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Pulling Together Section One -- Roles


SECTION ONE: Roles and Responsibilities

As with many current environmental and public health issues, the challenges of effectively addressing public health and environmental protection at hazardous waste sites are greater than one agency or discipline can manage. A significant factor that hinders effective communication and collaboration is poorly defined roles and responsibilities.

"No one person or group always has the lead on any site. The lead shifts as a need arises. The shift is smooth because everyone works well together. They realize they all have the same goal. There are fewer overlaps in function—more of a collaborative effort."

— LCP site, Georgia, ATSDR Regional Representative

The web of regulations and agencies assigned to overseeing environmental and public health issues related to hazardous substances is as complex as the environmental health issues related to the hazardous substances themselves. Thus far, the "solution" to the complexity of these technical issues has been to bring together the knowledge, expertise, and resources of agencies working across multiple disciplines. However, with this solution comes the fragmentation of authority and a new challenge: effectively working together across multiple agency boundaries, mandates, authorities, jurisdictions, and cultural differences.

Though federal, state, tribal, and local environmental health agencies have a common goal of improved public health and environmental protection, the means to achieve this goal depend upon the resources, focus, and perspectives of the various agencies as well as the diverse professional training and perspectives of agency staff. These differences are intended to be complementary, but can lead to real or perceived conflict and confusion among involved agencies and the community.

The challenge is to seamlessly leverage these differences to provide the team of individuals working together with more information, expertise, and resources—bringing the best that each agency has to offer to bear on the problem to improve public health and environmental protection. Improvements in science and technology offer one part of the solution, but effective management of hazardous waste sites, and the communities affected by them, requires improvements in interagency collaboration.

Overlapping Roles and Shared Responsibilities

Given the web of responsibilities and authorities created by federal and state regulation, it is often difficult to delineate where one agency's responsibilities end and another agency's begin. For example, two major federal agencies—U.S. Environmental Protection Agency (EPA) and the Agency for Toxic Substances and Disease Registry (ATSDR)–are both mandated to protect public health. EPA is the lead agency for site remediation (clean-up) and ATSDR for public health investigation and intervention. Both agencies collect and use health data for different purposes. While EPA collects site samples and health data to determine long-term remediation, ATSDR conducts human health assessments and consultations to determine existing human health exposure and consequences.

"At the beginning of meetings and conference calls, participants introduced themselves, giving their name, the agency they work for, and their or their agency's roles, interest, and mission. This helped to keep the various participants informed of roles and responsibilities, and also to keep the meetings focused".

— Lowell Lufkin, Director of Environmental Health (OH)

Understanding the distinct and overlapping roles and responsibilities of each agency involved is a critical first step to building effective working relationships and garnering the benefits of interagency collaboration. To help you define the roles and responsibilities of various agencies, a brief description of many key agencies is provided below.

Click here for the Roles and Responsibilities Chart, which notes the core roles and responsibilities at hazardous waste sites, and illustrates where the roles and responsibilities overlap among the five key agencies—EPA, ATSDR, the state health agency, the state environmental agency, and local public health agencies (LPHAs).

For more detailed descriptions of each agency's role and responsibility, click on the agency title below.

  • U.S. Environmental Protection Agency (EPA)
  • Agency for Toxic Substances and Disease Registry (ATSDR)
  • State Health Agency
  • State Environmental Agency
  • Local Public Health Agencies (LPHA)
  • Community Organizations and Concerned Residents


"Getting Your Ducks in a Row" and the Perception of Secrecy

A tension often exists between the desire to begin interagency collaboration without public participation in order to "get your ducks a row" and the desire to gain the trust, acceptance, and cooperation of the community. Caution should be exercised when choosing to hold meetings that exclude community members. This action can create a perception of secrecy and decision-making behind closed doors. A closed door inevitably leads to the assumption that there is something to hide.

Why Collaborate

The overlap of roles and responsibilities by multiple agencies may seem confusing, duplicative, and even contradictory, especially to the newcomer and members of the affected community. In fact, much of the conflict at sites between agencies and community members may arise from the perceived lack of coordination or the presence of conflict among agencies. Therefore, effective interagency collaboration is an essential ingredient for effective agency-community interaction. This brief overview of the multiple roles and responsibilities at hazardous waste sites highlights the need for interagency communication and collaboration, not only to accomplish the complex task of site clean up, but also to address the range of community concerns related to the hazardous substances and agency actions at the site.

