Instructor Guide for Module 3 - Empire State Public Health Training

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Instructor Guide for Module 3
Organization and Legal Basis of Public Health
Introductions and Pretest
A Brief History of Public Health
Modern Public Health: Tools and Functions
Organization and Legal Basis of Public Health
Public Health Ethics
Posttest and Course Evaluation
Developed by:
Continuing Education, School of Public Health, University at Albany and the
Professional Development Program, Rockefeller College, University at Albany
Instructor’s Guide
Organization and Legal Basis of Public Health
Acknowledgements
The development of these training materials was made possible by support from the New York
State Department of Health and the New York New Jersey Public Health Training Center, which
is funded through a grant from the Health Resources and Services Administration (HRSA) of the
U.S. Department of Health and Human Services.
Project Coordinator
Carol Young, PhD, Continuing Education, School of Public Health, University at Albany
Content Experts

Robert Burhans
NYSDOH

David O. Carpenter
UAlbany

Andrew Doniger
Monroe Co. (NY) DOH

William Leavy
UAlbany

Patrick Trapp
NYSDOH

Carol D. Young
UAlbany

Vicki Zeldin
NYSDOH

NYNJ Public Health Training Center Team

Pennsylvania and Ohio Public Health Training Center
Research, Design, and Editing
Cheryl Reeves, MS/MLS, Continuing Education, School of Public Health, University at Albany
Instructional Technologies Unit, Professional Development Program, Rockefeller College,
University at Albany
Contact Information
New York New Jersey Public Health Training Center
http://www.nynj-phtc.org/
Carol Young, PhD
School of Public Health, University at Albany
One University Place
Rensselaer, NY 12144-3456
Phone: (518) 402-0330
Fax: (518) 402-1137
E-mail: cyoung@albany.edu
Web: http://www.albany.edu/sph/
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Instructor’s Guide
Organization and Legal Basis of Public Health
How To Use This Guide
This Instructor Guide accompanies the MS PowerPoint slides for Module 3 Organization and
Legal Basis of Public Health. It contains the slides, notes, key points, and additional references
for the instructor’s presentation of Module 3.
Instructors are encouraged to modify the material to suit the specific audience and/or location of
instruction. Specific instructions on how to modify PowerPoint presentations can be found in the
Course Guide, which should be used in conjunction with each of the Instructor Guides.
All materials may be downloaded from the comprehensive curriculum source page at
http://www.nynj-phtc.org/intro/.
The entire course (Modules 0-4) is intended to be presented in six-hours. Module 3 is designed
to take 60 minutes.
Before you Begin


Read the Course Guide for Instructors, which explains how to
o
Organize the entire day’s presentation
o
Create student guides
o
Use PowerPoint software
Teaching tips, preparation checklists, and many other details are also provided. The
Course Guide is found under “Other Materials” on the source page.
Read the Instructor Guide for each module to become familiar with the content and flow.

Look for notes and slides that require examples specific to your own training situation
(i.e., audience, health department, location).

Determine whether a module’s generic presentation should be modified for your specific
audience. Additional slides may be found under “Other Materials” in the file “Additional
Slides.”

Review all activities in this module. Make sure you have materials to hand out to
participants.
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Instructor’s Guide
Organization and Legal Basis of Public Health
Module 3: Organization and Legal Basis of PH
Slide 1
Key Points:


Slide 2
The focus of this module
o
Explain the legal basis for our activities in
public health
o
Address core legal competencies for
front line professional staff
Does not address specific state laws or state
organizational structures.
Key Points:


Legal responsibilities and limitations
o
What obligations does the public health
professional have?
o
What limitations are imposed on public
health professionals?
o
What legal liabilities does public health
work have when balancing the rights of
the individual and obligations for public
safety?
Organizational Structure
o

Sources and scope of authority for public
health laws
How your job fits into the big picture (combines
the first two objectives)
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Organization and Legal Basis of Public Health
Slide 3
Key Points:

Inherent in public health is the tension between
individual rights and the protection of the larger
community. Ask group for examples:
o
Smoking vs. indoor air
o
Fluoridation and vaccination
o
Motorcycle helmets and speed limits
o
Physician-assisted suicide

Public Health law balances this tension.

