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.

~

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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Updated IS-100 Course: Missing the Target

Earlier this week, FEMA’s Emergency Management Institute (EMI) released course materials, including student manual, handouts, instructor guide, and visuals, for the updated IS-100/ICS-100: An Introduction to the Incident Command System.  Note that this update (IS-100.c) has been available online since the summer.  The release of materials, however, included no errata, so absent comparing the previous version to this, I can’t speak specifically to what the changes include, though I’m aware from their release of the online course several months ago that there were adjustments to account for some of the revised content of the third edition of the NIMS doctrine, released in October of last year.

Those familiar with my running commentary for the past few years of ‘ICS Training Sucks’ are aware that much of my wrath was focused on the ICS-300 and ICS-400 courses.  That said, with the release of the third edition of NIMS (my review of the document can be found here), there were some needed additions to incident management fundamentals and my realization that the ICS-100 and ICS-200 courses are ignoring a significant population of professionals in their content.  While ICS itself was largely built for field personnel working within a command (vice coordination) structure, over the years, the prevalence of various forms and types of emergency operations centers (EOCs) has grown significantly.  One of the biggest additions in the most recent version of the NIMS document was, in fact, the inclusion of much more meaningful content on EOCs and their potential organizational models.  While still a minority compared to first responders, there is a significant audience of people taking ICS-100 because of their assignment to a local, county, state, or organizational EOC.  Yet, the ICS-100 materials have scantly more than ONE SLIDE talking about EOCs.

Yes, we do have courses such as the ICS/EOC Interface course and others that dive deeper into EOC operations and how they coordinate with each other and with command structures, but the introduction to all of this is often the ICS-100 course, which all but ignores EOCs and the audiences who primarily serve in them.  In fact, there are many jurisdictions that require EOC personnel to have ICS training (smartly), which starts with the ICS-100 course (why?  Because it’s the best/only thing generally available to them), but I’m sure many people taking the course are a bit confused, as it doesn’t speak at all to their role.  While I feel that ICS training for EOC personnel is important, an introductory course like this should include a bit more on EOCs.

As with my original writing on ICS Training Sucks, I bring this back to the fundamentals of instructional design, which is focused on the AUDIENCE and what THEY NEED TO LEARN.  It’s evident that these fundamentals are being ignored in favor of a quick update, which might change some content but does not improve quality.  Let’s actually look at who are audience groups are and either incorporate them all into the course, or develop another course and curriculum to meet their specific needs (aka EOC-100).  Otherwise, they are simply ignoring the fact that what is currently available is like fitting a square peg into a round hole.  Sure it fills a lot of space, but there are also some significant gaps.

While a number of jurisdictions have identified this need and developed their own EOC training, there are a lot of standards and fundamentals that could be addressed by FEMA in a national curriculum.  This is certainly a missed opportunity, and one that makes many of our responses less than what they should be.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Updated NIMS and ICS Courses

Be sure to head over to https://training.fema.gov/is/ to check out the updated IS-100.c (Introduction to the Incident Command System) and IS-700.b (Introduction to the National Incident Management System).  These courses have been updated to reflect the ‘refreshed’ NIMS doctrine, which includes some information on EOC structures, among other things.  For my review of the NIMS refresh, check out this article.

©2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC ™

NIMS Implementation Objectives and A Shot of Reality

Happy 2018 to all my readers!  Thanks for your patience while I took an extended holiday break.  A minor surgery and the flu had sidelined me for a bit, but I’m happy to be back.

This morning, FEMA issued NIMS Alert 01-18: National Engagement for Draft NIMS Implementation Objectives.  NIMS Implementation Objectives were last released in 2009, covering a period of FY 2009-FY2017.  With the release of the updated NIMS last year, FEMA is updating the implementation objectives and has established a national engagement period for their review.