Interagency teams should discuss and define these roles at specific sites early in the collaborative process to ensure understanding of one another's responsibilities and commitments. Roles and responsibilities should be re-evaluated throughout the multiyear process of site remediation to improve collaboration and communication among all parties. The worksheets listed below should help you get started. The next section, A Framework for Agencies Working Together, will help you build from this understanding of differing roles to developing shared purpose and joint action.

Opportunities and Need for Collaboration

  • Sharing key information: community demographics, site history, sampling results, exposure data, and health histories.
  • Coordinating data gathering, analysis, and interpretation.
  • Utilizing expertise, connections, and resources of various agencies to expedite and improve decision-making.
  • Coordinating messages for and outreach to concerned residents.
  • Providing a systematic and coordinated approach for incorporating and responding to community concerns.
  • Creating a forum for resolving perceived and real interagency conflicts.

Worksheets

 

ATSDR

ATSDR is the public health agency mandated to address human health concerns at hazardous waste sites. ATSDR is funded through Superfund money and sits within the Centers for Disease Control and Prevention. Its mission is to "prevent further exposure and adverse human health effects, and diminished quality of life associated with exposure to hazardous substances from waste sites, unplanned releases, and other sources of pollution present in the environment." ATSDR employs a multidisciplinary staff including epidemiologists, physicians, toxicologists, engineers, public health educators, and support staff. ATSDR has an advisory role only; for example, ATSDR can advise medical treatment, but does not provide it. Also, ATSDR advises EPA on health measures, such as providing an alternative water supply for a community or restricting access to a site, but it cannot require EPA to follow these recommendations. For more information see the ATSDR Web site www.atsdr.cdc.gov/faq. Here, you will find information on how EPA and ATSDR differ, what ATSDR cannot do under legal mandate, and other useful information.

 

Primary roles and responsibilities:

Scientific/data

  • Investigates sites to determine if communities are or were exposed to hazardous substances;
  • Performs health studies and related actions—gains greater knowledge of the link between exposure to hazardous substances and adverse human health effects;
  • Maintains toxicological profiles that provide descriptions of health effects associated with 300 toxic substances; and
  • Maintains registries of people exposed to the most dangerous substances.

Community

  • Writes and disseminates health consultations to address community questions about exposure to specific hazardous materials from a specific site;
  • Conducts public health assessments to evaluate data and information to make health recommendations;
  • Conducts health education to inform the public, physicians, and healthcare providers about the health effects of hazardous substance exposure and how to reduce exposure; and
  • Conducts medical monitoring, screening of blood and urine of an "at-risk" population for specific diseases or conditions relating to hazardous waste, and may result in referral for treatment.

Interagency

  • Disseminates public health advisories—notices sent to EPA, state and local agencies, alerting them to a public health threat;
  • Provides indirect funding to LPHAs and other organizations;
  • Funds research conducted by universities, state agencies, and others studying the relationships between hazardous waste exposures and illness;
  • Has Memorandums of Understanding with Department of Energy, Department of Defense, Department of Agriculture, Indian Health Services, and minority foundations, as well as industry partners for conducting research;
  • Notifies other agencies involved of the actions taken; and
  • Develops/utilizes interagency communications system.

Health Consultations

Health consultations provide assessment and service on a specific health issue related to possible human exposure. ATSDR can provide assistance about the potential health impact of exposures, supply information about ways to reduce exposures, or determine appropriate public health measures. ATSDR can be petitioned to conduct a health consultation on non-NPL sites. Health consultations are generally completed within several months.

Public Health Assessments

ATSDR uses environmental, health outcome, toxicological, and community concerns data to undertake a thorough evaluation of the public health impact of a site. If a site poses a public health hazard, ATSDR identifies public health actions that may prevent or reduce exposure, or lessen the impact of that exposure. If a site may pose a public health hazard, ATSDR identifies what information needs to be obtained about the site or the substance in order to determine whether the site poses a public health hazard. Public health assessments are conducted at all NPL sites and may be petitioned at non-NPL sites. They may take up to two years to complete.

