NACCHO Public Health Principles and Guidance for BF

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PUBLIC HEALTH PRINCIPLES  AND GUIDANCE FOR BROWNFIELDS POLICIES AND PRACTICES

National Association of County and City Health Officials
September, 1998

In those communities with brownfields properties, where the health of the
public is an issue, NACCHO seeks to provide guidance to local health
officials and other agencies with the responsibility to protect public
health. The purpose of this guidance is to define an optimal response in
linking public health to economic redevelopment, for those local health
departments with the capacities to meet the guidance.  This guidance
stresses the importance of working closely with the community and values an
expanded role for public health in economic redevelopment processes.  While
not all health agencies may have the authority and resources they need to
play a comprehensive role in community revitalization activities, the
expanding number of brownfields properties and efforts to speed-up the
development process in many jurisdictions require an enhanced vigilance to
health consequences. Given the potential health consequences of
brownfields, all local health departments are encouraged to address as many
of these guidelines as possible. 

General Principles

* "When an activity raises threats of harm to human health or the
environment, precautionary measures should be taken, even if some cause and
effect relationships are not fully established scientifically. In this
context, the proponent of an activity, rather than the public, should bear
the burden of proof....The process of applying [this principle] must be
open, informed and democratic and must include potentially affected
parties. It must involve an examination of the full range of alternatives,
including no action."

	(Based on the Wingspread Statement on the Precautionary Principle,
developed 	January 23-25, 1998, Racine, Wisconsin)

* The health of the public is intimately linked to economic prosperity and
that economic development is vital to creating healthy and sustainable
communities

* Economic redevelopment potentially affects pubic health-positively and
negatively. 

* The health of the community and the environment must be protected by
ensuring that development poses no known significant health threats in the
clean-up process or future use

* The potential exposure to hazardous substances must be investigated

Role of Public Health Authorities in Site Activities and Decision-making

* seek to ratify the readiness of the property for redevelopment, drawing
on the local health agency expertise when present, or seeking state/federal
advice as appropriate

* ensure an audit of the site and assess health concerns, with active
participation from the community

* develop a permanent process for integrating the work of public health
from start to finish, into zoning, land use and other activities related to
redevelopment. 

* strongly encourage partnerships between EPA and local health agencies to
institutionalize a public health role in assessing the brownfields property

* determine the baseline health of the local community potentially affected
by the proposed site

Full Collaboration and Participation in Brownfields Process by Affected
Community Residents

* health and planning officials should ensure affected community residents
early, sustained, and effective  participation in all stages of brownfields
decision-making and that mechanisms are available to make this possible.

* developers and redevelopment authorities must assure adequate public
notice on the proposed development plan, including timeline and where to
submit comments

* members of the public must be assured an opportunity to submit written
comments on the proposed cleanup plan and/or request a public meeting

* health and planning officials should support strong community
collaboration practices, beyond those required by EPA; the National
Environmental Justice Advisory Council's (NEJAC) community collaboration
principles - written by community representatives - should be used as one
possible example


Community Knowledge, Training and Assistance

      Communities with local health agency leadership should:

* build the capacity of the community to participate by providing
technical assistance, training, advisory groups and other support to insure
effective participation

* provide equal protection to all residents with respect to enforcement of
all health and environmental laws and standards, and work to ensure the
adequacy of those laws

* expand and protect the public's right to know about contamination;
strengthen right-to-know, enforcement, and compliance activity in affected
communities

* provide answers to the community's questions about public health concerns

* foster the development of community leaders-capacity building for the
community

* provide the public with access to any studies or reports completed for
the redevelopment project

* post signs at site in question with information on the proposed plan

* interpret results of environmental impact assessments for communities
(i.e., present scientific data)

* work with communities to evaluate the health risks of redevelopment to
the community

* keep communities abreast of the results of environmental exposure
assessments, as well as public health activities needed based on those
assessments; receive more information on thresholds for public health effects

* engage in outreach efforts to existing networks and to groups that
ordinarily don't participate

Standards for Sustainable Communities

* ensure that the contamination is cleaned to appropriate health and
environmental standards and does not threaten public health 

* ensure that laws cannot be weakened due primarily to the cost of the
clean-up

* ensure that future use of the property does not include activity that
will lead to new health problems

* ensure that properties designated for residential use or schools, as
compared with industrial uses,  require the strictest standards

* ensure that clean-up standards and programs are not weakened

* ensure that residents are fully involved in planning and implementation
of relocation plans, whenever relocation is required, as well as a plan to
insure their well-being in any relocation

* ensure that brownfields reuse is compatible with local land use and
community perspectives

Monitoring, Surveillance, and Diagnosis
      Local health agencies should:

* maintain offsite testing requirements to ensure that contamination has
not migrated

* identify the health effects of redevelopment

* ensure that the affected community participates in audits and assessments
and ensure that public health issues are not overlooked

Funding for Public Health

EPA and other granting bodies to cities must provide funding for:

* public health agencies to participate in redevelopment activities

* communities to participate in redevelopment activities

* monitoring and enforcement of institutional controls as required by law

Adopted by NACCHO Board of Directors
September 23, 1998
Per Resolution 98-6

1 Brownfields is the term used to describe properties that have been
abandoned or underused which may be contaminated by toxic substances.

2 National Environmental Justice Advisory Council. (A Federal Advisory
Committee to the U.S. EPA. The Model Plan for Public Participation.
(November 1996).