We Only Need One ICS

I came across an article yesterday posted on EMS1/AMU’s blog about EMS adopting an incident command system.  It’s an article that leaves me with a lot of questions.

I want to examine some individual statements within the article.

  1. “Many EMS providers lack training and awareness about implementing an incident command structure.”

 

This is 100% true, but I’ll also expand this statement across much of public safety and emergency management.  Aside from well-experienced practitioners of ICS, which there are relatively few compared to the greater public safety/EM community, most simply aren’t equipped to implement a significant incident management system.  The biggest reason is that ICS training sucks.

 

  1. “EMS organizations have only recently recognized the value and need for such a command structure as part of their response strategy.”

 

I would suggest that this is partly true, but in many parts of the nation, requirements and standards have been established by way of executive order, state and regional EMS protocols, and other means for EMS to use ICS.  Many of these have been in place since the 90s, before HSPD-5 and NIMS requirements, but certainly with the emergence of NIMS in 2003, this has largely been a standard of practice for EMS, if not a requirement in many places (and under specific circumstances, such as required through OSHA 1910.120).  While I understand that ‘standards’ and ‘requirements’ don’t necessary define value, they essentially dictate a need.

 

  1. There was a recognition that “EMS providers were having difficulty applying fireground incident command practices to EMS calls.”

 

While I agree with what I think is the spirit and intent of this statement and bring this back to my comments on item 1 above, I’m still cringing at the ‘fireground incident command’ phrase in this statement.  ICS isn’t just for the fireground. While it may have been born in wildfires, that was decades ago.  We are now officially in 2019 and should be well past this concept that ICS is only for the fireground.  Even if we disregard, for the sake of discussion, the requirements for all responders to use ICS, such as those in OSHA 1910.120, which predate NIMS, HSPD-5 was signed almost 17 years ago!  Nothing in HSPD-5 or the original NIMS document elude to the current implementations of ICS being a fireground system.  It was to be applied to all responders.

 

  1. “During a response, providers did not establish a formal command structure”

 

Totally true.  This applies, however, not just to EMS, but to most of public safety.  See my comment for item 1.

 

  1. “In 2012… they began to research various fire and EMS command models that were scalable and practical for all types of critical EMS calls.”

 

I’m not sure why there is a need to look past NIMS ICS.  Perhaps we are stepping back to my comment on item 1 again, but if you understand the system, you can make it work for you.

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It is absolutely not my intent to throw negativity on the author or the people who spearheaded the implementation of an EMS-specific ICS as cited in this article.  They clearly identified what they perceived to be a need and tried to address it.  I give them credit for that.  It should be seen, though, that they identified many of the same needs that ICS was developed to address in the first place.  They then created a system (which has many of the same qualities of ICS) that is focused on EMS needs during an incident.  The issue here is bigger than this article, and certainly more endemic.  Unfortunately, the article doesn’t really provide much detail on their ‘provider in command’ model, but what they describe can all be accomplished through NIMS ICS if properly utilized.  They even identify objectives of their model, which are really just pre-identified incident objectives.  They certainly don’t require a different model.  I think, however, what they largely accomplished was an audience-specific training program to show how elements of ICS can be implemented.  I just don’t think they needed to change the model, which is what the article seems to indicate.

Sadly, trying to make customized adaptations of ICS is nothing new.  For years, some elements of the fire service have dug in with certain models which are fire-ground centric.  Other disciplines have dome similar things.  It’s worth mentioning that FEMA had developed a number of discipline-specific ICS courses, such as ICS for Public Works or ICS for Healthcare.  While the intent of these courses is to provide context and examples which are discipline-specific (which is a good practice) rather than new models specific to these disciplines, I think that has inadvertently given some the impression that there are different systems for different disciplines.  ICS is ICS.

Once again, I put the blame on poor training curriculum.  When a system is developed and proven to work under a wide variety of circumstances and for a wide variety of users, yet users keep feeling a need to develop adaptations for themselves, this is not a failure of the system or even the users, it’s a failure of the training.

