School Response Framework

In 2008, the Colorado General Assembly amended 22-32-109.1 (4) to set forth a School Response Framework, or a school safety, readiness, and incident management plan. The School Response Framework consists of policies described in Senate Bill 08-181, and by satisfying the requirements of the Framework, a school or school district would be in compliance with the National Incident Management System (NIMS) developed by FEMA.

This detailed overview of the School Response Framework is written for schools and their community partners. It was prepared by Michael Dorn, Executive Director of Safe Havens International Inc., a non-profit school safety center whose analysts have worked in more than twenty countries to make schools safe, warm and supportive environments for children to grow and flourish.

This overview is excerpted from Dorn's longer article at School Safety Partners entitled, Using the Best Tools to Prepare for the Worst. As a registered member you are invited to leave a comment there, and your thoughts and suggestions would be most appreciated. Registration is free.

What is NIMS?

The National Incident Management System, or NIMS, is a system that has been developed for you by the Federal government. The system has already proven its effectiveness in hazardous materials incidents, natural disasters, hostage situations and other crisis events that have actually impacted schools in Colorado and around the nation. The National Incident Management System incorporates a concept known as the Incident Command System, or ICS, which has been in use by public safety agencies, hospitals, schools and other organizations since the 1970s. NIMS is a nationally standardized structure for local, state, federal and private agencies and organizations to help them work efficiently using teamwork and standardized concepts to make the most important decisions first using close coordination of available resources to prepare for, respond to and recover from crisis situations effectively.

With strong bipartisan support, the Colorado legislature and governor passed Senate Bill 08-181, which was introduced by Senator Tom Wiens, making Colorado the first state to make the National Incident Management System a mandatory requirement for all public and charter schools. The United States Department of Education urges school systems to become NIMS compliant and makes NIMS compliance mandatory for receipt of federal funding for school emergency response and crisis management grants. Many other states including New York, Georgia, Indiana, Florida, Wisconsin and New Hampshire have initiated substantial state - wide efforts to incorporate NIMS into their schools but Colorado is the first state to make NIMS compliance mandatory for all school districts.

This groundbreaking legislation will assist schools in dramatically improving safety and the level of emergency preparedness. Senate Bill 08-181 is designed to help Colorado schools continue to improve their level of emergency preparedness in a meaningful, achievable manner tailored to local risks, resources and realities. The legislation was passed because of a realization that school children, school employees and public safety responders can die if school officials are not prepared in advance to use NIMS effectively under actual field conditions during a crisis.

As noted in the legislation, "Each school day, Colorado school personnel are accountable for the safety of over 800,000 students, or about one-fifth of Colorado's population." Because educators are usually the first adults to become aware of and have the ability to start the response to school crisis situations, it is paramount they understand how to make key decisions quickly and work closely with community response agencies as a team rather than in a disjointed and ineffective manner as has often been the case without NIMS. The legislation is designed to provide support for schools in attaining NIMS compliance. For example, teachers who complete approved NIMS training such as the Federal Emergency Management Agency's free online training program IS-100.SC Tutorial Incident Command System for Schools can now receive professional development credits through the legislation.

As student and staff safety is the first responsibility of any school system, NIMS is not only a legislative requirement in the state of Colorado, it is a moral obligation for Colorado educators.

How have Colorado schools been doing on NIMS compliance prior to the legislation?

Discussions with law enforcement, fire service, emergency management and school leaders while the legislation was being developed indicated that as with schools in other states, Colorado schools varied widely in how effectively they have incorporated NIMS into their preparedness efforts. Some school systems have not incorporated NIMS at all while others have made significant progress. It appears that at the time the legislation is passed, most Colorado school systems were not NIMS compliant. School systems that have worked to implement NIMS should still utilize the self evaluation checklist included with this document to ensure they are compliant under the new legislation and should not assume they are already in compliance. It is also important that NIMS compliance, like all effective emergency preparedness strategies be viewed as an ongoing effort because school systems work to improve continually and NIMS is a continually improving concept.

Summary of MOUs

Besides requiring schools to implement NIMS, a key point of the legislation is a section designed to ensure schools and community response agencies collaborate closely in planning and preparing for emergencies. The legislation requires schools to formalize memoranda of understanding commonly known as MOUs with community partners. MOUs are written agreements outlining roles, responsibilities and use of resources during a crisis between collaborating organizations. For example, a school district should have MOUs in place for all off site family reunification sites not owned by the district. Schools lacking formal MOUs have frequently experienced major difficulty in resolving major crisis events.

Drills and exercises are needed to make NIMS a reality.

Experience has demonstrated that a thoughtful and progressive drill and exercise program tailored to the school environment is one of the most effective ways to help test school plans, procedures and equipment while allowing school employees and their community partners to practice implementing plans, procedures and using emergency equipment under carefully simulated crisis conditions. SB 08-181 embraces this concept as a way to carry out the implementation of NIMS in a realistic manner. This creates a sense of empowerment, confidence and comprehensiveness in emergency preparedness which allows responding school employees and public safety officials to turn chaotic situations into controlled and organized resolution of the crisis at hand.

