by Mark Bishop, vice president of policy and communications
In 2007 Congress charged the U.S. EPA with the task of issuing voluntary guidelines for states on how to develop and implement environmental health programs for schools. Now, we are excited to report that the draft guidelines [pdf] are out and available for public comment.
We’re thrilled that the EPA is releasing this document and emphasizing the importance of school environmental health. Providing a resource that helps states promote environmental health and support schools in addressing health issues is incredibly important and can have significant benefits for the nation’s children for years to come. Thank you to the EPA for your efforts on this work.
To really make these guidelines effective and helpful, however, we believe the EPA needs to address several key issues with the current draft. Our specific concerns are described in more detail in our comments to the EPA (available here in .doc format), but my most significant concern with the current draft is the need to connect environmental health programs with state policy.
It’s clear through our experience and research that the states with effective environmental health programming are the same states that have policies supporting the development of such programs. If the EPA wants to support states in promoting health in schools, it needs to identify best practices and recommendations for successful policy development.
In fact, in January 2011, HSC convened a meeting of stakeholders to discuss and develop recommendations to EPA on this topic. These recommendations [pdf] addressed ways to develop effective state policies that could support healthy school environments. Key findings included:
- Policies that are developed with the engagement of school stakeholders are more likely to be successfully implemented than those that are developed without input from these important constituencies.
- Mandates, even those that are unenforced or include opt-out options, can lead to more effective policy implementation than can voluntary guidelines alone. Policies that include opt out clauses with public disclosure are politically acceptable to policymakers.
- Interagency cooperation is key to the successful design and implementation of environmental health policy. Promoting collaboration and creating opportunities for NGO engagement would support more comprehensive program development and improved communication with schools.
- Policies that build on existing school policies are more likely to be adopted and implemented. (Examples include school improvement plans, school report cards, inspection protocol, etc.)
- Understanding current trends in education policy is an important step in identifying additional policy handles.
- Recognition programs can be important tools for changing school policy and practice, and there are good examples of other federal agencies that have successfully implemented these types of programs.
We are glad the EPA has released this draft, and now urge the EPA to revise the draft guidelines to include a focus on connecting school programs to effective state policies.
We encourage you to share your feedback with the EPA as well! Click here to submit your comments. Comments must be submitted by this Friday, April 20 at 4 p.m. Eastern.