There are facets of public safety and emergency management that are generally not using ICS as well or as often as they should.  EMS is one of them.  As an active EMT for over a decade (including time as a chief officer), I can attest that (in general) ICS training for EMTs is abysmal.  The text books tend to skim over the pillars of ICS and focus on the operational functions of triage, treatment, and transport.  While these are important (for a mass casualty incident… not really for anything else), they fail not only in adequately TEACHING the fundamental principles of ICS (which can and should be used on a regular basis), but they fall well short of actually conveying how to IMPLEMENT ICS.  Further, much of the training provided includes a concept of ‘EMS Command’, which is opposed to what is in ICS doctrine.  We shouldn’t be encouraging separate commands and ICS structures at the tactical level of the same incident.

A few years ago I had started a crusade of sorts to get a better ICS curriculum developed.  There was a lot of support for this concept across the public safety and EM community, not only in the US but other nations as well.  Perhaps with the coming of the new year that effort needs to be reinvigorated?

© 2019 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

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The National Strategy for Countering Weapons of Mass Destruction Terrorism

Earlier this month, the White House released a short document titled The National Strategy for Countering Weapons of Mass Destruction Terrorism.  This is a document I’m not sure we needed, and certainly does not meet the expectations of a national strategy document.  While it does outline eight distinct ‘lines of effort’ (objectives), which identify the priorities of this overall strategy, it provides no new approaches and very little substance, even for a national strategy document.

Those Lines of Effort are:

  • Deny terrorists access to dangers materials, agents, and equipment
  • Detect and defeat terrorist WMD plots
  • Degrade terrorist WMD technical capabilities
  • Deter support for WMD terrorism
  • Globalize the counter-WMD fight
  • Strengthen America’s national defenses against WMD terrorism
  • Enhance state, local, tribal, and territorial preparedness against WMD terrorism
  • Avoid technological surprise

The lines of effort are solid and practical, but are activities which are already taking place and are generally proven best practices.  Though most of the descriptions for each of the lines of effort are a page or less, making the whole document read more like an executive summary.  Most strategic plans usually identify some key activities (strategies) associated with each objective, which in this document are uninspiring and buried in narrative.  As mentioned previous, there are also no new information or novel approaches in this document.  It seems like it was prepared by an intern who was directed to synthesize some background information for a meeting.  A well-developed strategy is something that can be referenced in future related activities, but this document is so unremarkable, it really doesn’t seem to matter much.  Had direction been given to the National Security Council or the Department of Homeland Security, I’m confident that their subject matter experts could have developed a document that is much more meaningful.  This document was a swing and a miss, providing us with nothing new or tangible in our efforts to counter WMD.

What are your thoughts?

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

No Standards for Armed Teachers in Colorado

No matter what side you fall on in the debate on arming teachers, I think most people can agree that if teachers are to be armed, there should be some standards.  Apparently, Colorado law makers don’t think so.

Whenever giving someone the ability to handle a deadly weapon, especially as part of or sanctioned by their employer, there should absolutely be some standards in place.  To name a few:

  • What kind of weapon is allowed?
  • Are there any conditions in which that weapon cannot be carried?
  • Can the weapon be secured on the premises?
  • What are the rules for use of the weapon?
  • Does the person have to register their possession of the weapon?
  • What initial and refresher training requirements are in place?
  • Who is responsible for maintaining training and other records?
  • Who carries the legal liability?
  • Are mental health checks required?
  • What procedures are in place for reporting an incident involving the weapon?
  • What procedures are in place if the person is accused of a violent offense outside of work?

As the article cites, and as most of my readers are likely familiar, law enforcement officers and military personnel participate in many hours of fire arms training.  Before a weapon is even put into their hands, they are schooled on the components of their weapon, rules for use of force, and firearms safety.  On the range, safety discipline is paramount.

It’s not to say there aren’t any standards being put in place by these school districts in Colorado.  Many of them may be addressing all of these questions and more.  Unfortunately, there is a lack of consistency, since, as special districts, they are empowered to self-govern in many aspects (this is similar in most, if not all states).  The lack of statewide standards leaves a lot of room for gaps and liability, and, regardless of altruistic intent, can potentially endanger not only students, but first responders as well.

From a public safety perspective, I encourage local law enforcement, fire service, EMS, and emergency management to coordinate with their school districts (they should be anyway) if they are allowing their teachers to be armed.  Don’t only encourage policy, procedure, and standards to be in place, but press hard for it and offer to be involved.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

Changing The Lexicon on Terrorism Preparedness, Response, and Recovery

A couple months ago I posted about NFPA 3000: Standard for Active Shooter/Hostile Event Response Program.  Soon after posting, I ended up purchasing a copy of the standard and, combined with other readings and discussions, am fully bought into not only this standard but a change in our lexicon for this type of incident.

