ECE Program Certification
In this approach, the burden of finding potentially problematic ECE programs and unsuitable locations is placed more on the operator or owner than on a government entity. The operator provides information to a licensing or other government agency regarding the suitability of a location for an ECE program. This can be done in various ways. As part of the ECE program licensing process, an operator can complete a questionnaire about past property uses or paperwork to certify that the property is not affected by hazardous chemicals and is not located next to a facility where hazardous chemicals are used. A wide range of documentation can be used for such certifications and submittals. In New Jersey (whose regulatory program is discussed in detail in Chapter 5.3), a license applicant must hire a consultant to assess the building and property to document that it is suitable for child care use. In contrast, New York requires child care centers to self-certify that the center, property, and surrounding environment do not contain environmental hazards. Connecticut asks child care license applicants to complete a questionnaire about the past use of the building and property. Connecticut has no regulatory requirements mandating that the questionnaire be completed, and the level of due diligence needed to complete the questionnaire is left to the discretion of the child care center license applicant.
Each of these operator submittal and certification options has benefits and tradeoffs. Requiring that every program hire a consultant to do an environmental assessment before receiving a license could be an onerous burden on operators. However, the information obtained might be more reliable than self-certification, for which operators might put differing amounts of effort into the process. Using submittals or certifications from operators could be made voluntary or could be required using regulations. The level of resources needed to carry out this general approach depends on the level of review or audit of the submittals and certifications. This approach could be designed to apply only to new applicants or could be made retroactive to include all licensed ECE programs