Next 3 slides are stories of these tensions
See “Background Materials” at the end of this Instructor Guide.
Slide 4
Key Points:

Stories that tell the power invoked to protect
public health:
o

Tell the story of TYPHOID MARY
Consider these personal freedoms:
o
o
o
Freedom of Movement:

Quarantine

Isolation Procedures
Bodily Freedom:

Mandatory Vaccination

Screening for Tuberculosis
Privacy:

Disease Reporting

Disease Notification
See “Background Materials” at the end of this Instructor Guide.
Source of Graphic: Work Projects Administration (WPA) Federal Art Project,
poster created between 1936 and 1941. Courtesy of Library of Congress,
Prints & Photographs Division, FSA-OWI Collection, [LC-USZC2-1594 DLC
(color film copy slide)].
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Instructor’s Guide
Organization and Legal Basis of Public Health
Slide 5
Key Points:

Stories that tell the power invoked to protect
public health:
o

Tell a story related to one of these public
health responsibilities (vaccination,
mandatory reporting, inspection,
licensure)
Consider these personal freedoms:
o
o
o
Freedom of Movement:

Quarantine

Isolation Procedures
Bodily Freedom:

Mandatory Vaccination

Screening for Tuberculosis
Privacy:

Disease Reporting/Notification
See “Background Materials” at the end of this Instructor Guide.
Source of Graphic: Work Projects Administration (WPA) Federal Art Project
[poster created about 1940]. Courtesy of Library of Congress, Prints &
Photographs Division, FSA-OWI Collection, [LC-USZC2-5208 DLC (color film
copy slide)].
Slide 6
Key Points:


Stories that tell the power invoked to protect
public health:
o
Tell a story related to public nuisance
(e.g., see photo), OR
o
Ask group for stories/examples about a
public nuisance
Legal Point: Public health has broad powers to
address public nuisances that threaten the
public’s health.
Photo: Image of Bailiff Morris Wilson taking cats from
the home of Anna and Isabella Patton. Circuit court
bailiffs collected 50 cats that lived in the house. Anna
Patton is standing in the street, by a Quaker Oats crate,
and Isabella Patton is coming out of their home,
carrying a box. The Patton home was located at 7359
South Kenwood Avenue in the South Shore community
area of Chicago, Illinois.
This photonegative taken by a Chicago Daily News photographer was
published in the newspaper on November 9, 1915. Courtesy of Library of
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Instructor’s Guide
Organization and Legal Basis of Public Health
Congress, Prints & Photographs Division, FSA-OWI Collection, [DN0065343, Chicago Daily News negatives collection, Chicago Historical
Society].
See “Background Materials” at the end of this Instructor Guide.
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Organization and Legal Basis of Public Health
Slide 7
Key Points:


Slide 8
Authorities AND limits on authority have the
same legal basis
o
Public Health Departments have many
responsibilities, powers, and extensive
authority
o
Courts have interpreted the state “police
power” broadly
PH officials must weigh an individual’s rights
against society’s need for protection
o
Public Health officials have limits placed
on their powers
o
Tension between some public health
requirements and the freedoms they
affect
o
The individual, with certain civil rights
and liberties, has the right to challenge
public health laws
Key Points:


Basic components of due process fairness are:
o
NoticeGiving adequate information
about legal requirements to the persons
affected, so that they can avoid the
consequences of noncompliance. Laws
must be written clearly and precisely.
o
An opportunity to be heardIntended
actions must have an opportunity to be
challenged
Ask group for examples of Due Process OR
give examples
o
Example: A public health agency cannot
revoke a nursing home license without
giving the owner notice of the action and,
under most circumstances, an
opportunity to challenge the action before
the license is revoked. In an emergency
situation the agency may unilaterally
revoke a license, but must then give the
owner an opportunity to challenge the
action in a later hearing.)
See “Background Materials” at the end of this Instructor Guide.
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Organization and Legal Basis of Public Health
Slide 9
Key Points:

Unless a meaningful factual difference exists
between two activities, two persons, or two
situations, the Constitution requires that they be
treated alike. Government and the legal system
cannot arbitrarily discriminate.

Applies to both the law and its application.

