The alarms are relentless, the lights are flashing, and you’re offsite. Will your people respond appropriately to the threat or place themselves in harm’s way?
Yes, smart emergency response plans are critical. Yet if you don’t get the words off the paper and into people’s heads, you have failed. Training is essential.
Your mandatory emergency action plan (EAP) and fire prevention plan (FPP) contain procedures that outline precise decision-making and actions. Without proper training, personnel empowered to execute your plans will squander time, duplicate some actions and completely omit others. Your people become needlessly vulnerable and your organization risks greater loss. In the aftermath, productivity will plummet and your senior management could face lawsuits, fines and even prosecution.
Also, every applicable national standard mandates employee training on EAPs, disaster recovery and business continuity plans, including NFPA 1600, ASIS.BSI BCM.01 and BS 25999.
What 'Training' Means
OSHA regulations create two classes of employees for emergency response: employees organized into an emergency team, and all other personnel who are to be supervised during emergencies. Many employers are surprised that OSHA requires every employer to assign employees into an emergency team. “I can’t even train them to stop piggybacking at exterior doors,” they may say. “Now you want them to be emergency responders!”
Consider this: Police and fire officers are not the first responders; they are the official responders. You and your employees are the first responders. Since you can’t repeal the laws of physics, you shall create an emergency team.
Span Of Control
NFPA and the federal government recommend a 1:5 ratio for emergency team members to total occupants. “Occupants” includes employees, contractors (cafeteria, security officers, IT, mail room, cleaning crew, etc.), visitors — any occupants.
This can feel like an onerous mandate proclaimed by some bureaucrat, but is isn’t. The 1:5 ratio was recorded 2,500 years ago when Alexander the Great deployed tens of thousands of soldiers, with horses and equipment, thousands of miles across the then-known world in an organized fashion. Alexander's men were undefeated over this ten-year compaign.
In the business world, experts—starting with Ian Hamilton in the early 20th Century—have recognized the range of 1:3 to 1:7 as the correct ratio of supervisors to those supervised, or “span of control.” NFPA 1600, NIMS, ICS and NRDF are explicit about the range of 1:3 to 1:7, concluding that 1:5 is best.
Span of control is dictated by many factors in your organization:
- How often senior managers are out of the office
- How mobile employees are, both intra- and inter-facility
- How many hours per week your facility is occupied
- Number of shifts worked
- How often your emergency response team is trained and exercised
- How often your employees are supervised, trained and exercised
- Whether your organization’s culture makes emergency planning and response a priority
Most organizations’ emergency teams are too small. If one or two key members are out when an emergency strikes, your organization’s response is compromised.
'Train Everyone, Including The Band'
In 1991, the Oceanos cruise ship, carrying 571 passengers and crew, sank in the Indian Ocean off South Africa. To this day, no one knows why.
What we do know is that the first people to abandon ship in lifeboats were the captain, his senior officers and most of the crew. At his trial for negligence, the captain said, “When I give the order to abandon ship, it doesn't matter what time I leave. ‘Abandon’ is for everybody. If some people want to stay, they can stay."
It took seven hours for everyone else—including some with special needs—to get off the ship. The remaining lifeboats and 16 helicopters ferried all remaining passengers and crew to safety, without major injury.
So who was in command? The tour director. Her emergency team? The band that had been playing for passengers.
When an emergency strikes your facility, it’s probable that many emergency team members will be absent. That’s why you train more people than you think you need to, so you ensure competent response.
Hands-On, Site Specific Training
OSHA says on-screen training can supplement, but never substitute for, classroom training. OSHA’s battle cry for years has been “hands-on” training in a classroom by a “qualified” trainer because EAP and FPP training requires articulated skills for employees — especially for emergency team members.
All planning and training must be “site specific.” This rules out the exclusive use of stand-alone, off-the-shelf, third-party or headquarters’ programs and videos that your facility might post on its intranet or play in a conference room. These tools may supplement, but cannot substitute for, the annual classroom training tooled to your unique site by a qualified trainer.
“Qualified” is defined by OSHA as one competent from experience and/or training in emergency action and fire prevention. That eliminates HR personnel who orient new hires on policy and benefits.
What To Train
Mandated by all those aforementioned national standards, especially NFPA 1600, the all-hazards protocol requires your organization to plan and train for everything. In addition, your planning and training must enumerate these policies and procedures:
- Visitor management
- Emergency notification system
- Medical standard of care
- First aid plan
- Bloodbourne pathogens plan
- Chain of command
- Emergency team jobs
- Span of control
- Assembly areas
- Garage/parking lots
- Crisis communications
- When to invoke DR & BC plans
The Miracle On The Hudson
On January 15, 2009, US Airways Flight 1549 took off from New York’s LaGuardia Airport with 150 passengers. Within minutes of takeoff, the plane lost both engines to a double bird strike, and Capt. Chesley B. Sullenberger III had to ditch in the Hudson River. This type of incident usually results in severe injuries and fatalities. In this case, all 155 passengers and crew went home to their families that night. The worst injury was a broken arm.
How is this possible? Here was a terrifying emergency that struck a bunch of strangers, who then had to coordinate their response within moments.
