Follow-Up on Potentially Problematic ECE Programs and Locations
Another key component of an ECE safe siting program is having a process for referral and follow up on ECE programs identified as having potential problems. If you have multiple methods for identifying potential problems, you will receive referrals from different entities, such as local zoning boards, ECE program licensing groups, and local health departments. You will greatly benefit from establishing a procedure for how your partners communicate information to you about potential problem ECE settings. The procedure could be as simple as an email or telephone communication, or providing a copy of an inspection report or operator certification or questionnaire. After an ECE program is referred, it is a good practice to document all follow-up activities, including all communications. Data evaluations and conclusions about exposures and risks also need to be documented. ATSDR health consultation and technical assistance documents provide a good format for documenting such health evaluations and other follow-up activities and interventions.13 Maintaining good documentation is also important for tracking the progress and accomplishments of the program and conducting evaluations of how the program is performing.
A good practice is to make one agency or unit responsible for coordinating the follow-up activities. Coordination and communication are extremely important and simpler with a single point of contact. The group responsible for following up does not need to have the expertise to address all the potential issues, but they need to communicate and coordinate with those who have the appropriate expertise. Coordination with staff members who have regulatory or licensing authority for ECE programs is especially important because those persons might have licensing timeframes or deadlines that are pertinent to the follow-up or enforcement activities. Lastly, because the licensing and inspection staff usually have ongoing interactions with operators, it is important to closely coordinate with them on follow-up activities such as site visits or any other activities involving direct communication with the operator.
As stated earlier, the group ideally suited for the lead role in follow-up activities is a state health department with expertise in assessing exposures and health risks from hazardous substances in the environment. This is because the follow-up process will conclude with a health call regarding whether the ECE program is safe or whether exposure reduction actions are needed. Those actions might range from soil remediation to drinking water treatment or installation of a sub-slab ventilation system. Because risk communication might be needed as part of follow-up work, the unit taking the lead for follow-up work ideally would have risk communication expertise. The unit with primary responsibility for a safe siting program can also serve as a resource for ECE program providers on general environmental exposures and risks.
13 The CCDBG has a technical assistance network that may also help coordinate a follow-up intervention.
See the following for more information: https://childcareta.acf.hhs.gov/External.
Types of follow-up activities that might be needed
- Site visit
- Review of environmental site assessment documents
- Review of inspection reports of nearby facilities
- State environmental agency property file review
- Local land record property review
- Coordination and communication with involved parties
- Review of operator submittals
- Review of license materials
- Identify data gaps
- Recommendations for environmental data collection
- Evaluate environmental data, assess exposures and health risks
- Risk communication
- Exposure reduction recommendations