So first, a bit of commentary on this document…

The new objectives are broken out by major content area of the updated NIMS document, including: Resource Management, Command and Coordination, and Communication and Information Management; as well as a General category to cover issues more related to management and administration of the NIMS program.  What we also see with these updated objectives are implementation indicators, which are intended to help ground each objective.  Overall, the number of objectives in this update has been cut in half from the 2009 version (28 objectives vs 14 objectives).

All in all, these objectives appear to be consistent with the current state of NIMS implementation across the nation.  They are certainly suitable for most matters in regard to the oversight of implementing NIMS and it’s various components.  The biggest sticking point for me is that this document is intended for use by states, tribal governments, and territories.  If the goal is to have a cohesive national approach to implementation, I’d like to know what the implementation objectives are for FEMA/DHS and how they compliment those included in this document.

Objectives 8 through 11 are really the crux of this document.  They are intended to examine the application of NIMS in an incident.  These objectives and their corresponding indicators (which are largely shared among these objectives) are the measure by which success will ultimately be determined.  While it’s a good start for these to exist, jurisdictions must be more open to criticism in their implementations of NIMS and ICS.  In addition, there should be an improved mechanism for assessing the application of NIMS and ICS.  While formal evaluations occur for exercises under the HSEEP model, we tend to see inconsistent application of the feedback and improvement activities to correct deficiencies.  Proper evaluations of incidents, especially at the local level, are often not performed or performed well. For those that are, the same issue of feedback and improvement often stands.

Extending this discussion into reality…

The reality is that many responders are still getting it wrong.  Last year my company conducted and evaluated dozens of exercises.  Rarely did we see consistently good performance as far as NIMS and ICS are concerned.  There are several links in this chain that have to hold firm.  Here’s how I view it:

First, the right people need to be identified for key roles.  Not everyone is suited for a job in public safety or emergency management in the broadest sense.  Organizations need to not set up individuals and their own organization for failure by putting the wrong person in a job.  If a certain job is expected to have an emergency response role, there must be certain additional qualifications and expectations that are met.  Further, if someone is expected to take on a leadership role in an ICS modeled organization during an incident, there are additional expectations.

Next, quality training is needed.  I wrote a couple years ago about how ICS Training Sucks.  It still does.  Nothing has changed.  We can’t expect people to perform if they have been poorly trained.  That training extends from the classroom into implementation, so we can’t expect someone to perform to standards immediately following a training course.  There is simply too much going on during a disaster for a newbie to process.  People need to be mentored.  Yes, there is a formal system for Qualification and Certification in ICS, but this is for proper incident management teams, something most local jurisdictions aren’t able to put together.

Related to this last point, I think we need a new brand of exercise.  One that more instructional where trainees are mentored and provided immediate and relevant feedback instead of having to wait for an AAR which likely won’t provide them with feedback at the individual level anyway.  The exercise methodology we usually see applied calls for players to do their thing: right, wrong, or otherwise; then read about it weeks later in an AAR.  There isn’t much learning that takes place.  In fact, when players are allowed to do something incorrectly and aren’t corrected on the spot, this is a form of negative reinforcement – not just for that individual, but also for others; especially with how interrelated the roles and responsibilities within an ICS organization are.

While I’m all for allowing performers to discover their own mistakes and I certainly recognize that there exist multiple ways to skin the proverbial cat (no animals were harmed in the writing of this blog), this is really done best at a higher taxonomy level.  Many people I see implementing portions of ICS simply aren’t there yet.  They don’t have the experience to help them recognize when something is wrong.

As I’ve said before, this isn’t a school yard game of kickball.  Lives are at stake.  We can do better.  We MUST do better.

As always, thoughts are certainly appreciated.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC SM

 

 

2017 National Preparedness Report – A Review

With my travel schedule, I missed the (late) release of the 2017 National Preparedness Report (NPR) in mid-October.  Foundationally, the findings of the 2017 report show little change from the 2016 report.  If you are interested in comparing, you can find my review of the 2016 NPR here.