To get the answer, I turned to the National Transportation Safety Board (NTSB), which investigates nearly every plane crash worldwide and produces encyclopedic reports on causes and effects. NTSB pointed to two examples.
Both crashes involved Boeing 737s. Both crashed and burned at airports. In both cases, passengers had precisely two minutes to escape before the fuselage exploded. In one crash, all 150 passengers escaped. Not even a broken arm. In the other crash, 55 of 137 people onboard died.
Why? In the crash with no fatalities, nearly every passenger was a frequent business flier—like those on US Airways Flight 1549—who had heard the safety message so often they could recite it. When the emergency struck, they knew what to do.
In the other airport crash, every passenger onboard was a first-time flier — families on a charter going on vacation. The NTSB reported that a majority of the 55 deceased still had their seat belts firmly buckled. They didn’t know how to respond.
The Gray Area Of When To Train New Hires
How soon you should train new hires or embedded contractors (for purposes of emergency response, OSHA says you’re the “host employer” and thus responsible for all contractors) is a gray area. There is no law, regulation or standard that says when a new hire should be trained. Many experts and OSHA compliance officers opine new hires should be trained when exposed to the possibility of an emergency. In other words, on day one.
Other experts recognize that all-hazards, classroom training by a qualified trainer can’t happen every day there is a new hire. Accordingly, some believe that a new hire can be trained within the first 90 days in order to gang other new hires and make training classes more efficient.
Special Needs Personnel May Not Be Obvious
Special needs personnel (SNP) require extra attention in training. Every state’s fire code, all the aforementioned national standards, and ADA regulations and guidelines require every employer to plan and train their personnel to address the management of SNPs during any emergency.
The federal government defines SNPs for emergency response purposes as those who are pregnant, mobility-challenged (on crutches, in wheelchairs, have a prosthetic limb), don’t speak English, are under 18 years of age, hard of hearing, or vision impaired. You should also consider those who have recently returned from surgery or injury.
SNPs can be your employees, contractors and visitors. Everyone is your responsibility.
Command, Control & Communications
In every study of emergency response, you’ll find command, control and communications (CCC) at the heart of success or failure. Training CCC to both the emergency team and all employees is essential for success.
First, you need a chain of command (CoC) that designates who is in command for any emergency. That CoC needs to be deep to accommodate the absence of top people.
Next, all employees need to know how the emergency team will work so commanders can simultaneously exercise control over all personnel throughout the facility and outside. CoC must extend to all parts of the site to cover employees, contractors, visitors—including SNPs—throughout the emergency.
Your CoC must recognize that building management and/or emergency services will only have a few personnel at your site, all of whom will be busy in chaotic circumstances when your emergency begins. Thus, even though building management and/or emergency service may be giving orders, your emergency team will have to implement those orders regarding the movement or sheltering in place of your personnel.
Since cell phones and push-to-alk will almost never work during an emergency, you need to arm your emergency team with two-way radios. Moreover, you should have an emergency notification system to communicate with all of your on- and off-site stakeholders. You need to regularly train on all CCC technology to ensure they work during any emergency.
The Secret Benefit Of Employee Training
I hear many excuses from management regarding the employee training:
- “Our people are too busy.”
- “Our folks have the attention span of bumble bees.”
- “They won’t stand for it.”
- “This will scare them to death.”
When a national sample of American employees was surveyed about their most important issue at work, 85 percent said it was safety (National Opinion Research Center, 2010). All other workplace issues garnered a response 50 percent or less, including wages/salary, leave and union issues.
I have trained over 12,000 employees in all kinds of workplaces across the country. I survey immediately after training, asking for candid feedback and assuring confidentiality. Of those 12,000 trainees—employees just like yours—98.5 percent report that they were thrilled to receive emergency training: “Why haven’t we done this before?”; “Can we do this more often than once a year?”; “I can use this at home.”
Your employees thirst for this training.
It's great to have EAPs and FPPs, yet training is everything. Here is a summary of the points to consider:
- As an employer, you are required by law and national standards to train all of your employees and contractors, including your emergency team, at plan creation, then annually thereafter and at hire.
- Training shall be "all-hazards," covering two dozen foreseeable threats. Your personnel shall be trained in how to manage the emergency response of visitors and SNPs.
- The span of control of your emergency team should be 1:5 regarding all occupants on your site.
- Command, control and communications are the key to success or failure in all emergencies.
- Federal law requires “hands-on” and “site specific” training of all personnel by a “qualified” trainer in a classroom where questions can be asked and answered.
And remember that when an emergency strikes, if you are not compliant in your training, your management can be held legally responsible: “There are precautions so imperative that even their universal disregard will not excuse omission.”
In real estate, the three most important things are location, location, location. In emergency response planning, the three most important things are training, training, and more training.
Bo Mitchell was Police Commissioner of Wilton, CT for 16 years. He retired to found 911 Consulting, which creates emergency and business continuity plans, training and exercises for organizations like GE Headquarters, Health Net, Cablevision and Goodrich. Bo has earned 16 certifications in organizational safety and security. He also serves as an expert in landmark court cases nationally.
Bo is a Certified Business Continuity Professional, a Certified Emergency Manager and Certified in Homeland Security.