EP 1110-1-24
15 Dec 00
6-4. Maintenance of an Institutional Control Program. This section provides a general discussion of
some generic operations and maintenance considerations for an institutional control program.
a. Maintaining the Effectiveness of Institutional Controls.
(1) Setting up evaluation criteria. The institutional control plan should include the development of
site specific criteria that will be used to ascertain whether the program is achieving the specified goals.
The criteria may include:
(a) Is the current land use appropriate or in compliance with the institutional control program?
(b) Are engineering controls performing as intended? For example, if fences are used as a barrier
to access, an evaluation may include review of trespassing occurrences and how they were handled, as
well as evaluation of the physical condition of the fence (e.g., are there any holes or gaps in the fencing).
If signs are used, an evaluation should include a review of whether the signs are generally heeded or
ignored, and whether the signs are easy to understand and visible.
(c) Is the public notice and education component of the institutional control program reaching
those at risk? This may be evaluated by reviewing attendance at public education meetings, gauging
public response to the controls, conducting random interviews throughout the community, etc.
(2) Developing procedures to coordinate the activities of the responsible parties. The institutional
control plan should address the responsibilities of the various parties involved for maintaining the
effectiveness of the institutional control plan. These procedures should include the frequency and types
of inspections; reporting requirements for any inspections made; reporting of any noted violations; and,
enforcement responsibilities.
b. Resources. The resources available for maintenance activities should be considered when
comparing different institutional controls that may be implemented at a site. Resources may be available
at the Federal, state, and/or local level. The available resources will vary from site to site. For example,
one locality may have a strong, well developed and administered local planning agency or building
permitting agency, making zoning and permitting restrictions more attractive and feasible as institutional
controls in that location. On the other hand, some areas may have very little in the way of local
government resources that can be drawn upon to help maintain an institutional control program. The
level of interest and cooperation from any potential agencies must be considered before obligating these
agencies to assist in the maintenance of institutional controls.
c. Enforcement Authorities. The enforcement authority will depend on the type(s) of institutional
control implemented at a site as well as the legal authority held by the prospective enforcement agency.
6-7
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