Abstract

The concept of institutional control has been present in the environmental industry since the advent of the Comprehensive Environmental Response, Compensation and Liability Act of 1976. Many federal facilities undergoing environmental remediation under this Act have made valuable use of institutional control as an interim remedial action and as an important portion of final remedial alternatives. The core concept of institutional control has been to put in place administrative policies or physical barriers between potentially exposed populations and a contaminant source to avoid unwanted exposures to the potentially exposed populations.

The concept of estimating the risk to humans from exposure to contamination and its use as a defining criteria as to whether a site must undergo active remediation have been around just as long. Institutional control and human health risk assessment are intimately linked as crucial parts of the greater remedial alternative analysis topic—human health risk assessment being a determining criteria for proceeding with active remediation and institutional control being one of those remedial alternatives.

Institutional control’s core concept has very dramatic influences on the science and practice of human health risk assessment. A vital portion of human health risk assessment involves defining probable human receptor populations by using a set of criteria of which land use scenarios are a key part. A foundational goal of human health risk assessment has been to define realistic land use scenarios that can limit the number and types of potential exposed populations for which risk estimates must be calculated.

Institutional control by its regulatory definition limits potential land use on a given contaminated site, therefore limiting the realm of potential (realistic) exposed populations that should be considered in a human health risk assessment. This relationship makes the early identification of institutional control as part of an overall final remedy paramount to conducting efficient realistic human health risk assessment. In successfully doing so, remedial action managers and risk assessors must confide closely in each other to determine the probability of institutional control as a viable remedial action. Such cooperative strategy saves resources for both the remedial action manager and the risk assessor by avoiding unnecessary work to account for improbable exposure scenarios that can drive unnecessary remediation. The early consideration of institutional controls in defining future land use scenarios and therefore risk assessment exposure scenarios saves considerable money, time, and resources involved in successful remediation projects.