Ask group for examples of Equal Protection
OR give examples
o
Example: In 1886, the Supreme Court
held that a local ordinance prohibiting the
construction of wooden laundries without
a license—although a valid safety
measure on its face—had been
implemented in a way that violated the
equal protection clause. Almost all
Chinese applicants were denied licenses,
while nonChinese applicants routinely
received them [Yick Wo v. Hopkins, 118
U.S. 356, (1886)].
See “Background Materials” at the end of this Instructor Guide.
Slide 10
Key Points:


Ask group for examples of Public Health’s
Protection of the Population OR give
examples
o
Immunization requirements
o
Fluoridation
o
Compulsory HIV testing
o
Helmet and seat-belt use laws
o
Indoor smoking bans
Ask group for examples of the Individual’s
Right to Privacy OR give examples
o
Legalized birth control -- Griswold v.
Connecticut (1965)
o
Legalized abortion -- Roe v. Wade (1973)
See “Background Materials” at the end of this Instructor Guide.
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Organization and Legal Basis of Public Health
Slide 11
Key Points:

Summarize due process and equal protection

Remember that the public health professional IS
government.
Photo courtesy of U.S. Environmental Protection Agency (“November and
December 2003 are Water Security Month”) at
http://epa.gov/ogwdw/index.html
Slide 12
Slide 13
See “Background Materials” at the end of this Instructor Guide.
Key Points:

The Department of Health and Human Services
(HHS) oversees the major federal public health
agencies.

HHS and its subsidiaries provide:

o
Primary federal funding to each state.
o
Difficult or prohibitively expensive
services.
The newest addition (Federal Register: January
15, 2002 (Volume 67, Number 10), Notices,
Page 1980) is the Office of Public Health
Preparedness (OPHP), “to direct activities of the
Department of Health and Human Services
relating to protecting the civilian population from
acts of bioterrorism and other public health
emergencies.”
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Slide 14
Key Points:


Home rule authority
o
To avoid the need for specific
authorization each time a new need
arises, most states—either through
legislation or by constitutional
amendment—have given local
governmental units the right of local selfgovernance, to make decisions
concerning their own welfare.
o
Home rule allows local government to
carry out public health and other
functions without having to seek
legislative authority anew for each
specific activity.
o
Without constitutional or statutory home
rule authority, cities and town
governments would not be empowered
with their own rule-making functions.
Examples of home rule authority:
o
Courts upheld the New York City health
department's authority to require window
guards in high-rise residences.
o
San Francisco declared a “public health
emergency” and authorized needleexchange programs that were otherwise
illegal under state law.
See “Background Materials” at the end of this Instructor Guide.
Slide 15
Key Points:

Give example of Governmental Roles – e.g.,
Tuberculosis (TB)
o
o
o
Federal Government (CDC)

Provides funding to states to
control TB

Performs research on strategies
for testing and treatment of TB
State Health Departments

Provides funding to local
communities to control TB

Trains health care professionals
Local Health Departments

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Receives reports of new cases
from hospitals, physicians, and
Instructor’s Guide
Organization and Legal Basis of Public Health
labs

Tracks the care of TB patients

Finds contact to cases and
provides preventative treatment
to the contacts before they
become ill
See “Background Materials” at the end of this Instructor Guide.
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Organization and Legal Basis of Public Health
Slide 16
Key Points:

Local Health Departments have Special
Emergency Powers
o
In many ways the local health
commissioner or board of health is the
most powerful entity in local government.
o
In most communities, the board of health
can close down a facility or stop
community activities to protect the health
of the public without a court order.
o
Local boards can order quarantines and
isolation of patients infected with
communicable diseases.
o
Local governments have the authority to
declare “a state of emergency” to enable
the government and other agencies to
respond effectively in emergencies (e.g.,
to close the roads to traffic after a
windstorm that knocks down power poles
and tress).
Slide 17
Slide 18
Key Points:

Any society’s laws serve the functions of social
control and conflict resolution.

You are part of the governmental system of
laws, rules, and regulations.

Law is an important tool in achieving public
health goals.

Public health problems often can be resolved
without having to resort to confrontation.
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Slide 19
Key Points:


A strong hand is the last resort.
o
Explain the reason for the regulation.
o
Find areas of agreement.
o
Violators are not criminals.
When there is a threat to health or safety, take
action.
o

If you see a dangerous circumstance,
you have police authority.
Your first response should not be to litigate.
o
Reach cooperative solutions to problems
through negotiation.

Effective communication is essential to fulfilling
the core public health functions of assessment,
policy development, and assurance.