Summary of Interoperable Communications

One key to successful resolution of school crisis situations requiring a public safety response involves the concept of interoperable communications. In a number of school crisis situations, school and public safety officials have reported extreme frustration and difficulty in resolving the crisis due to their inability to talk to one another via radio systems. A significant part of the support initiative for SB 08-181 involves efforts to help educate schools and community partners regarding new concepts and technologies making interoperable communications more feasible for schools. The ability of a school principal to talk directly to paramedics during a crisis event could easily mean the difference between life and death for an injured child.

What does it take for a school or district to become NIMS compliant under SB 08-181?

The requirements of Senate Bill 08-181 were based on best practices in emergency management and school emergency preparedness. Legislators incorporated feedback from emergency management professionals, law enforcement personnel, education leaders and others in designing legislation that would result in efforts designed to yield significant results for Colorado schools impacted by crisis situations in the future.

The following are mandatory provisions for schools under SB 08-181:

Adoption Requirements

Each school district has to establish a date by July 1, 2009, by which each school of the school district shall be in compliance with the requirements of the legislation. Each school district must make the dates established open to public inspection.

Command and Management Requirements

School systems must institutionalize the Incident Command System (ICS) as taught by the Emergency Management Institute of the Federal Emergency Management Agency. In addition, each school system on or before July 1, 2009, must start to develop in conjunction with "community partners" a school safety, readiness, and incident management plan that coordinates with any statewide or local homeland security plans and that, at a minimum, identifies for each public school in the district the members of the safety teams, with backups, who are responsible for interacting with community partners and assuming key ICS positions.

Preparedness: Planning Requirements

Each school must establish potential locations for ICS-defined incident facilities and other operational locations and support functions. To the extent possible, school districts must enter into a memorandum of understanding (MOU) with community partners specifying responsibilities for responding to incidents. Each school district must develop a timeline and strategy plan, and a schedule, and conduct all activities with community partners. School districts must work with community partners to update and revise all standard operating procedures, to incorporate NIMS and to reflect the National Response Framework. School districts are also required to coordinate with community partners to assess overall alignment and compliance with NIMS; to identify requirements already met; establish a baseline for NIMS compliance; and to determine action steps, including development of a plan and timeline to achieve and maintain all NIMS goals.

Preparedness: Training Requirements

Key emergency school personnel, including but not limited to safety teams and backups must complete NIMS training and other courses approved by FEMA's Emergency Management Institute or Colorado higher education system of Community and Technical Colleges.

Preparedness: Drill and Exercise Requirements

Incorporate NIMS and ICS into all emergency management training and exercises. To the extent possible, each public school is to create and participate in an all – hazards exercise program based on NIMS and to conduct tabletop exercises programs and other exercises in collaboration with community partners from multiple disciplines and, if possible multiple jurisdictions to practice and assess preparedness. As part of the exercise process, districts must hold orientation meetings to inform all parties about emergency operations plans and procedures. Districts must hold drills, in addition to annual fire drills to improve individual and student emergency response procedures; and develop tabletop exercises to discuss and identify different roles and responsibilities in different scenarios. Each public school has to conduct a written evaluation following the exercises and certain incidents as identified by the school or school district and identify and address lessons learned and corrective actions in updating response plans and procedures.

Resource Management Requirements

Each public school, at least every academic term, must inventory emergency equipment, and review communications equipment and interoperability with affected state and local agencies. To the extent permissible by law, school districts must ensure that relevant national standards and guidance to achieve equipment, communication, and data interoperability are incorporated into acquisition programs.

Communications and Information Management Requirements
 
School districts must adopt written procedures for taking action and communicating with local law enforcement agencies, community emergency services, parents, students, and media in the event of certain incidents as identified by the school or school district.

Conclusion

Senate Bill 08-181 raises the bar for the level of school preparedness while providing a support network for Colorado school leaders and their organizations. The concepts required in the legislation focus on informing, planning, training, maintenance of communications equipment, and coordination of drills and exercises. These processes are already in place in many Colorado schools and the legislation formalizes the incorporation of NIMS into these existing efforts. SB 08-181 was crafted to make its requirements not only achievable for all Colorado schools, but to support them in making existing efforts more efficient.

Senate Bill 08-181 is a major step in continuing the efforts of Colorado educators and their community partners to prepare for major crisis events. As we have seen, crisis situations have impacted many of our nation's best schools in communities that were considered by most to be safe places to live. Your efforts to develop a NIMS compliant school or district could easily one day save lives. Please join us in furthering the effort to protect Colorado's most precious natural resource -- our children.

For a full discussion of NIMS Implementation Activities, please visit our special section, NIMS Implementation.

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