EPA

EPA was created in 1970 as the federal regulatory agency responsible for "protecting human health and safeguarding the natural environment—air, water, land—upon which life depends," as stated on the EPA Web site. EPA's broad powers include regulation and enforcement. It primarily uses scientists, engineers, lawyers, and analysts to carry out its responsibilities. EPA oversees the remediation (clean-up) process at all Superfund sites and most hazardous waste sites except for military sites. EPA may formally delegate authority to a state agency for oversight of clean-up for non-military sites. For more information, see the EPA Web site at www.epa.gov/superfund.

 

Primary roles and responsibilities

Authoritative

  • Assumes lead role at Superfund sites (see Superfund Remediation Process Flowchart);
  • Funds provided in Superfund program for sampling, removal, and remediation of hazardous waste sites;
  • Assesses, identifies, and negotiates with the potentially responsible party (PRPs);
  • Recovers the costs of remediation through litigation against the PRP, where possible;
  • Enforcement authority (permitting and fines);
  • Conducts emergency response and removal actions:
    • Provides timely response to hazardous waste situations.
    • Supplements local cleanup efforts; interacts with locals and media in a positive way.
    • Types of responses may include highway or train accidents, drug labs, chemical facilities, pipelines, pesticide fires and midnight dumping.
  • Routine Superfund responses include plume projections, toxicological information, disposal, treatment, links to other federal agencies, sampling (air, soil, water, drums/containers), containment, and cleanups;
  • Develops and enforces environmental standards in accordance with Federal and State requirements;
  • Makes final cleanup decisions (a.k.a. the Record of Decision (ROD). This is usually done with state concurrence;
  • Leads relocation of people at sites when necessary;
  • Conducts hazardous ranking process to place site on National Priorities List (NPL);
  • Performs laboratory certification;
  • Testifies on and writes bills pertaining to EPA's Superfund (regulations and funding); and
  • Develops and implements health and safety plans at sites.

Scientific/data

  • Conducts environmental sampling (remedial investigation);
  • Ranks sites using Hazardous Ranking System (HRS);
  • Interprets environmental data to establish cleanup levels and appropriate action;
  • Conducts ecological risk assessments (quantifies for the exposure pathway as well as background levels of a substance);
  • Performs feasibility studies/benefits analysis (e.g., compares the costs and technical abilities for various remediation procedures, and their impacts on public health);
  • Complies with state and federal laws and communities' acceptance; and
  • Based on scientific data, determines the technology to be used at site to treat and clean-up contaminants.

Community

  • Solicits public participation in Superfund Process;
  • Conducts public meetings and other events;
  • Liaison to public;
  • Initiates public comment periods;
  • Provides Technical Assistance Grant and Environmental Justice grants;
  • Conducts media press releases;
  • Gives written responses to public comment;
  • Conducts community interviews and prepares Community Relations Plan (CRP);
  • Establishes contact lists of local government officials, media, and community members;
  • Develops public fact sheets; and
  • Creates and maintains an information repository at each Superfund site to house documents developed during Superfund process.

Interagency

  • Coordinates parties involved at a site (citizens, local and state agencies, PRPs);
  • Uses Army Corps of Engineers as site consultant, and via other Memorandums of Understanding, where needed;
  • Coordinates with ATSDR for health-related advice;
  • Uses expertise of other agencies in peer review of documents;
  • Notifies other agencies involved of actions taken;
  • Develops and uses interagency communication system; and
  • Work with Coast Guard, Bureau of Land Management, and other federal agencies as needed.

Note: If the state, tribe, or, in rare cases, local agencies have the lead in remediation, they would adopt some of the responsibilities listed above.

Local Public Health Agencies (LPHAs)

"The role of the LPHA in the relationship changes as needs arise. LPHAs have conducted blood sampling, surveys, and lead/paint testing where they are able." – Director of Environmental Health, Marion County Health Department (OH)

LPHAs provide a variety of public health services to protect and ensure the health of the people living in their jurisdictions. Some of these services are inspections, maternal health programs, communicable disease control, health education and promotion programs, lead screening and abatement, family planning, and solid waste management. There are approximately 3,000 LPHAs nationwide. About two-thirds of them serve populations of 50,000 or smaller. The average-sized health department has a staff of 20, with staff sizes ranging from 1 to 21,700. On average, 46 percent of total funds come from state and federal sources; local sources provide 34 percent; and Medicaid, Medicare, and other sources account for the rest. For more information about LPHAs, visit the NACCHO Web site at www.naccho.org.

