Appendix C: Community Check List
This guidance manual was written to provide guidance to new and experienced health assessors when performing the variety of tasks associated with site-specific activities involved in the public health assessment process. The manual presents specific approaches, methods and resources for the public health evaluation of environmental exposures associated with a hazardous waste site. Chapter 4 has provided many suggestions and procedures that may be utilized in communicating and coordinating with the affected community during this process.
ATSDR’s Board of Scientific Counselors, a chartered federal advisory committee, also recognized the importance of community involvement and established a Community Tribal Subcommittee. That subcommittee has prepared the checklist contained in Appendix C; the checklist emphasizes a community/ tribal perspective on the key concepts found within the guidance manual. Agency staff, and others involved in site related activities should consider this as an additional tool during the public health assessment process.
The questions posed in this checklist represent the information needs that communities and tribes may have during the public health assessment process. If these questions are considered at the outset, appropriate information can be provided in the PHA which will satisfy community and tribal understanding of the process, findings, and conclusions. It cannot be stressed enough that ATSDR must engage and involve communities and tribes throughout the public health assessment process.
Community Check List For Site Activities During the Public Health Assessment Process
The Public Health Assessment (PHA) prepared by ATSDR and by cooperating states is a critical document for communities affected by hazardous waste sites and/or toxic releases. PHAs not only provide an assessment of potential exposure but also recommend actions needed to protect public health.
Over the past 4 years, the Community/Tribal Subcommittee (CTS) to ATSDR’s Board of Scientific Counselors (BSC) has recommended changes aimed at making both the PHA process and documents more responsive to community concerns and needs. Subsequently, the CTS organized a task force (Task Force 5) to provide more detailed recommendations to the PHA process.
The Community Check List for PHAs was developed by Task Force 5 of the CTS and revised by Henry S. Cole, Ph.D. to incorporate comments received from Special Consultants, and officials from ATSDR and the Washington State Department of Health.
The Community Check List can be used not only by communities but by health assessors to help develop and evaluate PHAs. The Check List can:
- Help health assessors (from ATSDR or states) better understand and respond to community concerns and expectations.
- Be used at the start of the PHA so that community members can work with ATSDR or state agencies to improve the PHA process.
- Can be used by community members as a guide when they review the draft PHAs. It can also be used by outside reviewers.
Explanatory notes. The “Community Check List for PHAs” is not meant as a substitute for ATSDR’s guidance on PHAs. Instead, the check list may help health assessors better view the site from the standpoint of community members that are looking for meaningful participation and understanding that they are not at risk from chemical exposure. Although the check list can be used to evaluate PHAs, it is not meant to as a detailed scoring system. Some of the elements may not apply to every site. Instead, it is designed to facilitate the planning process and to:
- Make the PHA process more community friendly and culturally sensitive from the outset
- Promote PHAs that are clearly written and responsive to community health needs
- Encourage assessors to obtain sufficient information from which to base conclusions
- Ensure that recommendations for action are fully protective of community health with an adequate margin of safety.
A number of the items on the check list are especially important for particular types of communities or sites. These are indicated in bold as follows:
FF = Federal Facility Site
TC = Tribal community
EJ = Environmental Justice community
Please note that ATSDR and state health assessors should be aware of special protocols applicable to tribal communities due to the sovereign status of tribal nations. Elements pertaining to tribal protocol are contained in Section 6.
Similarly, assessors should be aware of the many special problems and needs regarding environmental justice in minority and low income communities is a factor (see Section 7).
Components of the Check List
1.0 Clear Explanation of the PHA process.
Did agency officials:
- Provide a clear explanation of the PHA process early?
- Propose a timetable for the process?
- Clearly identify the roles of agency officials, contact persons, etc.?
- Identify members of the agency “site team?”
- Explain how PHA’s lead to action plans?
- Describe ATSDR’s limitations in regards to the actions open to it?
2.0 Community Involvement
2.1 Outreach and method of involvement
- What level of effort was made to identify and reach members of the affected community?
- What attempt did agency officials make to find out how the community wanted to be engaged? TC, EJ
- Were tribal protocols identified and respected by the assessment team? TC
- If community members initially distrusted the agency, what steps were taken to overcome the problem? EJ, TC
- Did community involvement start early in the PHA process?
- Were appropriate methods used to involve people in tribal and environmental justice communities? Were bilingual communications used where a significant portion of the population do not speak or read English? TC, EJ
- Were one or more community members involved on the agency’s “site team?”
- Was there a formal (e.g. Community Assistance Panel) or informal stakeholder process?
2.2 Concerns, input and communications
- What efforts were made to solicit community concerns?
- Was there a mechanism that allowed or encouraged continual communications and input throughout the process?
- Were key agency officials accessible to community members and responsive to their questions and concerns throughout the process?
- Were community members (and their experts) given an opportunity to review PHA plans and protocols before they were finalized? Were community concerns addressed in such protocols?
- Did the agency share important results with community members “along the way?”
