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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:
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
Aboveground storage tanks
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.