The 2017 NPR, on the positive side, provided more data and more meaningful data than its predecessor.  It appeared to me there was more time and effort spent in analysis of this data.  If you aren’t familiar with the premise of the NPR, the report is a compilation of data obtained from State Preparedness Reports (SPRs) submitted by states, territories, and UASI-funded regions; so the NPR, fundamentally, should be a reflection of what was submitted by these jurisdictions and regions – for the better or worse of it.  The SPR asks jurisdictions to provide an honest analysis of each of the core capabilities through the POETE capability elements (Planning, Organizing, Equipping, Training, and Exercising).

From the perspective of the jurisdictions, no one wants to look bad.  Not to say that any jurisdiction has lied, but certainly agendas can sway subjective assessments.  Jurisdictions want to show that grant money is being spent effectively (with the hopes of obtaining more), but not with such terrific results that anyone would think they don’t need more.  Over the past few years the SPRs, I believe, have started to normalize and better reflect reality.  I think the authors of the NPR have also come to look at the data they receive a little more carefully and word the NPR to reflect this reality.

The 2017 NPR (which evaluates 2016 data from jurisdictions) identified five core capabilities the nation needs to sustain.  These are:

  • Environmental Response/Health and Safety
  • Intelligence and Information Sharing
  • Operational Communications
  • Operational Coordination
  • Planning

I’m reasonably comfortable with the first two, although they both deal with hazards and details that change regularly, so keeping on top of them is critical.  Its interesting that Operational Communication is rated so high, yet is so commonly seen as a top area for improvement on after-action reports of exercises, events, and incidents.  To me, the evidence doesn’t support the conclusion in regard to this core capability.  Operational Coordination and Planning both give me some significant concern.

First, in regard to Operational Coordination, I continue to have a great deal of concern in the ability of responders (in the broadest definitions) to effectively implement the Incident Command System (ICS).  While the implementation of ICS doesn’t comprise all of this core capability, it certainly is a great deal of it.  I think there is more room for improvement than the NPR would indicate.  For example, in a recent exercise I supported, the local emergency manager determined there would be a unified command with him holding ‘overall command’.  Unfortunately, these false interpretations of ICS are endemic.

I believe the Planning core capability is in a similar state inadequacy.  Preparedness lies, fundamentally, on proper planning and the assessments that support it. While I’ve pontificated at length about the inadequacy of ICS training, I’ve seen far too many plans with gaps that you could drive a truck through.  I’ve recently exercised a college emergency response plan that provided no details or guidance on critical tasks, such as evacuation of a dormitory and support of the evacuated students.  The plan did a great job of identifying who should be in the EOC, but gave no information on what they should be doing or how they should do it.  The lack of plans that can be operationalized and implemented is staggering.

The NPR identified the top core capabilities to be improved.  There are no surprises in this list:

  • Cybersecurity
  • Economic Recovery
  • Housing
  • Infrastructure Systems
  • Natural and Cultural Resources
  • Supply Chain Integrity and Security

Fortunately, I’m seeing some (but not all) of these core capabilities getting some needed attention, but clearly not enough.  These don’t have simple solutions, so they will take some time.

Page 10 of the NPR provides a graph showing the distribution of FEMA preparedness (non-disaster) grants by core capability for fiscal year 2015.  Planning (approx. $350m) and Operational Coordination (approx. $280m) lead the pack by far.  I’m curious as to what specific activities these dollars are actually being spent on, because my experience shows that it’s not working as well as is being reported.  Certainly there has been some positive direction, but I’m guessing that dollars are being spent on activities that either have negligible impact or actually have a negative impact, such as funding the development of some of the bad plans we’re seeing out there.

I’m curious as to what readers are seeing out in real life.  What capabilities concern you the most?  What capabilities do you see successes in?  Overall, I think everyone agrees that we can do better.  We can also get better and more meaningful reports.  This NPR was a step in the right direction from last year’s, but we need to continue forward progress.

