Connecticut's Program Benefits, Program Improvement, and Lessons Learned18
Over the eight years that Connecticut’s Child Daycare SAFER Program has operated, approximately 46 ECE programs have been referred to EOHA for follow-up. Of these referrals, nine (20%) had potential environmental problems that needed additional environmental assessment. The additional data identified four ECE programs with contamination that needed to be addressed through soil remediation, drinking water treatment, or by providing bottled water. In all of these cases, the SAFER Program identified environmental exposures that might not have been identified through other channels. This shows the primary benefit of the program.
The SAFER Program has also provided ancillary, unanticipated benefits. Before initiating the SAFER Program, EOHA staff and licensing staff had little contact with each other (even though at the time, both programs were housed in the same branch within CT DPH). The SAFER Program has fostered new areas of interaction between licensing staff and EOHA. For example, child care inspectors identified a need for information and resources regarding safer alternatives for sanitizing and disinfection products used in daycares. Because of the SAFER Program, they contacted the EOHA Program for assistance. In response, indoor environmental quality staff within the EOHA Program prepared a fact sheet and provided training to ECE program workers and licensing staff about safer cleaning products and approaches.
Connecticut SAFER Program: Track Record
- Approximately six ECE programs per year are referred for follow up.
- On average, one ECE program per year has potential problems warranting environmental assessment.
- So far, four ECE programs needed interventions to reduce exposure to contamination.
- Referrals represent less than one percent of total ECE programs in Connecticut.
- Work load has been manageable with existing staff.
Some important lessons have been learned since the SAFER Program began. First, the Connecticut experience indicates that most ECE programs do not have environmental problems. Among all ECE programs included in the SAFER Program, only a few (about six per year) are referred for follow up. Of those referred for follow-up, still fewer needed additional testing or remediation. Connecticut’s experience also shows that the necessary follow-up work can be done using existing state health department staff, without slowing the licensing process. A major concern when the SAFER Program was first being discussed in Connecticut was that the program would slow the licensing process.
Connecticut has also learned that it is important to establish clear protocols and build good documentation for all daycares referred for follow-up. Establishing clear protocols and documentation ensures that the program will be able to sustain itself, even with changes in staff or management. Maintaining good documentation of all follow-up work also ensures that ECE programs that received a prior SAFER Program follow-up can be identified quickly and easily if they come through the referral process again.
In Connecticut’s SAFER Program, EOHA is the primary unit responsible for operating the program. EOHA is the group within CT DPH with the expertise to evaluate exposures and risks from hazardous substances in the environment. Connecticut has learned through its SAFER Program experience that a unit with this type of expertise is the ideal group to coordinate, promote, and support a statewide safe child care siting initiative. Connecticut has also learned that a program works more effectively if a single unit assumes responsibility for overall coordination and promotion of the program.
As previously mentioned, Connecticut chose to pursue a non-regulatory ECE siting approach because it was quicker and easier to start using than establishing new regulations. When EOHA first discussed ideas for the SAFER Program with the licensing staff, it was agreed that a non-regulatory program would be more likely to be viewed positively by ECE operators than additional regulations, which might be viewed as onerous. By not having a rigid regulatory structure, SAFER Program staff can easily modify procedures and approaches as needed. Connecticut operates its SAFER Program with existing resources, which probably could not have been done if the program had involved new regulations. Although no regulatory requirements mandate that SAFER Program guidelines and recommendations be followed, Connecticut has not yet encountered significant difficulties regarding ECE program compliance with the recommendations. EOHA coordinates closely with the licensing staff, the local health department, and CTDEEP on all SAFER recommendations. Consequently, there is concurrence on all recommendations before they are communicated to the child care facility or property owner. Further, SAFER recommendations are communicated by the local health department or child care licensing staff, both of whom have regulatory authority, and not by EOHA, which has no regulatory authority. These are likely the key reasons why ECE programs are complying with SAFER Program recommendations, even though they are not obligated by regulation to do so.
Connecticut’s experience has also highlighted aspects of the SAFER Program that need improvement. First, a handful of inspectors at the state and local level refer most of the ECE programs. Connecticut is working on ways to improve training content and target training messages to those inspectors who have never made a referral. Connecticut also knows that awareness of the SAFER Program is low among local planning and zoning officials. Connecticut has never received a referral from a local planning or zoning department. Additional outreach to local planning departments would increase awareness.
A recently completed improvement to the program is a redesign of the property history questionnaire given to new license applicants. State licensing staff and ECE program applicants using the form identified elements that could be improved. The redesigned questionnaire is now fillable electronically and is simpler to use, which should improve information collection.
Although Connecticut has had great success with its SAFER Program, the lack of enforceable regulations might be viewed by some as a drawback.