EP 1110-1-24
15 Dec 00
5-3. All Parties With Interest In The Property Must Be Involved In The Process. The foundation of an
institutional control program is meaningful stakeholder involvement. Active involvement of the local
officials and community is paramount to the development of local initiatives that will be supported and
successfully implemented.
5-4. Notice In Various Forms Is Useful In Protecting Communities. The local institutions should make
the decision regarding the type and extent of public notification. While notice is always beneficial for
safety consideration, global community notice may alarm the pubic and have detrimental impacts. For
example, property values may be adversely affected. Therefore, it is important for local officials to
target only those groups impacted by OE decisions. For example, notice may be provided during the
issuance of building permits to inform those individuals most likely to be effected (i.e., those engaged in
excavation activities).
5-5. Every Institutional Control Program Must Have An Assurance Strategy. Because of safety issues
inherent on an OE site, an assurance strategy is an important consideration during institutional controls
planning. Forms of assurance include recognition of responsibilities at all levels of government and
private citizens, state oversight, frequent communication, recurring review, elements of the maintenance
requirements and a fastidious attitude toward keeping commitments at the Federal level. Only
community action in the largest sense can determine adequate assurance.
5-6. Multiple Levels Of Control And Layers Are Desirable For Any Institutional Control Program.
Designing layering or redundancy into an institutional control program will maximize the strengths of the
individual controls while minimizing their limitations. Multiple levels of institutional controls help target
different "at risk populations" and add to the stability of the system. For example, children that go to
school near ordnance contaminated lands should be approached differently than construction workers
who excavate for utilities. School programs and informing parents are essential in the former group and
it may be more effective to issue a construction permit subject to elements of a safety plan based on the
site-specific ordnance contamination to the construction company. Violation of the excavation safety
plan developed during the removal project may result in voiding the construction permit. Delays, fines
and penalties may provide sufficient incentive for compliance under those conditions. In general, we
should avoid redundant regulations. Oversight, quality assurance and recurring review may add safety
benefits.
5-7. Records Are Necessary To Evaluate The Continuing Effectiveness Of The Institutional Control
Program During Recurring Review. Records must be maintained so the recurring review may assess the
continuing commitment at all levels within the community. Any opportunity for enforcement must include
records of implementation of the controls agreed upon during the project planning.
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