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Incident Management & Proper Demobilization Planning

A fair amount of courses, especially those oriented toward the Incident Command System (ICS), mention demobilization, but that mention is usually fairly gratuitous.  Even the core ICS courses generally only offer a couple of paragraphs or a handful of bullet points.  The ICS 300, since it does focus more on incident planning, does contain some good additional material, but it’s still quite brief.  Demobilization is a best practice of incident management, along with staging areas, that are rarely done properly.  It’s not a surprise, though… there isn’t a lot of emphasis on them in ICS and related training, and generally what is out there is pretty poor quality.  This has been further emphasized through nine separate functional exercises I’ve conducted over the past couple of months where it was easily identified that most participants weren’t really familiar with what demobilization meant to them and their organizations. This is no slight on them… it comes down to training.

There is certainly room for improvement when it comes to the ICS National Training Curriculum.  In case you aren’t familiar, I’ve written pretty extensively on it in the past.  And yes, I still believe that ICS Training Sucks (click here to check out a few articles I’ve written on the topic).  In regard to demobilization, much of what is out there (including the ICS curriculum and otherwise), in addition to the couple of paragraphs or handful of bullet points, also puts a lot of emphasis on the Demobilization Check-Out (ICS form 221).  By all means, STOP THAT.  Throwing another form in front of people without proper context simply serves to confuse them further.  I’m not saying we need to train everyone to be a Demobilization Unit Leader (there is a specific course for that… and it’s less than great), but shoving another form in front of someone for seven seconds doesn’t do a damn bit of good… and in fact it probably does some measure of harm – especially for building the case made by some that ICS is nothing but a bunch of bureaucracy.  We need to actually show purpose.

Largely, those bits of prose contained in courses do a decent job in explaining why we need to demobilize.  Simply put, we don’t want people and other resources standing around for hours before they are told they can go home.  Along with this is usually the book answer of when we begin to plan for demobilization – that’s as soon as we order the resource.  In reality, I’ll give that a ‘kind of’ instead of a resounding agreement.  Most of the time, no, we’re not considering that, especially at the onset of an incident.  But we do need to start considering it early on, especially when we no longer need a lot of resources at the end of the first phase of an incident.  Further down the road, we also tend to have a lot of expensive resources and teams that need to be disengaged and dismantled from our incident organization and the operating area rather carefully before they can be sent home.  These deliberate actions are another good reason for proper demobilization planning.

Demobilization planning?  Yes, planning.  NOT the ICS 221.  That form is nothing more than an accountability sheet.  It is NOT a plan.  First off, demobilization planning is a team effort.  There needs to be involvement and input across much of the command and general staff of your incident management structure (be it a formal incident management team or otherwise).  It’s a planning effort, so it should be centered within your Planning Section.  For a larger incident, certainly designate a Demobilization Unit to do coordinate this.

How do we even make this happen?  First, the concept needs to be sold to command.  They will initially say no.  Expect it.  Many Incident Commanders not well practiced in formal demobilization think that even discussion of the term must be reserved for late in the game.  It might take a couple of attempts and a need to make your case.  Demob doesn’t signal an end to the entire operation, and in fact additional resources may be flowing into the incident as others are being demobilized.  Once command is sold on it, then it needs to be discussed with the entire command and general staff.  Everyone has input.  Most of the resources belong to ops, so they should be able to identify when certain resources will complete their operations and will no longer be needed.  The logistics organization may have a fair amount of resources in place largely to support operations, therefore, as certain operations are demobilized, logistics may also be able to demobilize some of their resources.  They may also want certain things returned and accounted for, such as radios.  And if any hazardous material was present, the Medical Unit within logistics may be arranging long-term medical monitoring, which needs to become part of demobilization.  The Liaison Officer may be getting pressured by outside agencies or organizations to release resources and/or may have to explain to certain assisting agencies why their resources are no longer needed.  Finance/Administration is aware of how much certain resources are costing the responsible party, both in direct costs as well as maintenance costs.  There may be others with input as well.