NFPA3000

First off, in regard to NFPA 3000, it’s not rocket science.  There is nothing in this standard that is earth shattering or itself wholly changing to what we do or how we do it.  But that’s not the intent of NFPA standards.  NFPA technical committees compile standards based upon best practices in the field. The standards they create are just that – standards.  They are a benchmark for reference as we apply the principles contained therein.  NFPA 3000 provides solid guidance that everyone in EM/HS should be paying attention to.

What NFPA 3000 has helped me realize is that our focus has been wrong for a while.  Terrorism isn’t necessarily the thing we need to be preparing for.  Why?

First, let’s look at what is generally referenced definition of terrorism in the United States.  This comes from Title 22 Chapter 38 US Code § 2656f.  It states that terrorism is “premeditated, politically motivated violence perpetrated against noncombatant targets by subnational groups or clandestine agents’.  Note that the definition focuses on motive more than action or consequence.  While motive is very important in prevention/intelligence and prosecution, it is far less important to most preparedness, response, and recovery activities.

The term ‘active shooter’ has been used quite a bit, yet it’s not a good description of what communities and responders can face when we consider that perpetrators could use means and methods instead of or in addition to firearms.  We’ve seen a wide variety of these instances that involve knives, vehicles, improvised explosives, and more.

This is why I prefer the term ‘active shooter/hostile event response’ or ASHER.  While the term has been around for a bit (a quick internet search shows references going back to at least 2013), NFPA 3000 has essentially canonized it in our lexicon.  The definition provided in NFPA 3000 is focused on the incident, rather than the motivation, and is comprehensive of any means or methods which could be used.  That definition is – Active Shooter/Hostile Event Response (ASHER): An incident where one or more individuals are or have been active engaged in harming, killing, or attempting to kill people in a populated area by means such as firearms, explosives, toxic substances, vehicles, edged weapons, fire, or a combination thereof.

When it comes to preparedness, response, and recovery ASHER is the focus we need to have.  Motivations generally make little difference in how we should respond.  We should always be looking for secondary devices or other attackers – these are not features unique to terrorist attacks.  As we do with any crime scene, we should always be mindful of evidence that can lead us to the motives and potential co-conspirators of an attacker.  That’s important for investigation, prosecution, and the prevention of further attacks.  Does the term ‘terrorism’ still have a place?  Of course it does.  In our legal system, that’s an important definition.  Philosophically, we can argue that all attacks are acts of terror, but because of the legal definition that exists of terrorism, we can’t – at least in the US.

I encourage everyone to start making the move to changing the lexicon to ASHER where appropriate.  It makes sense and gives us the proper perspective.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC ™

An Updated Comprehensive Preparedness Guide 201 (THIRA/SPR)

In late May, FEMA/DHS released an updated version of Comprehensive Preparedness Guide (CPG) 201.  For those not familiar, CPG 201 is designed to guide communities and organizations through the process of the Threat and Hazard Identification and Risk Assessment (THIRA).  This is the third edition of a document that was originally released in April 2012.  This third edition integrates the Stakeholder Preparedness Review (SPR) into the process.  Note that ‘SPR’ has commonly been an acronym for State Preparedness Report, which is also associated with the THIRA.  The goal of the Stakeholder Preparedness Review appears to be fundamentally similar to that of the State Preparedness Report which some of you may be familiar with.

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First of all, a few noted changes in the THIRA portion of CPG 201.  First, FEMA now recommends that communities complete the THIRA every three years instead of annually.  Given the complexity and depth of a properly executed THIRA, this makes much more sense and I fully applaud this change.  Over the past several years many jurisdictions have watered down the process because it was so time consuming, with many THIRAs completed being more of an update to the previous year’s than really being a new independent assessment.  While it’s always good to reflect on the progress relative to the previous year, it’s human nature to get stuck in the box created by your reference material, so I think the annual assessment also stagnated progress in many areas.

