Released June 18, 2013

Released June 18, 2013

From the press release:

On June 18, 2013 the Obama Administration released the Guide for Developing High-Quality School Emergency Operations Plans, the Guide for Developing High-Quality Emergency Operations Plans for Institutions of Higher Education and the Guide for Developing High-Quality Emergency Operations Plans for Houses of Worship.   These guides are the culmination of years of emergency planning work by the Federal government, and the first joint product of ED, DHS, DOJ and HHS on this critical topic. The guides incorporate lessons learned from the recent shootings in Newtown and Oak Creek as well as the recent tornadoes in Oklahoma, can be customized to each type of community, and may be used to create new emergency plans as well as to revise and update existing plans.

The planning process outlined in the guides will help schools, IHEs and houses of worship align their emergency planning practices with those at the national, state, and local levels. National preparedness efforts, including emergency planning, are now informed by Presidential Policy Directive (PPD) 8, signed by the President in March 2011, which describes the nation’s approach to preparedness. This directive represents an evolution in our collective understanding of national preparedness, based on the lessons learned from terrorism, hurricanes, school incidents, and other emergencies.

The new guides translate the planning guidance from these recent developments to the school, IHE and houses of worship contexts, ensuring that they benefit from these advancements, and introduce schools, IHEs and houses of worship to a new approach to planning that includes walking through different emergency scenarios to create a course of action for each objective the team is trying to accomplish, whether it be providing fire prevention training to all students and staff that work with combustible materials or evacuating everyone in the building.

The Guide for Developing High-Quality School Emergency Operations Plans, the Guide for Developing High-Quality Emergency Operations Plans for Institutions of Higher Education and the Guide for Developing High-Quality Emergency Operations Plans for Houses of Worship may be accessed on the REMS TA Center website (http://rems.ed.gov) at the following location: http://rems.ed.gov/EOPGuides.

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A few points of interest:

  • It’s not often that we see marketing statements included in the title of emergency management documents. By including “High-Quality”, the title is making an assessment about the document (similar to how “I Can’t Believe It’s Not Butter” is both a statement and a title). Clearly, the team that created these guides saw all the pure crap that is considered sound planning on the internet and decided they needed a bold assertion in the title. I’m looking forward to the “High-and-Dry Floodplain Management Plan”, the “Got Risk? Risk Management Plan”, the “Just Do It! Field Operations Guide,” and the “It takes a licking and keeps on ticking! Shelter Operations Manual”.
  • I like that the planning team was comprised of a diverse collection of agencies such as the U.S. Department of Education, U.S. Department of Health and Human Services, U.S. Department of Homeland Security, U.S. Department of Justicem, Federal Bureau of Investigation, and Federal Emergency Management Agency.
  • I love that the templates include Prevention and Protection in addition to Mitigation, Response, and Recovery. Schools need to be in the mindset of planning and coordinating prevention and protection measures (especially using the core capabilities and PPD framework).
  • The guide for EOP planning for higher education replaces “Action Guide for Emergency Management at Institutions of Higher Education” (January 2010), which is rescinded. This is a big leap and all schools need to review and revise their plans based on the newest guidance.
  • The templates provide a clean-looking six-step planning process
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  • The templates offer very specific roles and responsibilities–this is excellent! For higher education, the template offers recommendations for residential life personnel, food services, general counsel, and many other offices/positions. Often in emergency preparedness in the academic environment, there’s a sense of diffusion due to the large number of people, departments, vendors, and services involved in emergency management. This cross-disciplinary, continuous program management is difficult in all settings, but in higher education this seems especially true.
  •  The templates suggest four assessments: Site Assessment, Climate Assessment, Threat Assessment, and Capacity Assessment. This sounds good–but complex and laborious. Not sure why the THIRA wouldn’t be a good recommendation since it’s being implemented as a standardized threat, hazard identification, and risk assessment tool. In my humble opinion, the THIRA probably could have been slightly modified (perhaps THIRA-ED…even rhymes with higher-ed!) to offer academia and emergency management offices a standardized assessment methodology.

(perhaps THIRA-ED…it even rhymes with higher-ed!)

  • The templates stress including planning for individuals with access and functional needs as well as those with limited English language proficiencyScreen Shot 2013-06-21 at 7.22.06 AM
  • I am absolutely thrilled about how the planning team chose to explain lockdown–not as an unreasonable, illogical panacea to all active shooter incidents (which goes against DHS guidance for active shooter response). I’m happy to buy the authors a drink after reading this. Here is the guides’ explanation verbatim:Deny Entry or Closing (Lockdown) Annex
    This annex focuses on the courses of action IHEs will execute to secure IHE buildings, facilities, and grounds during incidents that pose an immediate threat of violence in or around the IHE, such as a crime or bomb threat. The primary objective of a lockdown is to quickly ensure all faculty, staff, students, and visitors are secured in rooms away from immediate danger.
  • Including continuity of operations (COOP), psychological first aid, and recovery annexes in the template is very good planning–it’s what I do with my clients and I rarely see it replicated.
  • Excellent use of easy-to-understand language throughout the templates. For example, the higher ed template includes guidance on “Common FERPA Misunderstandings” and intelligently warns against “misinterpretations of the law and subsequent delays in information sharing can hinder first responders’ efforts to provide necessary assistance in a health or safety emergency”
  • The Questions and Answers at the end of the template is very helpful and makes it easy to comprehend difficult and commonly misunderstood issues, such as “How does FERPA interact with the Health Insurance Portability and Accountability Act of 1996 (HIPAA)?”
  • This answer has been the victim of many rumors and falsehoods over the years–it’s time some clear guidance was issued:

    Generally, HIPAA does not apply to health information in student records maintained by an IHE. While IHEs may maintain student health records, these records are in most cases not protected by HIPAA. Rather, student health information maintained at an IHE would be considered education or treatment records protected by FERPA

  • The templates include very simple but revolutionary ideas–especially regarding active shooter incidents, for example:
  • No single response fits all active shooter situations; however, making sure each individual knows his or her options for response and can react decisively will save valuable time.

Overall these are very strong planning guides and constitute a huge leap in emergency preparedness planning for vulnerable sites like schools and places of worship. Unfortunately, we are about 10 years overdue for this guidance.

Keep the momentum going!

My recommendation would be to not disband the planning team that authored these templates. Instead, keep them together. Develop a schedule of fact-finding trips and exercise evaluation for schools and places of worship. Provide the team with resources to respond after a school shooting or incident at a place of worship to identify lessons learned, best practices, and validate assumptions.

The military doesn’t disband special forces teams after a successful mission–that would  be silly. But we do that in emergency management all the time. We need continuity and momentum. We need to have a “special ops” team that specializes in planning doctrine and has its finger on the pulse of emergency management in schools and places of worship. The team would actively monitor feedback loops, thus allowing them to be proactive. Additionally–in my dreams of the perfect solution–the team would be able to provide cursory technical assistance to schools and places of worship. I know it’s far-fetched, but a branded team with an identity to develop standards and perform national outreach is the tonic we need. If it saved just one schoolchild’s life–it would be worth all the cost and hassle and bureaucratic hurdles.

As of today, it’s been 6 months and one week since the Sandy Hook Massacre. Let us never forget those innocent children and the brave adults that did everything to save them. Now it is time for us to do everything we can to prepare, protect, and prevent a similar incident.

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