- Were community members given timely notice regarding schedules, dates, deadlines and changes in schedule?
- Did community members receive ample time to review the Draft PHA? Was an extension of comment period granted if meaningful requests were made?
3.0 History, culture, demographics, vulnerable populations and land use
3.1 Obtaining information
Does the PHA:
- Fully describe the location and composition (demographics) of the “affected community?” EJ, TC
- Describe the history of the hazardous waste site relative to this community (history of sources, releases, pathways, exposure)?
- Describe the land use in the site area and its history? TC
- Does the PHA fully identify cultural practices and socio-economic conditions that can affect exposure to site contaminants and to the effects of such contaminants on health? For example, does the PHA thoroughly document the potential impact of consumption of local game and fish for subsistence (especially important for tribal and rural communities)? EJ, TC
3.2 Other questions
- Did assessors talk to long-time residents in developing the history and profile of the community? EJ, TC
- What steps were taken to identify vulnerable populations / susceptible communities, and those most at risk (example, sickle-cell anemia)? EJ, TC
- Does the PHA delineate specific eating habits, e.g. consumption rate foods, drinking water, etc.? EJ, TC
- Did the agency respect and hold confidential information considered to be proprietary by tribes including information on cultural, dietary and healing practices? TC
- Were all available data sources carefully considered and used appropriately?
- Were health agency personnel sensitive and respectful of community members in gathering information and soliciting community concerns? EJ, TC
4.0 Identifying potential exposure pathways
4.1 Obtaining information from the community
- Did the assessor(s) conduct “scoping visits” to determine potential exposure pathways?
- Did these visits include meetings or tours with area officials, with community members, with petitioners (at petition sites)? EJ, TC
- Did the agency conduct public availability sessions?
- Were potential pathways of concern to community members identified by area residents investigated?
- Did the assessment identify and solicit concerns from appropriate clinics or other practitioners?
- Did the agency work with community members to incorporate appropriate community-based sources of information e.g. specific health concerns, anecdotal evidence, or health surveys conducted by community groups? TC, EJ
4.2 Background and multiple sources of exposure
- How is background defined in the PHA? Is it defined as natural levels of contamination? Is it defined as contamination (both natural and manmade) not related to the source or site of concern?
- Did the PHA describe additional sources of contamination (those other than the target site) and exposure that may affect the same community? (Multiple sources)
5.0 Environmental and biological sampling
To properly assess the health of a community based upon past, present and future exposures, the agency must have ample appropriate data.
5.1 Environmental sampling
- Was the environmental data base supplied by regulatory agencies adequate to conduct the assessment and to evaluate exposure pathways identified?
- Did the PHA rely predominantly on data generated by potentially responsible parties? FF
- Were gaps in environmental data (e.g. soil, groundwater or air contaminant levels) clearly identified in the PHA?
- What attempts were made to fill data gaps? Did ATSDR recommend additional sampling to the regulatory agency? FF
- Did the health agency conduct its own sampling program if regulatory agencies (or federal facilities) failed to provide important data? FF
- Did ATSDR or state health agency consider community-based sampling where there were data gaps?
- Did the data base include offsite testing where potential offsite exposure was a concern to the community? FF
- Did the sampling contain sufficient number of background samples to define “background?”
5.2 Biological testing
- Did ATSDR conduct biological testing when requested by community members?
5.3 Past exposures
- Did the agency attempt to locate or obtain (see 5.4) materials needed to reconstruct likely historical/past environmental health exposures?
6.0 Tribal Protocols
6.1 Working with Tribal Governments
- Were Tribal Governments contacted and brought into the process at the start?
- Was proprietary (culturally sensitive) information identified (to the extent knowable) prior to beginning a PHA?
- Were protocols agreed upon with Tribal governments in advance? Were, meetings held (as needed) to ensure the tribe is satisfied that such protocols are being followed?
- Were Tribal Governments allowed to negotiate with the Agency regarding proprietary (culturally sensitive) information? Propriety information should be withheld from publication.
- Did the agency encourage and support open meetings of the tribal membership?
- Were community members given timely notice regarding schedules, dates, deadlines and changes in schedule?
- Did the Tribal Government receive ample time to review the Draft PHA? Tribal Government should be allowed to review and comment on Draft PHA before public comment period.
- Were Tribal environmental staff included in the process and allowed to observe and/or participate in data collection activities?
- Were cultural practices included in PHA recommendations? Proprietary (culturally sensitive) information may be included, but only if approved by the Tribal government.
6.2 Collecting information and data in tribal communities
- Was the tribe consulted regarding land use and cultural practices that potentially lead to exposure?
- Did the Agency thoroughly document the potential impact of specific life style factors such as consumption of local game and fish for subsistence?
- Did the agency take steps to identify vulnerable populations / susceptible communities, and those most at risk (i.e. children, elders, and the most traditional members)?
- Did the agency ensure that health agency personnel are sensitive and respectful of community members in gathering information and soliciting community concerns?