The other big change to the THIRA process is elimination of the fourth step (Apply Results).  Along with some other streamlining of activities within the THIRA process, the application of results has been extended into the SPR process.  The goal of the SPR is to assess the community’s capability levels based on the capability targets identified in the THIRA.  Despite the THIRA being changed to a three-year cycle, CPG 201 states that the SPR should be conducted annually.  Since capabilities are more prone to change (often through deliberate activities of communities) this absolutely makes sense. The SPR process centers on three main activities, all informed by the THIRA:

  1. Assess Capabilities
  2. Identify and Address Gaps
  3. Describe Impacts and Funding Sources

The assessment of capabilities is intended to be a legacy function, with the first assessment establishing a baseline, which is then continually reflected on in subsequent years.  The capability assessment contributes to needs identification for a community, which is then further analyzed for the impacts of that change in capability and the identification of funding sources to sustain or improve capabilities, as needed.

An aspect of this new document which I’m excited about is that the POETE analysis is finally firmly established in doctrine.  If you aren’t familiar with the POETE analysis, you can find a few articles I’ve written on it here.  POETE is reflected on several times in the SPR process.

So who should be doing this?   The document references all the usual suspects: state, local, tribal, territorial, and UASI jurisdictions.  I think it’s great that everyone is being encouraged to do this, but we also need to identify who must do it.  Traditionally, the state preparedness report was required of states, territories, and UASIs as the initial recipients of Homeland Security Grant Program (HSGP) sub-grants.  In 2018, recipients of Tribal Homeland Security Grant Program funds will be required to complete this as well.  While other jurisdictions seem to be encouraged to use the processes of CPG 201, they aren’t being empowered to do so.

Here lies my biggest criticism…  as stated earlier, the THIRA and SPR processes are quite in-depth and the guidance provided in CPG 201 is supported by an assessment tool designed by FEMA for these purposes.  The CPG 201 website unfortunately does not include the tool, nor does CPG 201 itself even make direct reference to it.  There are vague indirect references, seeming to indicate what kind of data can be used in certain steps, but never actually stating that a tool is available.  The tool, called the Universal Reporting Tool, provides structure to the great deal of information being collected and analyzed through these processes.  Refined over the past several years as the THIRA/SPR process has evolved, the Universal Reporting Tool is a great way to complete this.  As part of the State Preparedness Report, the completed tool was submitted to the FEMA regional office who would provide feedback and submit it to HQ to contribute to the National Preparedness Report.  But what of the jurisdictions who are not required to do this and wish to do this of their own accord?  It doesn’t seem to be discouraged, as jurisdictions can request a copy from FEMA-SPR@fema.dhs.gov, but it seems that as a best practice, as well as a companion to CPG 201, the tool should be directly available on the FEMA website.  That said, if the THIRA/SPR is being conducted by a jurisdiction not required to do so, the tool would then not be required – although it would help.

Overall, I’m very happy with this evolution of CPG 201.  It’s clear that FEMA is paying attention to feedback received on the process to streamline it as best they can, while maximizing the utility of the data derived from the analysis.  A completed THIRA/SPR is an excellent foundation for planning and grant funding requests, and can inform training needs assessments and exercise program management (it should be used as a direct reference to development of a Training and Exercise Plan).

For those interested, EPS’ personnel have experience conducting the THIRA/SPR process in past years for a variety of jurisdictions and would be happy to assist yours with this updated process.  Head to the link below for more information!

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC ™

A New NFPA Standard for Active Shooter/Hostile Event Response

The National Fire Protection Association (NFPA) has recently published a new standard for Active Shooter/Hostile Event Response (ASHER) programs.  NFPA 3000 is consistent with other standards we’ve seen published by the organization.  They don’t dictate means or methods, leaving those as local decisions and open for changes as we learn and evolve from incidents and exercises.  What they do provide, however, is a valuable roadmap to help ensure that communities address specific considerations within their programs.  It’s important to recognize that, similar to NFPA 1600: Standard on Disaster/Emergency Management and Business Continuity/Continuity of Operations Programs, you aren’t getting a pre-made plan, rather you are getting guidance on developing a comprehensive program.  With that, NFPA 3000 provides information on conducting a community risk assessment, developing a plan, coordinating with the whole community, managing resources and the incident, preparing facilities, training, and competencies for first responders.

