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Protecting 6,000,000 children in daycare from toxic hazards of cleanup sites

Mix 400,000 daycares with 550,000 cleanup sites nationwide, and the vision takes shape for a national daycare screening service to vigilantly protect 6,000,000 children  from inadvertent exposure to toxics.  This effort started after 2006 on the failings at Kiddie Kollege, where children attending daycare were exposed to high mercury levels. The childcare facility occupied the same building that ten years earlier had been a thermometer assembly factory.  The site’s environmental problems were known to environmental agencies but were lost in the site investigation backlog. Progress at the state-level, coupled with work by the  United States Environmental Protection Agency (USEPA), provides the basis of a national daycare screening service. This post to The Monitor describes the progress made in New Jersey, as well as different approaches taken in California and New York toward an efficient state-wide daycare screening service. Terradex has been a technology provider introducing DaycareWatch as a state screening tool.

This post draws upon a presentation by Terradex to the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) at their State Superfund Managers Symposium held on August 10 in Indianapolis, Indiana. Terradex plans a web conference on September 28, 2010 (tentative) to overview various state and federal approaches to daycare safety – we invite your participation and interest using the signup link.

New Jersey Learns The Lessons from Kiddie Kollege

In 2006, New Jersey Department of Environmental Protection (NJDEP) learned that children and their teachers at Kiddie Kollege had been occupying the Former Accutherm, Inc. site. The site had become lost in a cleanup backlog, and daycare activity had begun unbeknownst to NJDEP. Thus began the examination of multiple institutional failures that led NJDEP and the New Jersey legislature to establish a comprehensive multi-agency program to prevent the occurrence of another Kiddie Kollege in New Jersey.   In her presentation to ASTSWMO, Ms. Diane Pupa, on behalf of NJDEP, shared lessons learned and described a multi-layered program to find other “Kiddie Kolleges” and prevent repeat occurrences in New Jersey.

Ms. Pupa identified multiple opportunities to have detected the unsafe conditions:  the problem was hampered by lack of communication between agencies, lack of due diligence by the buyer,  map location errors, misunderstanding of regulatory documents, and more. At hundreds of thousands of daycares in the United States, the unfortunate pattern of events appears replicable without a systematic national approach. A 2006 article from L. Schnapf Environmental Journal, cataloging the incidents and roles of parties around the Kiddie Kollege, still reminds one of how repeatable the Kiddie Kollege scenario might be.

The New Jersey program appears an effective model for protecting daycare from toxics at cleanup sites, and was propelled by  legislative and a staffing commitment. The NJDEP Child Care – Education Facility Unit has a staff of 15 dedicated to daycare review, and NJDEP now approves all daycare centers before the Department of Children and Families Office of Licensing issues a license to operate.

Quantifying Daycare and Cleanup Sites in the United States

Nationwide there are approximately 100,000 daycare centers and 300,000 child care homes (a 2004 estimate by the House Ways and Means “Green Book”).  Combined, these facilities serve approximately 6,000,000 children aged five years or younger.  The average daycare facility turns over once every five years – across the country perhaps 80,000 new daycares are started each year. The turn-over necessitates that a program must review not only the current inventory of daycare, but also track new daycares coming into operation.

There are at least 550,000 cleanup sites. While the sites are slated for cleanup, approximately 40% of the 550,000 lay somewhere in the cleanup pipeline: awaiting investigation, under investigation, or being remediated. Adding further complexity to the cleanup process, the sites are tracked within a is the multitude of disconnected government databases.  Terradex’s has built its catalog of 550,000 cleanup sites from 110 databases from 3 federal agencies and 45 states. With an additional five states to complete, the number of cleanup sites will grow.  (These estimates are based on work Terradex has performed for USEPA building the Cleanup Site Map Service (CSMS) – a system still under review by USEPA. The CSMS is a web-based map service that displays basic location, site status, and use limitations on a common map platform. )

