EP 1110-1-24
15 Dec 00
3-1. Introduction. The establishment of an institutional control program is an important component of a
comprehensive risk management strategy for an OE contaminated property. This chapter will discuss
how institutional controls fit into the risk management approach and thereby, provide a level of
protection for the local community from OE hazards. This chapter will also discuss how local
stakeholder involvement is crucial to the establishment of a successful institutional control program.
3-2. Risk Management. Risk management is used by the government when OE risk remains at a site.
The risk management approach is designed to encourage meaningful stakeholder participation, foster
long-term community commitment to the institutional control program, and provide government support
for community needs. Risk Management consists of:
a. Risk Minimization Consistent with Community Needs. This component of risk management
focuses on minimizing the physical OE threat by removing as much of the ordnance as is practical
considering the needs of the community. This process occurs during the EE/CA and removal action
phases of the OE response process. Consideration should also be given to the possibility of engineering
controls, such as caps or other barrier-like structures to directly minimize the existing hazards.
Frequently, maintenance is required to ensure effectiveness of any risk minimization strategy that is
selected.
b. Residual Risk Management. Managing the residual risk by encouraging local initiatives is the
essence of institutional control planning. The local community is encouraged to become actively
involved in developing local initiatives to implement institutional controls. Local initiatives are institutional
controls for which the local authorities agree to support and provide long-term enforcement. The
federal government does not have the authority to enforce local initiatives; however, it can encourage the
local community and pledge its support to provide leadership, expertise, resources and a continuing
long-term review of the implemented institutional control program.
c. Recurring Review. Monitoring the effectiveness of all elements of the implemented project is
the basic nature of recurring review. At a minimum all projects must be reviewed every five years. The
frequency of review must be a design element that is site-specific. The recurring review elements are a
clear indication that the federal government provides a long-term commitment to managing residual risk
at sites contaminated by OE. Recurring review provides the opportunity to respond to problems that
develop over time, renew the communities understanding of the ordnance problem, refresh commitments
necessary to effectively protect the communities from ordnance hazards, re-evaluate the effectiveness of
the institutional control program, and to ensure productive use of the land resources.
3-1
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