NFPA standards are developed by outstanding technical committees with representation from a variety of disciplines and agencies across the nation.  In the development of their standards, they try to consider all perspectives as they create a foundation of best practices.  While the NFPA’s original focus was fire protection, they have evolved into a great resource for all of public safety.

I urge everyone to take a look at this new standard and examine how you can integrate this guidance into your program.  The standard is available to view for free from the NFPA website, but is otherwise only available by purchase.  Also available on their website is a fact sheet and information on training for the new standard.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Use of Pre-Developed Exercises – Proceed with Caution

I was recently asked by a client about my thoughts on pre-developed or ‘canned’ exercises.  As it turns out, I have a lot of feelings about them, most of them negative.  Pre-developed exercises, if properly understood and applied, can be a huge help, but the big problem is that we’re dealing with human nature, and some people are just damn lazy.  Garbage in, garbage out.

We need to keep in mind that exercises, fundamentally, are developed to validate plans.  Not my plans.  Your own plans.  While standards of practice mean that most plans have a high degree of commonality (i.e. a HazMat response plan for a jurisdiction in California will be largely the same as one for a jurisdiction in New York State), it’s often the deviations from the standards and the local applications that need to be tested most.  So it doesn’t do well for anyone to replicate an exercise that doesn’t test your own plans.  Similarly, the foundation of exercise design is objectives.  While the pre-developed exercise may have a theme that coincides with what you want to test, sheltering, for example, there are a lot of different aspects of sheltering.  The pre-developed exercise might not focus on what you need to exercise.  With all this, anyone who wants a quality exercise from something pre-developed is going to have to do a lot of re-development, which might be more frustrating than starting from scratch.

HSEEP1

If you want a quality exercise, you really can’t short cut the process.  Not only might HSEEP be required for whatever grant funding you are using for the exercise, but it’s a best practice – and for good reason.  So often people want to cut corners.  If you do, the final product will look like you’ve cut corners.  It might lack proper context, good reference documents, or meaningful evaluation.   The exercise planning meetings have defined purpose, and the documents help capture that process and communicate the intent to specific audiences.

On the other hand, there are proper ways to use materials from a previously developed exercise to benefit your own exercise.  The development of good questions in discussion-based exercises and injects for operations-based exercises can be a challenge.  Reviewing other exercises, especially when there might be some similarity or overlap in objectives, can be a huge help, so long as they are properly contextualized and relate back to objectives for your exercise.  This isn’t a copy and paste, though… as it all should still be applied within the exercise design process.

There are some exercises out there that might seem like exceptions to what I’ve written above.  The first that comes to mind are FEMA’s Virtual Table Top Exercises (VTTX).  The VTTX is a great program, conducted monthly, focusing on different themes and hazards.  FEMA’s Emergency Management Institute (EMI) assembles a package of materials that go to each community registered for the event, allowing a measure of local customization.  While jurisdictions may use this material differently, it is at least an opportunity to discuss relevant topics and hopefully capture some ideas for future implementation.

Similarly, my company, Emergency Preparedness Solutions, recently completed a contract with the Transportation Research Board for a project in which we developed a number of ‘generic’ exercises for airports.  These functional exercises, facilitated through a web-based tool, can be easily customized to meet the needs of most airports across the nation and are written with objectives focused on the fundamentals of EOC management within the timeline of an incident.  While specific plans aren’t directly referenced in the exercises, airport personnel are able to examine the structure of response in their EOC and can reflect on their own plans, policies, and procedures.  Similar to FEMA’s VTTX series, they aren’t a replacement for a custom-developed exercise, but they can help examine some fundamentals and start some important discussions.  I’m not able to get into much more detail on this project, as the final report has yet to be published, but look forward to future posts about it.

All in all, I tend to caution against using pre-developed exercises.  I simply think that most people don’t use them with the right intent and perspective, which can severely limit, or even skew, outcomes.  That said, there exists potential for pre-developed exercises to be properly applied, so proceed with caution and with your wits about you.  Understanding that time, money, and other resources can be scarce, emergency management has always done well with ‘borrowing best practices’.  While there is sometimes nothing wrong with that, short cutting the process will often short cut the benefits.  Do it right.  Use of a custom-developed exercise is going to maximize benefit to your community or organization.

© 2018 – Timothy Riecker, CEDP

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