SAFER Program Approaches

Building on the success of the pilot program, the SAFER Program was designed using three approaches to finding ECE programs with potential environmental concerns. Figure 1 is a logic model showing how the SAFER Program finds and addresses potential problem ECE programs. Connecticut recognized that because no single approach is perfect, using a combination of tools to identify potential problems would make it less likely that problems would be missed. The left (yellow) column of the logic model shows approaches used to identify potential problem ECE program. The SAFER partners listed in the green column use the approaches to identify ECE programs that could pose exposure concerns. The GIS-based approach is not yet being used. All ECE programs identified using SAFER approaches are referred to EOHA for follow up. The three approaches used by Connecticut and the follow-up process if a child care is referred are discussed below.

Figure 1. Logic model for Connecticut’s SAFER Program

Address Crosscheck

Licensing staff compare the street name of an ECE program (at the time the center applies for a license) with addresses in the Connecticut Department of Energy and Environmental Protection’s (CTDEEP) hazardous waste sites list. Currently, this crosscheck procedure is performed manually. The long-term goal is to use GIS technology to search for new and existing ECE programs near hazardous waste sites. The CTDEEP hazardous waste sites list includes locations that trigger Connecticut’s regulatory requirements for waste site cleanup. The SAFER Program was designed with an understanding that some properties with hazardous chemicals are missing from the list. No single approach is perfect. Using multiple approaches for finding potential problem ECE programs decreases the likelihood that problems will be missed.

Property History Questionnaire

EOHA developed a questionnaire for ECE program license applicants. The questionnaire is part of Connecticut’s license application package and is included in Chapter 6 of this manual. The questionnaire asks license applicants to provide information about the past use of the ECE property and buildings. Questions include whether the property was used as a dry cleaner, farm, gas station, landfill, manufacturing facility, nail or hair salon, funeral home, or shooting range. The questionnaire also asks whether the license applicant is aware of any environmental site assessment documents prepared for the property. The questionnaire allows an applicant to indicate that they do not know the property history. However, applicants are encouraged to answer all questions to the best of their ability. When licensing staff review the application, they refer the child care to EOHA for follow up if the questionnaire has any former use issues identified or if site assessment documents exist for the property.

Inspector Referral Form

ECE programs in Connecticut are inspected by the state before licensure and regularly thereafter. Local health departments also regularly inspect child care facilities. The referral form (see Chapter 6) is a tool to help inspectors identify and document property or building attributes that could signal the presence of hazardous contamination. In this way, the form brings programs to the attention of the SAFER Program. The referral form also helps inspectors identify types of businesses (such as a dry cleaner or nail salon) operating next to a child care facility that could adversely affect the environmental quality of the care. During regularly scheduled inspections, the inspector only needs to spend a little extra time to look for building and property attributes included in the referral form. EOHA provides yearly training for child care inspectors on what to look for and how to refer child care facilities to EOHA. The referral form also was provided to local health department staff to use when they conduct inspections. Inspectors view the form as a useful tool to help them ensure that ECE programs are operating in buildings and on land that is as safe as possible. During an inspection, if any of the items listed in the form are observed, the inspector refers the program to EOHA for follow up. In addition to completing the referral form, inspectors are encouraged to take photos or make a simple sketch of anything they observe that raises their concern. They are also encouraged to contact EOHA staff if they have any questions about something they saw while on a child care inspection

Follow-up Process

An ECE program location identified through any of the approaches is referred to EOHA. This referral is done by email or telephone call, or both. EOHA gathers and reviews the environmental and other relevant information available for the property. EOHA coordination with the local health department, CTDEEP, EPA, the ECE program operator, the property owner, and the licensing staff is a large part of follow-up activities. After gathering available records and reports, EOHA staff may conduct a site visit of a child care to resolve any remaining issues or questions. For example, they might make a site visit if a business such as a nail salon is located next to an ECE program and within the same building. During the site visit, odor issues are noted and ventilation systems are observed. Another situation in which a site visit is likely to be conducted is when a program is located on a property that had soil or groundwater testing or remediation because of the presence of hazardous chemicals. At the site visit, the location of the playground is observed to decide whether additional testing in the playground is needed. Site visits are always coordinated with the inspector and the local health department. If additional action is needed, such as collecting environmental data, EOHA

• Coordinates with all appropriate parties and evaluates the data.
• Provides recommendations to reduce exposure from environmental contaminants.
• Helps families and child care workers understand potential exposures and the risks those exposures might pose.

The final outcome of each ECE program follow-up is documented in written communication to licensing staff and summarized in a database maintained within EOHA.

Over the years since the SAFER Program was launched, the EOHA follow-up process has resulted in recommendations for soil, air, dust, and drinking water testing and soil remediation at a number of ECE programs. EOHA has not had an instance where a child care facility refused to comply with SAFER recommendations. This is because EOHA coordinates closely with the licensing staff, the local health department, and CTDEEP on all SAFER recommendations. Consequently, all recommendations are agreed to before they are communicated to the ECE program property owner. Further, SAFER recommendations are communicated by the local health department or licensing staff, both of whom have regulatory authority, and not by EOHA, which has no regulatory authority. These are likely the key reasons why ECE programs are complying with SAFER Program recommendations, even though they are not under specific regulatory obligation to do so.