Chapter 5: How to Build a Program - Models for a Safe ECE Siting Program

Generic Conceptual Model

This chapter presents models and approaches for state, county, or local entities to consider when creating a program for safe ECE program siting. The models and approaches do not have to be adopted in full, but may be implemented in parts or stages. Each state or locality will have different circumstances that dictate which approaches and sequencing will work best.

Key components to consider when building a program for ECE siting include your partners, state licensing and inspection programs, land use and permitting requirements, and hazardous waste sites (see Box). Each component is discussed in the sections below. Program components do not need to be implemented at the same time or in the sequence discussed here.

Identifying Partners and Building Partnerships

Building an effective, safe ECE siting program is most successful when it is a collaborative process. The effort can start with partnership building among governmental programs in your state responsible for the following:

1. ECE program regulation (licensing and inspection).
2. Hazardous waste site identification, assessment, and cleanup.
3. Local land use and permitting decisions.

For a program to work efficiently and effectively, a single unit should assume overall responsibility for initiating and then coordinating the program. An ideal group for this role is a programmatic unit within a state health department with expertise in assessing exposures and health risks from hazardous substances in the environment. In states with ATSDR APPLETREE cooperative agreement funding¹¹, the unit performing APPLETREE work is ideally suited to coordinate a safe ECE siting program.

The first steps in partnership building are to identify the primary partner groups with whom you will need to collaborate and familiarize yourself with their roles and responsibilities (see Chapter 4, Table 4.3, for descriptions of potential partners or stakeholders). A good understanding of how licensing, inspection, and regulation of ECE programs occur in your state is important. This includes learning about how local planning and zoning agencies make land use and permitting decisions for ECE programs. Also familiarize yourself with your state’s regulatory programs for identifying, assessing, and remediating hazardous waste sites. To help you gather information, Chapter 6 includes a list of questions to consider asking your partners and partner groups. Understanding the roles and responsibilities of your partner groups will inform you about what program model might be best suited for your state. It will alert you to potential obstacles, resource constraints, and data gaps that might influence how you set up your safe ECE siting program. It also might help you decide whether a regulatory, non-regulatory, or hybrid program will work best in your state (see chapter 4 for a definition of these programs).

By communicating up front with your partner groups, you will learn about ECE program siting policies and protocols already in place in your state. The Environmental Law Institute review of state environmental policies for ECE programs provides a good compilation of ECE program location criteria that might already be in place in your state. It is useful for you to learn if your state already has ECE program siting criteria, how the criteria are implemented, and how compliance with siting policies or regulations is enforced. Understanding your state’s policies and regulations can help you identify strengths and weaknesses in existing procedures and where changes can be made to improve the effectiveness of existing programs.

¹¹The Agency for Toxic Substances and Disease Registry (ATSDR) Partnership to Promote Localized Efforts to Reduce Environmental Exposures (APPLETREE) cooperative agreement program supports state efforts to evaluate and respond to environmental public health issues involving human exposure to hazardous substances in the environment.