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Area-Wide Soil Contamination Task Force Final Report
June 30, 2003


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8. Recommendations for Specific Land-Use Scenarios

This section contains Task Force recommendations for actions that should be taken in specific land-use scenarios in places where area-wide soil contamination is likely. Additional actions are recommended in situations where the Task Force was particularly concerned about a specific population, such as children, or to take advantage of opportunities to leverage ongoing activities to implement more aggressive measures to reduce the potential for exposure to arsenic and lead in soil. The Task Force emphasizes that these activities are meant to build upon and complement-not replace-broad-based education and awareness-building.

8a. Child-Use Areas

What are Current Approaches for Child-Use Areas?

There are a number of ongoing projects to address area-wide soil contamination at child-use areas across Washington State, including projects associated with the cleanups of the Tacoma and Everett smelter sites and other affected properties, and projects at a number of schools and parks built on properties affected by past use of lead arsenate pesticides, including schools in Chelan and Okanogan counties and parks in Yakima. Current approaches often involve outreach to school officials to provide information and support for implementation of individual protection measures and maintenance of good soil cover, and systematic soil sampling at child-use areas, followed by selection and implementation of additional protection measures. The Agencies typically provide both technical and financial assistance for responses at child-use areas.

    

The Task Force is particularly concerned about exposure of young children to arsenic and lead in soil. Children tend to have greater exposure than adults to soil and dust because they often play on the ground and tend to put things-such as hands, pacifiers, and toys-that may have soil on them into their mouths. Children are at greater risk than adults from lead because, when exposed, they absorb more lead than adults, and their rapidly developing nervous systems are more sensitive to lead damage. Parents already may be aware of the need to protect children from lead poisoning as a result of long-standing programs established to prevent children's exposure to residues from lead-based paint. Actions in other states or countries to address widespread soil contamination, as well as ongoing efforts to address area-wide soil contamination in Washington State, tend to prioritize activities that protect children. The Task Force felt a special responsibility to recommend actions that address the potential for children to be exposed to arsenic and lead in soil and spent much of its time considering recommendations for child-use areas.

Types of Child-Use Areas and Prioritizing Activities at Publicly Maintained Areas
The Task Force considered a number of types of child-use areas: primary schools and their associated playgrounds and playfields; public playgrounds and playfields (such as those at parks); childcare facilities, including preschools and family home childcare facilities; and camps. The Task Force also distinguished between publicly maintained child-use areas, such as public schools and parks, and privately maintained areas, such as private schools, playgrounds, and childcare facilities.

In general, the Task Force believes that the same responses are appropriate at both public and private child-use areas and that over time potential exposure should be addressed at all child-use areas where area-wide soil contamination is likely. However, the Task Force also recognizes that it may not be practical to address all child-use areas immediately. Accordingly, the Task Force recommends that publicly maintained child-use areas should be prioritized and responses in these areas should set the standard for protection of children.

Recommendations
In addition to the education and awareness-building discussed earlier in this report, the Task Force recommends five responses for child-use areas where area-wide soil contamination is likely:

  • Individual protection measures and maintenance of good soil cover in areas where children play to reduce the potential for children to be exposed to contaminated soil.
  • Qualitative evaluations to increase understanding of where exposure could occur and to focus implementation of soil testing and additional protection measures.
  • Soil testing where qualitative evaluations indicate the potential for exposure to contaminated soil and implementation of additional protection measures if contamination is found.
  • Mandatory soil testing at new public child-use area construction sites and implementation of additional protection measures if contamination is found.
  • Special approaches, including targeted outreach and a voluntary certification program, for family home childcare facilities and childcare centers.

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Individual Protection Measures and Good Soil Cover

What Does It Mean for the Agencies to
Provide Support, Encouragement, and Assistance to Local Jurisdictions?

Local governments, such as health districts and school districts, often will play a key part in implementing Task Force recommendations. In many places in this report the Task Force advises the Agencies to provide "support, encouragement, and assistance" to local jurisdictions. Besides financial support-the need for which the Task Force expects will be widespread-the Task Force has not attempted to precisely define what "support, encouragement, and assistance" might involve. The Task Force emphasizes that the first step is for the Agencies to reach out to local jurisdictions in areas where area-wide soil contamination is likely to provide information on the issue and the Task Force recommendations, and to ask what types of assistance and support the local jurisdiction might need.