Local public health agencies (LPHAs) have no statutory authority at hazardous waste sites, and cannot enter intercooperative agreements with ATSDR or be delegated authority by EPA. However, they still play an essential role at hazardous waste sites. In fact, this lack of statutory authority and associated mandates, may enable LPHAs to ensure that site issues are not dealt with in isolation of other public health issues of concern in the community. Local public health officials work to address the individual and community impacts of a site or hazardous substance in the context of the multiple public health as well as socioeconomic factors in the community. As the local governmental presence, local health agencies serve as an immediate point of contact for communities and agencies. Therefore, LPHAs must be informed and capable of addressing community concerns and questions. Additionally, LHPAs can serve in a leadership capacity or assist others with communication and coordination of public health issues among all interested and affected parties. Local public health agencies often take a role in collaborating with community residents due to their close proximity to the site; access to health records; and close connection to community members, local physicians, and media.

"Local health officials have critical roles in identifying community health concerns and populations-at-risk, developing local responses to prevent or minimize exposure to hazardous substances, and ensuring that the responsibilities and commitments of other agencies and parties are carried out" (Don't Hazard A Guess, pg. 18).

Primary roles and responsibilities:

Local Public Health Authority

  • Serves as local public contact regarding health issues;
  • Identifies populations potentially at risk;
  • Issues public health advisories to warn of potential exposure and ways to minimize exposure;
  • Takes immediate action to stop continuing exposures (e.g., seal off site, provide drinking water);
  • Proposes local ordinances and resolutions; and
  • Ensures long-term monitoring and site maintenance.

Scientific/data

  • Reviews emergency response plan;
  • Conducts emergency response;
  • Gathers site-specific data, including demographic and background information about the site and community;
  • Ensures that proper areas of the site are identified and that localized conditions are addressed;
  • Reviews technical studies;
  • Collects environmental and biological samples;
  • Reviews EPA and ATSDR reports;
  • Records reportable diseases, outbreaks, and site information; and
  • Maintains information repository (post-remediation).

Community Involvement

  • Establishes ongoing communication and information sharing with concerned residents;
  • Conducts community educational needs assessment;
  • Forwards community concerns to appropriate agencies;
  • Serves as Public Information Officer; and
  • Serves as a community advocate by ensuring that other agencies follow through on their commitments and responsibilities.

Interagency

  • Contacts and organizes local agencies and elected officials;
  • Connects local agencies/officials with state and federal officials;
  • Provides information on site history, community demographics, and community concerns to other agencies;
  • Provides information on authorized and unauthorized land use, affected populations, and possible exposure routes;
  • Organizes agency meetings and conference calls;
  • Contacts local healthcare providers;
  • Serves as local media contact;
  • Attends EPA, ATSDR and Community Advisory Group (CAG) meetings; and
  • Keeps state and federal agencies informed of and responsive to community concerns.

State Department of Health

State health agencies often have cooperative agreements with ATSDR to perform health assessments and other health-related work. States with cooperative agreements must follow technical guidance developed by ATSDR and are held to the same federal standards. For more information about state health agencies, see the Association of State and Territorial Health Officials' (ASTHO's) Web site www.astho.org.

Primary roles and responsibilities of the State Department of Health:

Scientific

  • Provides epidemiological expertise;
  • Collects and analyzes health data; and
  • Maintains statewide human health database.

Community

  • Informs the community and health professionals about site-specific health factors;
  • Performs communication and coordination functions with the public (e.g., create flyers, letters, and posters);
  • Apprises ATSDR and EPA Customer Service Branch of community issues/concerns; and
  • Writes consultations and public health assessments.

Interagency

  • Can enter into a cooperative agreement with ATSDR to conduct health assessments and consultations (e.g., epidemiological studies, and health education studies);
  • Abides by federal regulations, taking action within limits of statutory and regulatory requirements;
  • Notifies other agencies involved of actions taken; and
  • Develops/uses interagency communications system.