Ask group for examples of alternative
solutions to situations.
See “Background Materials” at the end of this Instructor Guide.
Slide 20
Key Points:


Your power and authority to protect the
population come from the laws.
o
Power comes from the laws.
o
Regulations come from the laws.
Legalities and ethics overlap
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Slide 21
Key Points:

Slide 22
Know the code, rule, regulation, or ordinance
you enforce.
o
What is your code?
o
What does it say?
o
What are the requirements?

Seek assistance if you think an action may
provoke legal implications. Go to the “higher
ups.”

Educational role: tell people how to abide by the
code.

ENFORCE THE CODE AND NOT YOUR
OPINION.

Although you have legal responsibilities and
powers, your work is in the public’s interest –
you have the public’s trust.
Key Points:


Anybody can be sued, but the courts have
traditionally sided with public health officials.
o
Keep the State informed.
o
Behave in a professional manner.
o
Act in good faith.
Give an example of being sued
o
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A local PH department did not permit a
rock concert to be held in a farmer’s field.
Because the concert’s promoters had
already marketed the event, the
sanitarian and the health department
were both sued by the promoter. Would
you rather be sued by a rock promoter or
by the parents of a dead rock ‘n roll fan?
Instructor’s Guide
Organization and Legal Basis of Public Health
Slide 23
Key Points:

Hand out a case study (Handout 3.1)

Use this or another case study to explore legality
issues.
A farmer in your county owns five dogs in addition to
several barn cats and livestock. A raccoon was found in
the cow barn at 6 pm when the family entered to start
the evening chores. One of the dogs was injured, and
one of the barn cats killed in a fight with the raccoon.
The raccoon subsequently tested positive for rabies. It
is not known whether the other four dogs or any of the
barn cats were exposed to rabies, although the other
dogs were involved in chasing the raccoon around in
the barn. Therefore, the risk of exposure was high.
None of the domestic animals is vaccinated for rabies. A
large animal veterinarian making a routine visit to the
farm two days later checked the cows for wounds and
found minor scratches on a couple of them. However,
the cause of the scratches was unclear (the pastures
and barnyard were mostly fenced with barbed wire,
which the cows sometimes jostled each other against).
Current law requires that animals not actively
vaccinated for rabies that have been exposed to a
potentially rabid animal be quarantined for six months at
the owner’s expense, or euthanized. The farmer refuses
to put any of the dogs in quarantine or to turn them over
to the County Health Department. Complicating matters
further, you have heard that one of the dogs involved in
chasing the raccoon is a housedog which sleeps on the
farmer’s bed at night.
What is your response?
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Background Materials and References


