n g are not a v a i l a b l e . Funding i s r e q u i r e d t o develop a
October 15, 1992
Page 6
t r a i n i n g program f o r the safety, i n t e g r i t y , and knowledge o f the employees
who r e g u l a t e a consumer o r i e n t e d i n d u s t r y .
The performance a u d i t provides e x c e l l e n t guidance f o r the department's
f u t u r e planning. The document w i l l be used as p a r t o f a s t r a t e g i c plan f o r
improving the e f f i c i e n c y and e f f e c t i v e n e s s o f the department. It would be
advantageous f o r the A u d i t o r General t o continue t h i s work i n other
d i v i s i o n s s p e c i f i c a l l y t h e A d m i n i s t r a t i v e D i v i s i o n , Metrology Laboratory,
and Petroleum Laboratory, and we i n v i t e you t o arrange t h i s work i n t h e near
f u t u r e t o c o i n c i d e w i t h o t h e r e f f o r t s being made by management.
Thank you again f o r a l l o f y o u r a s s i s t a n c e and guidance.
D i r e c t o r