State Environmental Agency

State environmental agencies may take responsibility for aspects of site remediation if authority has been officially delegated by EPA. Generally, state agencies have the primary role at a hazardous waste site during the pre-remedial (conducting Preliminary Assessment and Site Inspection) and post-remedial (long-term operation and maintenance) phases. The state must meet the minimal federal remediation requirements. Thus, they can enforce stricter standards, but cannot weaken the federal standards. For more information, see the Environmental Council of the States Web site at www.sso.org/ecos.

Primary roles and responsibilities of State Environmental Agency:

Authoritative/technical

  • Conducts emergency response;
  • Provides toxicological resources (e.g., consultants);
  • Sets standards and provides necessary permits;
  • Provides regulatory oversight (commenting on reports and recommendations);
  • Performs Preliminary Assessment and Site Inspection, to assist with hazardous ranking system;
  • Leads CERCLA programs, if authorized;
  • Provides, in most cases, funding for 10 percent of the cleanup at NPL sites;
  • Handles state Superfund program for non-NPL sites and NPL sites, if authorized; and
  • Abides by federal regulations, taking action within limits of statutory and regulatory requirements.

Scientific/data

  • Collects and analyzes environmental site data; and
  • Conducts environmental monitoring (i.e., long-term site maintenance and operation), after remediation process is complete.

Community/interagency

  • Performs communication, coordination, and community involvement functions (e.g., create flyers, letters, and posters, collects community information);
  • Reviews site work plans;
  • Provides remediation recommendations to the lead agency;
  • Notifies other agencies involved of actions taken;
  • Develops/uses interagency communications system; and
  • Contacts EPA Customer Service Branch and ATSDR of the Superfund program to make aware of community issues/concerns.

Community Organizations and Concerned Residents

Members of the community are the individuals affected by the site and therefore have a right to participate in the decision-making related to the site. These rights are recognized in federal and state statutes that require that the health assessment and remedial processes be a matter of public record and both EPA and ATSDR employ community involvement coordinators to address community concerns and provide information on site activities. Additionally, public comment and review are actively solicited at particular points in the process to ensure that the selected remedy is "acceptable" to the community. Although these formal requirements are important, broader community engagement is essential to fully capture the essential knowledge and information that only community members will have regarding site history and unrecorded uses, health concerns, and changes overtime.

Community collaboration includes the participation of community members in the designing and implementing of programs and policies. The degree of community collaboration is determined by the degree of partnership between the community and the LPHA, the frequency of regular communication, the equity of decision making, community access to LPHA information, and the skills and resources of the community members. Most critically, community collaboration is a dynamic, ongoing process of working together through which the community is engaged as a partner in public health action.

Effective community collaboration builds and strengthens the relationship between the LPHA and the community. It also enhances the agency's work. The community has critical skills and knowledge which, when incorporated into departmental program planning, development, implementation, and evaluation, will increase the likelihood of success in achieving the goals of programs and projects.

NACCHO continually provides LPHAs and their communities with assessment and planning tools. Assessment and planning are important functions of public health and can help communities to identify and address issues that will improve community health. To assist with these processes, NACCHO has developed other tools, including the following:

Protocol for Assessing Community Excellence in Environmental Health (PACE-EH)

A guidance tool designed to assist local health officials in the planning and implementation of a community-based environmental health assessment. The PACE EH methodology consists of 13 interrelated tasks, including project planning, assessment team recruitment, environmental health issue identification, indicator development, and action plan development, that together describe a flexible and collaborative assessment process.

Mobilizing for Action Through Planning and Partnerships (MAPP)

A Web-based, community-wide strategic planning tool for improving community health. Facilitated by public health leadership, this tool helps communities prioritize public health issues and identify resources for addressing them. Community ownership is the fundamental component of MAPP. Because the community's strengths, needs, and desires drive the process, MAPP provides the framework for creating a truly community-driven initiative.

Assessment to Action: A Tool for Improving the Health of Communities Affected by Hazardous Waste

A tool that facilitates collaboration between local public health agencies and communities in decision making throughout a community environmental health education needs assessment process. It provides steps and methods to assess community needs and concerns related to hazardous waste sites, and formulate action steps for addressing environmental health concerns.