Slide 3 Background
Historic “tension” between protecting a population’s health and preserving the rights of
the individual.
Segue review from Module 1 -- “History of Public Health”
o
Laws and regulations to protect the health of the community are found in virtually
all civilizations, Eastern and Western
o
Tribal Rules passed on through oral traditions
o
Chinese Empire
o
Bible (Leviticus spells out the rabbi’s power to evict lepers and demolish their
housing)
o
Koran (detailed food codes)
o
Roman Senate
Slide 4 Background
Story of Typhoid Mary
Mary Mallon was a carrier of typhoid. She was a cook in a house in Mamaroneck, N.Y., for less
than two weeks in the year 1900 when the residents came down with typhoid. She moved to
employment in Manhattan the next year, and members of that family developed fevers and
diarrhea, and the laundress died. She went to work for a lawyer, until seven of the eight
household members developed typhoid. Mary spent months helping to care for the people she
made sick, but of course the contact made many of them worse. In 1904, she took another
position on Long Island. Within two weeks, four of ten family members were hospitalized with
typhoid. She changed employment. Three more households infected.
In 1906, the strange outbreaks of cases in New York attracted the suspicion of Dr. George
Soper. Typhoid usually strikes in poor, unsanitary conditions; cases among the rich (and
sanitary) were unusual. He discovered that the common element was an unmarried, heavyset
Irish cook, about forty years old. No one knew her whereabouts. After each case she left and
gave no forwarding address. Dr Soper traced her to an active outbreak in a Park Avenue
penthouse--two servants were hospitalized and the daughter of the family died. Soper
interviewed Mary, and suggested there might be a connection between the dishes she served
and the outbreaks of typhoid. She cursed at him. He requested a stool sample, and she
threatened him with a meat cleaver. Finally, police and the New York health commissioner
arrested her. She went kicking and screaming.
Under questioning, she said she rarely washed her hands when cooking and felt there was no
need--she didn't consider herself a threat. Cultures of Mary's urine and stools (taken forcibly
with the help of prison matrons) revealed that her gallbladder was teeming with typhoid
salmonella. She refused to have her gallbladder extracted or to give up her occupation as cook,
maintaining stubbornly that she did not carry any disease. It's interesting that the state was quite
willing to pay for cutting out her gall bladder--an operation that usually had no effect but carried
a real risk of killing her--but didn't even consider disability relief or payments for not cooking.
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Authorities confined her to a cottage in the Bronx, where she lived and ate alone. She was
effectively imprisoned without trial. She worked at Riverside Hospital as a laundress. In 1910,
promising to remain a laundress and never return to cooking, Mary was released. She changed
her name to Mary Brown and got a job as a cook. For the next five years, she went through a
series of kitchens, spreading illness and death, keeping one step ahead of the frustrated Dr.
Soper.
In 1915, a serious epidemic of typhoid erupted among the staff of New York's Sloan Hospital for
Women, with twenty-five cases and two deaths. City health authorities investigated, learning
that a portly Irish-American woman had suddenly disappeared from the kitchen help. The police
tracked her to an estate on Long Island. She refused to cooperate with health authorities,
withheld information about her past, and used different pseudonyms when she changed cities.
Three deaths have been definitely attributed to her, with estimates running as high as 50.
Mary was quarantined for life on North Brother Island. She died in 1938 of pneumonia. The
autopsy revealed that her gallbladder was still actively shedding typhoid bacilli. She was buried
by the Department of Health at Saint Raymond's Cemetery in the Bronx.
Slide 5 Background
Jacobson v Massachusetts (1905) Com. v. Pear, Com. v. Jacobson, 67 L.R.A. 935, 183
Mass. 242, 66 N.E. 719 (Mass., Apr 02, 1903) (Compulsory Vaccinations, Small Pox, Police
Powers)

This is a suit against Mr. Pear and others to recover a fine of $5 for refusal to submit a
Small Pox vaccination pursuant to a health statute. The statute in question, R.L.c.s 137
orders all residents of the city who have not been vaccinated or revaccinated to do so
due to the prevalence of Small Pox. The board of health informed Mr. Pear that he
would have to be vaccinated or pay a $5 penalty. Mr. Pear refused and was
prosecuted. Mr. Pear claimed that the statute was unconstitutional under both the
United States Constitution and the Massachusetts Constitution. The court found that the
statute was not unconstitutional. The court recognized that the Constitution of
Massachusetts authorizes such police powers in order to protect public health and
safety. Mr. Pear also claimed that the court erred in not allowing him to admit testimony
of medical experts who opposed vaccination. This case was then appealed to the
United States Supreme Court, which upheld the Mass. Court in the classic public health
case, Jacobson v. Commonwealth of Massachusetts, 197 U.S. 11 (1905)

Source: http://biotech.law.lsu.edu/cases/vaccines/Jacobson_v_Massachusetts_brief.htm
Herman Biggs, Commissioner of Health of the State of New York (1892)

In 1892, Dr. Herman Biggs of New York started mandatory reporting of TB cases. The
board adopted most of the recommendations made by Biggs, including the creation of
the Consumptive Hospital. These recommendations created a storm of controversy
among the medical community. Many private doctors objected to the mandatory
reporting, believing that it violated physician-patient confidentiality. Because of the
resistance from the medical community, reporting practices were not fully implemented
for several years. In the end, Biggs' recommendations to the Board and their
implementation in New York City created the model for TB control programs that was
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emulated by other health departments across the country and laid the groundwork for a
campaign called the "War on Consumption.“
Slide 6 Background
Public Nuisances
[n] (law) a broad legal concept including anything that disturbs the reasonable use of your
property or endangers life and health or is offensive

http://www.mrsc.org/Subjects/Legal/nuisances/nu-what.aspx
In very general terms a nuisance is something that annoys -- a wearing on the nerves by a
persistent unpleasantness. It can evoke anger and interfere with comfort and peace of mind. In
a regulatory environment the term nuisance embraces anything that results in an invasion of
one's legal rights. A nuisance involves an unreasonable or unlawful use of property which
results in material annoyance, inconvenience, discomfort, or damage to another person or to the
public. The unlawful use may involve doing something (example: piling garbage on residential
property) or failing to do something (example: cutting or removing noxious weeds from
residential property).
Nuisances are sometimes called nuisances because they are remedied by abatement.
Common nuisances include the accumulation of junk, animals, noise, dangerous buildings,
sewage and unsanitary conditions, and encroachments on public right-of-way which interfere
with pedestrian passage. The words abate and abatement are the legal terms used to describe
the process for putting an end to, or terminating the nuisance.
Slide 8 Background

