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Chapter 1: Statement of Problem, Burden, and Manual Overview

The Problem

The Agency for Toxic Substances and Disease Registry (ATSDR) created the national Choose Safe Places for Early Care and Education 2 (CSPECE) Guidance Manual  to protect children from health risks caused by locating (siting) and operating early care and education (ECE) programs on or near places where environmental hazards are present. In the United States, about 8.3 million children younger than five years are cared for in licensed child care centers [1]. Children in these programs could be at risk from environmental exposures if the programs they attend are not safely sited.

Until recently, the potential for harmful environmental exposures from the location of ECE programs was not given much consideration. Although every state and the District of Columbia has licensing requirements for ECE programs, what is included in those licensing requirements varies from state to state. Most states do not have licensing regulations that specifically address hazardous environmental exposures that can occur from the location of the ECE program [1].

Improperly siting an ECE facility can have consequences. In particular, children and ECE staff can be exposed to harmful levels of hazardous contamination. The mere presence of contaminants at an ECE program can cause stress, worry, and fear among staff and parents, even if exposures are not significant. It can also lead to financial and legal consequences for the ECE program.

How does this manual fit into other Department of Health and Human Services initiatives?

The CSPECE manual enhances efforts to protect children from environmental exposure by providing a conceptual model for building a safe siting program to address the environmental safety of an ECE site. Also, tools and resources are provided that can be used throughout the process of implementing a safe siting program.

The Administration for Children and Families (ACF), in the U.S. Department of Health and Human Services, is responsible for several programs that directly influence ECE programs across the United States. Two of these programs, the Office of Child Care and the Office of Head Start, recently released updated rules to help ensure the safety of children who attend child care and Head Start programs. These rules are the Head Start Program Performance Standards, and 2016 Child Care and Development Fund Final Rule, which was based on the Child Care and Development Block Grant Act of 2014 (Public Law 113-186). The law identifies minimum health and safety requirements, training requirements, and monitoring requirements to ensure that ECE facilities receiving Child Care and Development Fund financial assistance protect children’s health and safety [5]. The reforms will benefit more than 1.4 million children receiving child care subsidies, as well as other children who receive no direct funding [5].

In promulgating the CCDF rule, ACF referred to Caring for Our Children Basics: Health and Safety Foundations for Early Care and Education Settings, released in 2015. Caring for our Children Basics is voluntary guidance which presents the minimum health and safety standards experts believe should be in place where children are cared for outside of their homes—regardless of program or funding stream [3].

ACF also referred to Caring for Our Children Basics in new Head Start Performance Standards. These standards enforce requirements to help ensure the safety of all Head Start programs. The standards state that “A program must establish, train staff on, implement, and enforce a system of health and safety practices that ensure children are kept safe at all times. A program should consult Caring for our Children Basics…” [6].

The ATSDR CSPECE guidance manual relates to several of the standards contained in Caring for Our Children Basics, including the following:

  • 4.2.0.6 — Availability of drinking water.
  • 5.1.1.2 — Inspection of buildings.
  • 5.1.1.5 — Environmental audit of site location.

The CSPECE guidance manual can help states or locales in addressing the standards included in Caring for Our Children Basics by

  • Describing how environmental exposures can happen at ECE programs.
  • Providing a conceptual model for building a local or state level program to address safe siting.
  • Providing tools to help in screening sites.
  • Providing resources that can be used throughout the implementation process.

Public Health Burden and Impact: Current Knowledge from Two States
Determining how many ECE programs are improperly sited is challenging. The experiences of two states provides some information on the scope of the problem.

In 2007, the Connecticut Department of Public Health (CT DPH) created its Child Care Screening Assessment for Environmental Risk (SAFER) Program. The SAFER Program finds ECE programs on or near properties where the presence of hazardous chemicals could harm children. It also strives to raise awareness at the state and local level about ECE program siting. CT DPH receives approximately six referrals each year for follow-up regarding environmental concerns. On average, one child care program of the six has potential problems warranting environmental assessment. Between 2007 and March 2016, the SAFER Program has

  • Addressed 46 ECE program referrals for site-related concerns affecting about 800 children.
  • Determined that 10 of the 46 referrals required more data to assess the site.
  • Recommended that five programs take actions to prevent potential harmful exposures for 87 children [7].

Given that CT DPH’s program is voluntary, the total burden in the state might be greater.
The state of New Jersey passed detailed regulatory requirements in 2007 relating to environmental conditions at the site of child care facilities in the state. Between 2007 and March 2016, among 3,939 licensed child care centers in New Jersey

  • 671 centers (17%) were identified where actual or potential air exposures of concern were possible from incompatible prior use or co-location with a contaminated waste site, dry cleaners, nail salon, or another site.
  • 422 (11%) had air contaminant levels above the New Jersey Department of Environmental Protection’s screening values, which resulted in further evaluation.
  • 87 (2.2%) child care centers had possible harmful exposures and action was needed [8].

In New Jersey and Connecticut, about 6,000 children have been protected from harmful exposures to contaminants identified at ECE sites since 2007.

ATSDR has worked on sites across the country where ECE programs have been in locations that were not safe. Most sites come to the attention of ATSDR after the exposure has been recognized. Determining the number of children at risk for harmful environmental exposures across the United States is challenging. Only limited data are available to estimate how many ECE programs and children in those programs might be at risk for exposures. Using data from one state and extrapolating it to the rest of the country is one way to try to calculate and estimate, even if it has limitations. Using this strategy, ATSDR estimates that 1.35 million children are in programs that warrant additional evaluation to ensure the site is safe, and about 174,000 children might currently be exposed to harmful contaminants.3

2 Early care and education (ECE) encompasses child care, family child care homes, Head Start, and pre-K settings. Although this manual can be used to identify potential siting issues at any of these facility types, its focus is on licensed child care facilities. The term “early care and education or ECE” will be used in this manual except for references that only apply to licensed child care facilities or where material from other sources specifically refer to child care or daycare centers and not ECE programs as a defined here.

3See Appendix E for how these data were calculated and limitations on the data.

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