Efforts to Prevent Daycares Operating Near a Cleanup Site

The likelihood of co-located daycare at a remediation site is rare, but too high for affected families and involved jurisdictional agencies.  NJDEP’s efforts have resulted in 3,777 preliminary assessment of daycares, showing that 33 daycares (about 1%) have potential contamination exposure.  The common contaminants occurring at daycares were poly aromatic hydrocarbons (PAHs)leadasbestos, pesticides and PCBs.  Vapor intrusion of contaminants is another significant exposure pathway.  Indoor air screening 2,851 centers lead to 507 centers being sampled for two classes of common contaminants: those derived from chemical products used at the daycare and those derived from nearby toxic sites. The airborne toxics derived from within the daycare include 1,4 DCBmethylene chloride and formaldehyde. The contaminants that volatilized from toxic sites included benzenetolueneperchloroethylene and trichloroethylene – contaminants typical of gas stations and dry cleaners.  Ultimately, 6 centers (0.2%) were closed due to indoor air quality issues, and 275 centers (10%) remain on continued air monitoring.

A limited proximity analysis of New York’s 18,000 daycare facilities to 2,200 New York remediation sites revealed less than 0.5% were located at or within 100 feet of a remediation site, and 2.7% fell within 100 to 500 feet of a remediation site.  Proximity is a key risk factor, but other considerations such as the extent of cleanup, the type of contamination, and migration pathways further refine whether a particular daycare is at risk.

State childcare licensing agencies provide numerous reviews for the safety of children in daycare.  Why wouldn’t state licensing agencies provide the review for proximity to cleanup sites? As environmental scientists, we know that the chemistry of contaminated sites is complex and the environmental regulatory filings are also complex.  It is reasonable to anticipate that the multiple state and local agencies that license and approve daycare facilities would not have the capacity to make judgments of environmental safety – that judgment is made in New Jersey by the Department of Environmental Protection, not the Children and Families Office of Licensing. Nationally, the judgment of safety would likely be left to an environmental professional or the applicable environmental oversight agency.

New York and California Daycare Screening Approaches

The states of New York and California are utilizing a method to continuously obtain daycare licenses from the issuing agencies, and then compare daycare locations to cleanup site locations. If a targeted at-risk daycare is found, an alert is issued to the environmental agency to facilitate resolving any of the at-risk situations at the flagged daycare.

This continuous locational screening approach captures at least two essential elements – discovering potentially at-risk daycare, and then efficiently managing the alert across the environmental agency and ultimately to the affected daycare.  This approach presumes that the state environmental agency would provide notice to its state daycare licensing division or licensed daycare operator.  The states of New York and California retain Terradex to screen daycare locations, and these efforts provide the basis of the summary of the progress of the DaycareWatch service.

New York State Experience. Within New York state, daycare is regulated by two agencies: the New York Office of Child and Family Services (OCFS) and the New York City Bureau of Child Care.  Cleanup sites are overseen by New York Department of Environmental Conservation, and are broadly cataloged into three environmental databases: petroleum, remediation, and bulk storage. Terradex’s current DaycareWatch scope monitors a subset of this data: the remediation database and the OCFS childcare database. The effort is likely to expand soon to include the petroleum sites and the Bureau of Child Care licenses.

The DaycareWatch service has been active since April 2010. The procedures followed under DaycareWatch include: 1) monthly review of new daycare licenses, 2) monthly updates of the remediation site lists, 3) preparation of monthly lists of new daycares within 250 feet of a remediation site, and 4) maintenance of web mapping service (at right) which permits the searching by address or remediation site for tabulations of nearby daycares.  When at-risk daycares are discovered, the NYSDEC program manager alerts the assigned NYSDEC project manager of the specific circumstance.

California State Experience: Within California, daycare (and senior centers) are licensed by the California Community Care Licensing Division (CCCLD).  Cleanup sites at the state level are overseen by California Department of Toxic Substances Control (DTSC) (via Envirostor), the State Water Resources Control Board (via Geotracker), and the Integrated Waste Management Board (via Solid Waste Information System).  Additional catalogs of environmental site restrictions are maintained at the local level (e.g. institutional controls are cataloged by County of San Diego).

Since 2007 Terradex has provided DTSC with LandWatch service  to monitor numerous sensitive land activity data across its portfolio of 377 sites that carry land use restrictions.  Among the data sources monitored are the licenses issued weekly by the CCCLD.  LandWatch offers geospatial screening similar to DaycareWatch, but also introduces an alert management process.  This process transmits summary information showing the environmental site and the sensitive use to the DTSC project manager.  The LandWatch alert system then facilitates logging the interchange between Terradex and the DTSC staff as the alert is judged and ultimately closed.  Closing the alert can reflect either that the stakeholder was alerted to the situation, or that the project manager judged after review that there was no risk. A key attribute of LandWatch is that the closure of the alert is tracked in order to make sure that the situation is not overlooked within all the other duties of the project manager.

