Risk Management: Identifying Environmental Impairment Risks

The risk of environmental impairment is known by a more familiar term: pollution. Regardless of the term you use to refer to this risk, it poses a considerable threat to many businesses, including organized camps. As if the risks of environmental damage weren't problem enough to manage, both federal and state governments have complicated matters by enacting sweeping and sometimes vague legislation that makes compliance difficult.

Fortunately, organized camps are stewards of the environment, not polluters. Preservation of the natural beauty and idyllic settings many camps enjoy is an important aspect of camp's mission. Teaching children respect and appreciation for the environment of camp and the world creates hope for the future and helps create "a world of good." An environmental tragedy at camp would be the antithesis to this philosophy and fundamental value of camp. While no camp director would be intentionally neglectful, the risks of environmental impairment/pollution can catch even the most risk management-minded camp director off guard.

Federal regulators, the Environmental Protection Agency (EPA) in particular, along with their state counterparts are focused on identifying sources of pollution and on presenting the potentially responsible parties with the bill for cleaning up the environment. This can be very expensive and potentially devastating to your business. Chances are the clean-up costs and the attendant civil liabilities that are generated by an environmental incident are not covered by general liability insurance.

Until 1986, most Comprehensive General Liability (CGL) policies covered the "sudden and accidental" release, discharge, or overflow of pollutants. Today, most CGL policies exclude the pollution/environmental impairment risk nearly completely, leaving your organization "bare" and probably in a position of assuming this risk blindly. While there is some insurance coverage available in the marketplace for environmental impairment liability, it is often limited in scope. Consequently, the best plan of action remains a combination of education, solid risk management practice, and insurance.

Identifying Environmental Impairment Risks

By now, you may be wondering where the environmental impairment and pollution risks are at camp. That is exactly the right thought and the place to begin; risk identification is the first step in the risk management process. Consider the following environmental impairment risks:

• underground storage tanks for gasoline, diesel fuel, and kerosene
• above-ground storage tanks for the same fuels
• old landfill or dump on camp premises
• water-treatment facilities on premises
• wastewater-treatment facility on premises; sludge disposal
• chemicals for pool, paints, solvents, herbicides, pesticides, and many common cleansing products
• gasoline pump near dock
• automobile repair and maintenance on premises raise issues for the disposal of waste oil and other fluids from the vehicles
• medical or "red bag" waste from the camp health center
• stable; disposal of manure and location of manure piles
• hazardous chemicals in photo lab

These are just a few of the areas where the risk of environmental impairment/pollution is present at camp. You can probably identify others unique to your site and operation. Take some time now to develop a comprehensive list of environmental impairment exposures.

You may want to seek outside help developing your list of environmental risks. If you do, look in the telephone book yellow pages under "Environmental & Ecological Products and Services" to find consultants who do environmental site assessments. They may be able to help with risk identification, along with risk management and compliance issues.

Besides using outside consultants, some directors call upon other directors for assistance. Others study the issue and educate themselves and associates to increase awareness of the risks. If you are interested in this approach, check out the EPA's Web site, www.epa.gov. Whichever approach you take, realize that accidents that result in environmental damage present a catastrophic exposure to your camp business and to the site you occupy.

Managing the Risks

Once you have your list of exposures, develop an approach to managing each one. This is the risk-control step in the risk management process.

Underground storage tanks
If you have older, steel underground storage tanks on your camp premises, one approach is to discontinue using them to reduce the risk of leakage into well, lake, and other ground water. Another approach might be to dig them up and remove them. If you discover they have leaked, you will have to remove the soil that has been contaminated. This can be expensive. There may be other approaches, such as removing the fuel and filling the tank with sand, which may allow you to leave the tanks in the ground. If you have such an exposure, obtain professional advice on which approach makes economic sense and is acceptable for your situation.

Aboveground storage tanks
If you have aboveground storage tanks for gasoline or other fuels, consider the risk of spill or leakage. Is the tank protected against damage from a collision with a vehicle or piece of equipment? If not, consider putting up a guard rail or steel posts to reduce this risk. If you have a self-service pump, what is the risk of a spill while vehicles are being fueled? Many gas stations have modified the pump handle removing the feature that allows the fuel to flow automatically. This is intended to reduce the risk of a spill. How does your gasoline pump handle work? Another risk control measure is to construct a dam around the above-ground tank to catch a spill if one occurs. If you don't make a dam, how will you contain fuel spills?

Chemicals
Chemicals for pools and water treatment, pesticides, herbicides, and many cleaning products used at camp are considered hazardous material. Your distributors should provide you with Material Safety Data Sheets (MSDS). These sheets list important information to help you identify risks and the hazards these chemicals present to the environment and the employees who use them. If you haven't done so already, take some time to read these and educate yourself and your employees. If you have questions about how to store, handle, or dispose of these chemicals in an environmentally safe fashion, contact the distributor. Another source for information is your local fire department's hazardous material team. Consider contacting them with your questions.

Managing environmental risks is challenging. Protecting the camp environment as a place to help children grow into responsible adults takes dedication, a lot of hard work, vigilance, and knowledge.

Originally published in the 2000 September/October issue of Camping Magazine.