    

The first step to minimize the potential for children to be exposed to elevated levels of arsenic and lead in soil should be implementation of individual protection measures and maintenance of good soil cover in areas where children play. The Task Force emphasizes that it is not necessary to confirm that elevated levels of arsenic and lead are present in soil before implementing individual protection measures and providing for good soil cover. Rather, where area-wide soil contamination is likely, the Task Force strongly recommends that these measures be instituted immediately unless 1) qualitative property evaluations indicate that elevated soil levels of arsenic and lead are not likely or it is unlikely that children could be exposed to soil, or 2) quantitative soil testing shows that elevated levels of arsenic and lead in soil are not present.

The Task Force believes this is a reasonable approach primarily for two reasons. First, as discussed above, children are the population most vulnerable to adverse health effects from soil contamination, particularly from exposure to lead. Second, implementing individual protection measures and providing for good soil cover in play areas are, to a great extent, consistent with the types of personal hygiene practices and routine maintenance activities that should already be in place at schools, parks, childcare facilities, and other child-use areas.

The Task Force recommends that the Agencies work with local health jurisdictions to support, encourage, and assist with implementation of individual protection measures. This may include providing training, briefings, or other assistance or materials to local health jurisdictions. In addition, the Agencies should work with local jurisdictions and other organizations, such as the Washington Association of Maintenance and Operations Administrators, to support, encourage, and assist with activities that maintain good soil cover and to integrate these activities into ongoing landscaping and maintenance practices. This may include providing training or information on the relative effectiveness of various soil covers and methods to maintain effective soil cover. Grass, for example, may not be an effective cover for contaminated soil on an athletic field or other child-use area if it is not properly maintained.

Qualitative Evaluations of Potential Exposure
The Task Force strongly encourages property owners/managers of other child-use areas to carry out qualitative evaluations of the potential for exposure to arsenic and lead in soil in places routinely used by children. Qualitative evaluations should use easily identifiable factors (such as elevation at properties potentially affected by historical use of lead arsenate pesticides) to determine if elevated levels of arsenic and lead in soil are likely, and easily observable features (such as the presence or absence of bare dirt) to identify situations when there is the greatest potential for exposure. Qualitative evaluations should help identify situations where there is or could be direct, frequent contact with contaminated soil over a period of months. The Task Force recommends that the following checklist be used to carry out qualitative evaluations.

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Table 2: Qualitative Evaluation Checklist for Understanding Potential Exposures to Arsenic and Lead in Soil

Please visit and walk around the site, preferably during daylight hours, before answering these questions.
Q1. Is the property near a historical smelter location in Pierce, King, Snohomish, or Stevens counties? If YES or UNSURE, go to Q4.

If NO, go to Q2.

Q2. Were lead arsenate pesticides used on the property historically (e.g., on apple or pear trees)? If YES or LIKELY, go to Q4.

If NO, go to Q3.

Q3. Are portions of the property within 25 feet of a road built before 1995? If YES or UNSURE, go to Q4.

If NO, elevated levels of arsenic and lead are not likely to be present in soil.

Q4. Do children routinely play in this area? If YES or UNSURE, go to Q7.

If NO, go to Q5.
Q5: Do people spend a lot of time in this area (e.g., while gardening)? If YES or UNSURE, go to Q7.

If NO, go to Q6.

Q6: Are there frequently used, unpaved paths or trails through this area? If YES or UNSURE, go to Q7.

If NO, potential exposure to elevated levels of lead and arsenic in soil is less likely.

Q7: Is there any exposed dirt in play and high-use/traffic areas (e.g., swing sets, gardens, sports fields, lawns, and paths)?
 
Note: Asphalt, wood chips, grass cover, or other natural/synthetic barriers may help limit potential exposure to contaminated soil. The Consumer Product Safety Commission recommends that surfaces around playground equipment have at least 5-12 inches of wood chips, mulch, sand, or pea gravel, or are covered with mats made of safety-tested rubber or rubber-like materials.

If YES or UNSURE, there may be a higher potential for exposure to contaminated soils. Use individual protection measures to minimize potential exposure and determine whether to test soils.

If NO, go to Q8.
Q8: Would you expect soils to be exposed at any time during the year (e.g., due to seasonal sports or other activities)? If YES, there may be a higher potential for exposure to contaminated soils. Use individual protection measures to minimize potential exposure and determine whether to test soils.

If UNSURE, check with the landowner or organization responsible for maintaining the property to see whether a maintenance program is in place to ensure that play and high-use/traffic areas remain thoroughly covered year round.

If NO, the potential for exposure to contaminated soils is less likely.

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