Toward a National System for Daycare Safety

What is the prospect to construct a national-scale daycare screening and alert process? This section presents progress toward getting the cleanup sites and daycare data to feed a national screening system, and the organizational processes to serve the solution across fifty states. Terradex has worked several years with USEPA’s Office of Solid Waste and Emergency Response (OSWER) and USEPA’s Office of Site Remediation Enforcement to build a national database to help local government and the public make informed land use decisions.  The CSMS project with USEPA provides an optimal platform within which to introduce a national DaycareWatch service: the service has already catalogued datasets from 45 states and 3 federal agencies.  Furthermore, the project has been constructed in collaboration with ASTSWMO, an organization embodying state and federal cooperation environmental waste management.

The CSMS maintains a structure whereby states can have their environmental datasets automatically updated into the CSMS national map service.  The CSMS collects the data either by automatic spidering of databases or through uploads accomplished by the state agency. The CSMS severs environmental site information as a simple web service that provides point and polygon locations of environmental sites — this data would be bye basis from which to compare the locations of daycare facilities.  The CSMS platform could be augmented to also collect  the records for new daycares facilities. As with the environmental data, daycare records  can be obtained by either crawling the state agency websites or through the upload of the equivalent datasets through the CSMS infrastructure.  Additional daycare records can be obtained from commercial datasources that aggregate new daycare centers for listing services.   The commercial datasource anticipates providing 1,200 new daycare records per month and can provide an initial catalog of existing daycare providers.  The commercial datasources would be supplemented overtime with state and local licensing sources.  Herein lies the basis for a database of environmental sites and daycare from which to feed the DaycareWatch screening.

The CSMS combined with Terradex’s LandWatch provide a basis to generate reports and alerts of at-risk daycares.  Each state and federal agency is controls which users would receive reports, and conducts the upload of cleanup and daycare datasets.   As a web service, the DaycareWatch would be able to  track these notices, and help the state maintain that the alerts of nearby daycare are received and resolved.  The labor burden on a state should be modest as projections anticipate 500 alerts per year nationwide. Averaged across 50 states,  any state agency would likely receive a manageable 10 alerts per year.

A Look Forward

This post has developed the prospect of a national screening system for daycare sites.  Terradex, as a technology service provider knowledgable in institutional controls, is pleased to be contributing to the effort.  The screening approach embodied in DaycareWatch will require further development and interest on behalf of USEPA, ASTSWMO, and state environmental agencies.  Over time, state childcare licensing departments could be integrated into the service, and their understanding of how to manage the unlikely but important risks posed by toxic sites will grow. The CSMS platform has already worked to provide uniform and intuitive statements of cleanup status so that non-environmental professionals can be better informed, and thus take the proper precautions.

Daycare screening can serve another relevant purpose for environmental agencies:  helping assure that low-priority cleanup sites do not get hidden in an investigation or cleanup backlog when new sensitive uses like daycare emerge nearby. DaycareWatch could help re-prioritize cleanup lists based on real time development of daycare use (or other sensitive uses). In hindsight, such an approach might have guided NJDEP early on to re-prioritize their known contaminated sites list and push the Accutherm site to clean-up long-before Kiddie Kollege’s occupancy.

Any national screening  will need to confront challenges in data quality, lack of locations of cleanup sites and daycares, and find budget to support the effort. Furthermore, documenting that a daycare is protected is never as news worthy as the daycare that tragically becomes impacted.  Still the progress made in New Jersey, as well as California, New York and likely other states is to be celebrated.

Terradex looks forward to furthering and perfecting the DaycareWatch platform’s development. We hope further development will occur during the discussion in the September webinar. Please consider participating by registering.

Feedback to this post. A state official supportive of this effort suggested that we incorporate monitoring any facility where children are present – school sites, churches, youth centers and parks.  The naming should be expanded to encompass this broader service. A article in the The County Gloucester Times looks back at Kiddie Kollege four years later.

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