Finding Potentially Problematic ECE Programs and Locations

An important component of a safe ECE siting program is having an established process for finding potential problems. To do so, every program needs to have a way of finding

  • ECE programs sited on land or in buildings where the presence of hazardous chemicals could result in harmful exposures.
  • ECE programs located next to facilities using hazardous chemicals that could affect the ECE program.
  • Locations that might not be safe for siting a new ECE program because of a past use or because of nearby facilities.

Appendix E describes types of former uses or nearby uses that could have left residual contamination. Chapter 4 also has examples of businesses that might pose exposure concerns if operating next to an ECE program.

A safe ECE siting program can be designed using a single approach or multiple approaches for finding problematic ECE programs and locations. Having more than one procedure for finding problem ECE programs and sites reduces the possibility that problems will be missed. Several general approaches can be used to find problem ECE programs and locations. Some approaches are resource intensive, and some require little to no additional resources.

The approach(es) you select will be driven by existing regulations, policies, and procedures and your partner groups. Your program will also be shaped by whether it will place burdens on government entities, on ECE program operators, or both. A program can be established using

  • Approaches that rely on regulations to enforce procedures (regulatory model).
  • Approaches that can be implemented without the need for regulations (non-regulatory model).
  • A combination of regulatory and non-regulatory approaches (hybrid model).

No one type of program is preferred. Every state is different and what works in one state might not work well in another state. Table 5.1 summarizes approaches that could be used to find problem ECE programs and locations. The table is not intended to be exhaustive. Other approaches also could be successful in your state. For each approach, Table 5.1 summarizes how the approach could be implemented and provides advantages and drawbacks for the approach. Each approach is described in more detail after the table.

Table 5.1. Approaches for finding potentially problematic ECE programs and locations for future ECE
Approach Implementation Advantages Drawbacks
Approaches for finding potentially problematic ECE programs and locations for future ECE
ECE program certification
  • ECE program operator documents that building, property and surrounding environment have no environmental hazards of concern
  • Potentially lower burden on government agencies
  • Higher burden on ECE program operators
  • Covers only new siting, unless retroactively implemented
  • Potentially unreliable without government auditing or compliance process
  • Audit or compliance process might have high resource needs for government
  • Government entity documents that building, property and surrounding environment have no environmental hazards of concern
  • Low burden on ECE program operators
  • High government resource needs
  • Covers only new siting, unless retroactively implemented
Geographic based
  • Compare addresses to find co-located ECE program and hazardous waste sites or potentially incompatible businesses/land uses
  • Low resource needs (provided hazardous waste sites lists exist)
  • Low resource needs if implemented only for new ECE programs and not existing ECE programs
  • Low burden on ECE program operators
  • Potentially miss a nearby problem businesses or land uses if not on the same street as the ECE program
  • Potentially resource intensive to include all current ECE programs
  • Comprehensive list of nearby hazardous waste sites may not exist
  • Complete list of incompatible businesses might not exist
  • GIS-based comparison to find ECE program within a specified geographic radius of a hazardous waste site/ potentially incompatible business/land use
  • Low resource needs (provided GIS-based data are available)
  • Covers existing facilities and new siting
  • More comprehensive than street address match
  • Allows for repeat analysis on regular basis with little resources
  • Low burden on ECE program operators
  • High resource needs if GIS-based data must be generated
  • Potentially high resource needs to keep GIS-based data current
Inspections
  • Use existing ECE program inspection process to look for ECE program siting issues and incompatible nearby uses
  • Low resource needs
  • Covers existing facilities and new siting
  • Low burden on ECE program operators
  • Takes advantage of inspections already happening
  • Limitations on control of inspection frequency and process
  • Requires regular inspector training
  • Create new inspection process
  • Inspection process can be designed specifically for siting and location issues
  • Covers existing facilities and new siting
  • Low burden on ECE program operators
  • Potentially high resource needs
  • Requires regular inspector training
Local zoning/ Permitting
  • Local planning and zoning boards identify issues during permitting process for ECE programs and potentially incompatible businesses
  • Low resource needs for local boards to implement
  • Low burden on ECE program operators
  • Potentially high resources needed to contact and train local permitting boards
  • Covers only new siting
Siting Criteria
  • Develop location criteria for siting new ECE programs
  • Low burden on ECE program operators
  • Potentially high resource needs to develop criteria and determine compliance
  • Covers only new siting
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Page last reviewed: October 30, 2018