More than one in four U.S. residents are students, attending kindergarten through college. Most of these 75.8 million children, teenagers and adults - not counting faculty and staff members - are on campuses with written emergency plans.
Many plans expose them and their campuses to risk. According to the U.S. Government Accountability Office's 2007 report to Congress:
Our firm's experience with public and private campuses supports these facts. While well intentioned, the campus emergency plans we see are typically thin regarding:
There is no federal statute, regulation or standard requiring K- 16 campuses to create emergency response plans. Nor are there any state standards required of public or private K-16 campuses. Thankfully, 32 states require emergency plans for their public schools.
The U.S. Department of Education, Dept. of Homeland Security and Federal Emergency Management Agency have issued guidelines for campus emergency planning. Yet all are di Iferent. All are general. None are all-hazards.
So if there are no statutes, regulations, standards and consistent guidelines, you can write a campus emergency plan without worrying about compl iance issues, right? Wrong!
When you're the defendant, your planning and training will be scrutinized in your deposition and trial testimony. You may never get to trial because your attorneys will advise a settlement. They'll say, "We can't let you testifY that you didn't plan or train to the allhazards standard and federal law because it wasn't in the budget or it took teachers away from classrooms. Jurors believe you're mandated to keep children and employees safe." While NFPA 1600 is a "should," in the hands of Jitigators facing ajury, it's really a "shall." Add OSHA regulations, and you have a formidable set of compliance issues that you must meet to survive the legal crisis that follows an emergency.
Emergency planning for 75.8 million students and corresponding faculty and personnel is a huge undertaking. Given today 's threats, our campuses are not prepared. While there are no campusspecific federal laws, regulations or standards, campus emergency planners must pay strict attention to OSHA regulations and NFPA 1600. Ultimately, ajury will be the defining standard against which you and your campus will be held.
Bo Mitchell was Police Commissioner of Wilton, CT for 16 years. He retired in 2001 to found 911 Consulting which creates emergency, disaster recovery and business continuity plans, training and exercises for organizations like GE Headquarters, Cablevision, Goodrich, Western and Central Connecticut State Universities. He serves clients headquartered from Boston to LA working in their facilities from London to San Francisco. Bo has earned 16 certifications in homeland security, organizational safety and security. He also serves as an expert in landmark court cases nationally.
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