- Did the agency utilize a tribal member to work with the agency during the PHA process?
- Did PHA delineate specific consumption rate of foods, drinking water, etc.? This information should be provided by the tribe from data they collect and agree to divulge for purposes of the PHA.
- Did ATSDR, EPA and state agencies consider tribal-based sampling including where there were data gaps?
- Were tribal staff and/or tribal consultants involved with sampling if requested?
7.0 Environmental Justice
Minority and low-income communities are often disproportionately impacted from environmental pollution but have unequal access to environmental and economic benefit. Health assessors should ensure that affected community members from these sites are involved in all aspects of PHA development and to ensure that ATSDR and state agencies address the special needs and circumstances of these communities. Specific questions are as follows:
- Were appropriate methods use to involve people in environmental justice communities? What attempt did agency officials make to find out how the community wanted to be engaged?
- Were bilingual communications used where a significant portion of the population do not speak or read English?
- If community members initially distrusted the agency, what steps were taken to overcome the problem?
- What measures did the agency take to build the capacity of the affected community to ensure full participation?
- Were health agency personnel sensitive and respectful of community members in gathering information and soliciting community concerns?
- Does the PHA fully describe the location and composition (demographics) of the “affected community?”
- Does the PHA delineate specific eating habits, e.g. consumption rate foods, drinking water, etc.?
- What steps were taken to identify vulnerable populations / susceptible communities, and those most at risk (example, sickle-cell anemia)?
- Environmental justice communities often experience many potential sources of contamination and exposure. Does the PHA address the issue of multiple environmental stresses?
- Does the PHA fully identify cultural practices and socio-economic conditions that can affect exposure to site contaminants and to the effects of such contaminants on health including stress factors?
- Do the recommended public health actions adequately consider socio-economic and cultural practices in the affected community? Are they socially and culturally applicable to the specific community of concern?
8.0 The PHA Document
8.1 Exposure pathways and health effects
- Does the PHA document clearly discuss pathways and routes of exposure?
- Does the PHA provide a clear rationale provided for not considering other pathways?
- Did the assessors evaluate all potential pathways of concern to community members?
- Did the assessors fully explain the basis for eliminating pathways as possible causes for concern? Was there adequate data available to eliminate such pathways?
- Are the methods for selecting contaminants of concern clearly identified?
- Did environmental concentrations exceed health-based target levels, regulatory standards or criteria, or cleanup targets?
- How did the finding of concentrations above health-based levels or standards affect the PHA conclusions, especially those associated with potential or completed exposure pathways?
- How did the results of bio-testing affect PHA conclusions?
- Were possible additive or synergistic mechanisms considered in cases of multi-chemical and/or multiple exposure pathways? Did such considerations translate into conclusions and recommendations?
8.2 Adequacy of data and uncertainties
- Are the data presented clearly with supporting information?
- Are the conclusions (especially those on the degree/ categories of public health hazard) supported by the evidence presented in the document?
- Did the PHA document clearly identify and describe data gaps, concerns about data validity and scientific uncertainties and state how these problems impact conclusions?
- Does the PHA acknowledge that it “doesn’t know” when it “doesn’t know?”
- Does the final PHA document fully address comments by community members on the draft PHA? Were changes made that better address community concerns?
- Is the PHA document written in a manner that is clear and understandable to members of the affected community?
- Is a second language version available where a significant portion of the community has difficulty reading or understanding English? EJ, TC
9.0 Recommendations/Public Health Actions
- Were community members involved in developing the recommendations and the action plan?
- Were a full range of alternatives considered in selecting recommended health actions?
- Is the action plan sufficient to address health hazards or data needs identified?
- Are the recommendations protective, reliable, and precautionary from the standpoint of public health?
- Does the PHA explain the basis for eliminating more protective options than the alternative(s) selected?
- Does the PHA document fully explain the basis for the options (recommendations) selected for the action plan?
- Did the PHA recommend filling data gaps identified?
9.1 Cultural practices and vulnerable populations
- Does the action plan adequately consider cultural practices? EJ, TC
- Does the action plan adequately consider vulnerable populations? Provide an additional level of protection or prevention? EJ, TC
- Are there sufficient resources identified to carry out the plan?
- Is the plan affordable or practical for community members?
- Can the plan be implemented in a timely manner? (What is the timeline for implementation?)
Use of CERCLA authority to obtain needed information. Although ATSDR and state agencies attempt to obtain information through the voluntary cooperation of PRPs, both Superfund and RCRA contain provisions that allow ATSDR to obtain such information in cases where PRPs fail to provide information needed to conduct PHAs and other Superfund / RCRA mandates.The following provisions are especially applicable to sites where assessors have had difficulty in obtaining information from PRPs.
- Did the agency use these authorities to require PRPs to submit documents and other information required to assess environmental exposures?
- If not, did the agency conduct an investigation to determine whether such materials exist and should be considered?
Comment – ATSDR is developing policy on use of these investigative authorities. Once established, this policy may provide structure and procedure for these authorities.