The EPA IG concludes:
We found no evidence that the EPA used, promoted or encouraged the use of private “non-governmental” email accounts to circumvent records management responsibilities or reprimanded, counseled or took administrative actions against personnel for using private email or alias accounts for conducting official government business. EPA senior officials said they were aware of the agency records management policies and, based only on discussions with these senior officials, the OIG found no evidence that these individuals had used private email to circumvent federal recordkeeping responsibilities.
The previous EPA Administrator and the then Acting EPA Administrator who followed were issued two EPA email accounts. One account was made available to the public to communicate with the EPA Administrator and the other was used to communicate internally with EPA personnel. This was the common practice for previous Administrators. The practice is widely used within the agency and is not limited to senior EPA officials. These secondary EPA email accounts present risks to records management efforts if they are not searched to preserve federal records.
The agency recognizes it is not practical to completely eliminate the use of private email accounts. However, the agency had not provided guidance on preserving records from private email accounts. The EPA has not implemented oversight processes to ensure locations provide consistent and regular training on records management responsibilities, and employees complete available training on their delegated National Records Management Program duties. Inconsistencies in employee out-processing procedures pose risks that federal records are not identified and preserved before an employee departs the agency. EPA also lacks an automated tool to create federal records from its new email system.