Fifth Amendment: “No person shall be…deprived of life, liberty, or property, without
due process of law; nor shall private property be taken for public use, without just
compensation.”

Fourteenth Amendment applies due process to state governmental actions.
Slide 9 Background

Fourteenth Amendment: “Nor shall any state deprive any person of…equal protection
of the laws.”

Equal protection does not require the same treatment in all instances. For example:
o
More stringent driver’s license requirements to persons over 75 years of age.
o
Preferences to children, pregnant women, or special risk persons.
Slide 10 Background
Note the difference between intimate and nonintimate behavior. The courts have consistently
rejected the argument that compulsory seat-belt use laws violate the Constitutional right to
privacy. The court's recognition of individuals' right to privacy in deciding when and whether to
have a child in Griswold became the basis for later reproductive rights decisions. In Eisenstadt
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v. Baird (1972), the court granted unmarried couples access to contraception, and in Roe v.
Wade (1973), the court recognized a woman's right to choose abortion.
Slide 12 Background

1798 Marine Hospital Service (prevent importation of epidemic diseases) evolved into
U.S. Public Health Service.

Influence of the federal government grew after the levy of a federal income tax (16th
amendment - early 20th century)
Slide 14 Background

Tenth AmendmentThe powers not delegated to the United States by the Constitution,
nor prohibited by it to the States, are reserved to the States respectively, or to the
people.

State health agencies: All fifty states, the District of Columbia, and the territories of
Guam, Puerto Rico, American Samoa, and the U.S. Virgin Islands have a state or
territorial health agency (which we will call a state agency for brevity). Each state health
agency is directed by a health commissioner or a secretary of health. Each state also
has a chief state health officer, who is the top public sector medical authority in the state.
(The same person may fill both positions, or the chief state health officer may answer to
the director of the state agency.)

State boards of health: As of 1982, twenty-four states had boards of health. In most of
these states, the chief health officer reports to the board. In some states, the chief health
officer is a member of the board. More than 90 percent of the state boards are appointed
by the governor. The remainder are appointed by professional associations or by the
state health agency director. The general responsibilities of state boards of health are
policy and budget related.

State and Local Government on the Net at http://www.statelocalgov.net/index.cfm

It is common for city councils to develop their own local public health ordinances or
health codes. This autonomous exercise of power is limited by the rule that localities
may not assign responsibilities to local health departments that are in conflict with state
laws and regulations. Thus public health law is even more of a patchwork at the local
level, where health departments are not only responsible for local public health
ordinances but must also deal with enforcement authority, responsibility, and limitations
established by state law.

Slide 15 Background
Local regulations must be consistent with NYS law – can be more stringent.
o
Ask: What does “stringent” mean?
o
(Answer: STRICT -- Webster’s New World Dictionary – “1. Rigidly controlled,
enforced, etc.; strict; severe.”

Give an example of a local rule, regulation, or ordinance that is “more stringent” than the
rule, regulation, or law of higher authority.

Ask: Can a local rule be less stringent than a state regulation? (No)

Ask: Because of HOME RULE, can a local rule be less stringent than a State law? (No)
page 20 of 21
Instructor’s Guide
Organization and Legal Basis of Public Health

NYS example of process: NYS Clean Air Act
o
State Health Commissioner (Axelerod) passed a regulation that was challenged
by the legislature
o
Court ruled that Axelerod overstepped his authority
o
Legislature passed legislation that was similar to the regulation
Slide 19 Background

What do you have an obligation to enforce and how do you enforce it?
o
Restaurant inspections – if the food temperatures are not acceptable, do you
shut down the business?
o
Nursing home inspections – if the alarm system is down, do you shut down the
business?
o
Indoor smoking
Handouts for Module 3

3.1 Case Study (MS Word document)
page 21 of 21
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