As this discussion occurs, Planning/Demobilization should be keeping good notes as these comments, concerns, and priorities may become part of the demobilization plan.  The plan itself consists of five standard sections:

  1. General information – what does this plan pertain to and generally, what’s it about (it’s an overview).
  2. Responsibilities – This identifies, within the ICS structure, who is responsible for what in regard to demobilization
  3. Release Priorities – These are the agreed upon priorities identified by command and general staff.
  4. Release Procedures – This should have the most detail, starting with identification, authorization, and notification of the resource of their impending demobilization status. How far ahead of the demobilization are they advised?  Who do they have to talk to along the way?  What equipment should be returned?  Do they need to submit any reports or paperwork?  Who do they actually sign out with?  How and when do they return home?  Based on the nature of the incident, consider a mandatory overnight before they can travel, medical monitoring, and a debrief.  And always require resources to confirm that they have arrived safely back to their home station.  This, by the way, is where you reference the ICS 221 form, which will maintain accountability of the demobilization process.  Certainly customize this form to match your procedures.
  5. Reference Information – This can include travel information, contact information for key personnel (such as the Demobilization Unit Leader), maps, schedules, reminders, and other info.

Like the majority of implementations of ICS, demobilization planning is generally accomplished in the head of the IC and perhaps other staff.  That’s likely fine for more routine type 5 incidents, and even some type 4 incidents.  There may be some type 4 incidents that have enough complexity and disparity of resources, that a written plan is a good idea.  Certainly anything more complex should have a written plan.  Just as we should be writing incident action plans for planned events, demobilization plans should also be used.  If anything, it makes for good practice.  For the same argument, it’s also great for exercises (not only for the players, but also for exercise management).

Looking for a demobilization plan template?  Here’s one.  I’m not familiar with the authors, but it’s a fairly standard template for such a plan.  I’m generally wary of templates, but this is pretty basic.  If you might find yourself in the position of organizing incident demobilization for your agency or jurisdiction, save it and start modifying it now.  There are likely a set of standard priorities and procedures which you can identify now that you can include in the plan.  Be sure to have an ICS 221 that you can modify for implementation as well.  Just be sure to not ‘finalize’ either one of these… just like an IAP, they are documents developed specifically for an incident, event, or exercise.

So there you have it, a bit of demobilization planning advice from someone who is trained and experienced in actually doing it.  I hope this was helpful.  Of course I’m happy to provide some direct advice as well as happy to hear from others who are experienced themselves in demobilization.  What best practices have you identified?

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

 

ICS and the Human Factor

A number of my articles have mentioned the unpredictable human factor in executing emergency plans and managing incidents, particularly for complex incidents.  We can build great plans and have a great management system to facilitate the incident management process, but the human factor – that largely intangible level of unpredictability of human behavior – can steer even the best emergency plan astray or derail an incident management process.

An article published in the Domestic Preparedness Journal yesterday, written by Eric McNulty, reflects on this.  Mr. McNulty cites several human factors which have relevance within incident management and encourages leaders to understand these factors within themselves and others to bring about more effective leadership.  The introductory paragraph of his article suggests the need for integrating behavior training into ICS training to ‘improve performance and outcomes’.  Given the impact of behavior factors on how we respond, this is a concept I can certainly endorse for a much-needed rewrite of the ICS curriculum.

I’ve heavily referenced Chief Cynthia Renaud’s paper, The Missing Piece of NIMS: Teaching Incident Commanders How to Function in The Edge of Chaos, in the past and continue to hold her piece relevant, especially in this discussion.  Chief Renaud’s suggestions draw lines parallel to behavioral factors, which suggest to me that we certainly need to integrate leadership training into ICS training.  The current ICS 200 course attempts to do so, but the content simply panders to the topic and doesn’t address it seriously enough.  We need to go beyond the leadership basics and explore leadership training done around the world to see what is the most effective.

Incident management is life and death – not a pick-up game of stick ball.  Let’s start taking it more seriously and prepare people better for this responsibility.

© 2016 – Timothy Riecker, CEDP

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