Uniform Environmental Health Code: A Modern Management Tool for Progress
Stevens, Mark B., Roberts, Richard L., Bennett, Pamella V., Journal of Environmental Health
In "Environmental Stealth," Doser and Schmidbauer expressed fear that public health is not being adequately protected where poorly written laws and regulations are "...ignored, waived, compromised, modified or misinterpreted by the responsible regulatory agency." The author expressed a belief that laws and regulations should be viewed as "tools" to get public health work done (1).
A related viewpoint was expressed by Dr. Thomas H. Hatfield in his provocative paper, "The Failure of Sanitarians:"
"Sanitarians are and always have been professionals that apply many different disciplines to control environmental influences on health. ... The true power of our profession -- the ability of the generalist to integrate and apply multiple disciplines -- is the power we must exploit (2)."
Dr. Hatfield also emphasized how appropriately used negotiation skills could help EH professionals avoid the need to make compromises.
The authors of this paper believe these opportunities (for negotiated power and integrity without compromise) are especially present within the matrix of the Uniform Environmental Health Code (UEHC).
The responsibilities of EH professionals go beyond the mere enforcement of laws and routine daily activities. EH professionals also have an obligation to actively advance the cause of EH through review, analysis and participation in EH program advancement and development of modern EH laws (3). Laws and regulations arise out of public perceptions and concerns. EH professionals can help define emerging EH problems and develop solutions based upon sound (practical and scientifically based) health principles (4).
The development, adoption and use of the UEHC in San Bernardino County, California has been a successful response to these needs. It has furnished a proper tool so that multi-disciplined EH professionals have enjoyed jobs well done through "integrated EH power."
In San Bernardino County, the need for a UEHC began in the 1970s. At that time, county environmental health programs were transferred from the county Department of Public Health to a newly created Department of Environmental Health Services (DEHS). This was made possible by state legislation that recognized the value of independently administered EH programs.
After the transfer, several administrative problems came to the attention of DEHS management:
* EH elements of the county code were merged with traditional medical public health issues;
* Many city codes lacked EH elements or included conflicting county code sections. Code language was cumbersome and antiquated in many instances;
* DEHS was providing services to many cities without contractual or other legal authority. Court challenges to DEHS enforcement efforts were possible where codes and contracts were vague, inconsistent or absent;
* During and after the transfer, several new EH programs were developed that lacked code provisions for their implementation;
* EH programs were being provided to several cities at unequal service levels based upon traditions, unwritten agreements and other non-rational criteria;
* The 1978 California Property Tax Initiative (Prop 13) placed additional burdens on local government. As tax dollars diminished, health service fees were critically needed to support DEHS programs. Service delivery levels needed to be clearly stated in the EH codes and service contracts. Provisions to pay for optional and expanded services were needed; and
* Where EH problems transcended political boundaries, coordinated and uniform EH compliance procedures were needed for efficient solutions.
The need in focus
For DEHS to effectively meet these challenges, a legal tool, the UEHC, was urgently needed that would help assure the public that EH programs were: comprehensive, coordinated, of quality, cost effective, properly identified, prioritized, uniformly delivered, neutral regarding special interests, resourceful in solving multi-faceted problems, free of excessive and duplicative administrative overhead. …