THIS BLOG POST IS WRITTEN BY GUEST CONTRIBUTOR, Lucien Canton, a nationally recognized expert on strategic planning for crisis and disasters.

It’s a sad fact of life that most of our emergency plans are written not for the end user. Instead, they are written to please someone else’s idea of what a plan should be. That means the inclusion of specific language or the inclusion of concepts that may be meaningless to actual plan users. It is this commitment to compliance with the latest “guidance” that drives most plan updates. If you allow yourself to fall into this trap, you are literally wasting time and money on something that will produce little value to your organization.

What is the standard?

The two standards most used in our industry, NFPA 1600 Standard on Disaster/Emergency Management and Business Continuity/Continuity of Operations Programs and EMAP’s Emergency Management Standard do not specifically require plan updates. Instead, they focus on evaluation of the emergency management program. NFPA 1600 suggests evaluation through periodic exercises and tests and through post-incident analyses. It also identifies nine areas in which changes should trigger a reevaluation of your program. The EMAP Standard has a similar requirement but does not suggest specific triggers.

FEMA’s CPG 101 Developing and Maintaining Emergency Operations Plans goes a bit further than the standards. While there is no specified timeframe for review, it does set a two-year limit for revisions: “In no case should any part of the plan go for more than two years without being reviewed and revised.” CPG 101 also provides its own list of nine events that should trigger a plan review which are different from those in NFPA 1600.

There are two common threads running through the standards and the FEMA guidance. The first is the need to for a documented process for regularly reviewing and revising your emergency management program. Secondly, that process should be sensitive to changes in your operating environment that could have an impact on your plan.

The Reality

Unfortunately, many organizations update plans based on:

• Someone (elected official, senior executive, community group) just noticed the date on your plan is five years old and thinks it needs to be updated.
• You’re facing an inspection or audit.
• You just got grant funding to update plans.
• Someone (DHS, FEMA, your state) just put out new guidance and you want to comply
• You just took over and your plan looks like it could use some work.

The next step is then to hire a consultant to help with the update. You do one of two things:

1. Given limited funds, you focus on updating your base plan.
2. You tell the consultant to update the base plan and all the annexes but provide only limited funds.

Sound familiar? If so, you’ve wasted time and money on a product that will be useless to you in the long run. The reality is that much of the guidance you receive is just that: guidance. You don’t have to adopt it. Secondly, while there have been some new concepts added, the content of the base plan has been largely unchanged since the first guide was issued in 1990.

The only true measure of a plan is if it will actually work when it is needed. That means holding planning meetings with stakeholders to review the plan, update strategies, and agree on revisions. If you’re not willing to put in the work to make sure it’s done right, you’re just making cosmetic changes. Hire a technical writer or get an administrative assistance to do your update.

A Better Approach

Plans are not static. They are merely a snapshot of where your strategic think was at the time you wrote the plan. During a crisis, the plan is a toolbox, not a recipe book. You adapt and modify elements to meet the needs of the crisis. Accept that your work is not done just because you’ve published a new edition and focus instead on continuous improvement.

• Establish a review process. Your plan may not need frequent updates but it does need frequent review. Use the triggers in the standards as points of departure and consider them when doing after action reviews for actual incidents and exercises. Tie this in with your corrective action program.
• Involve your planning team in deciding what needs updating and when. Updating a single department plan may be more effective than revising your entire plan.
• Question the applicability of new guidance before adopting it and making major revisions to your plan.
• Stop making changes to your base plan. The real work is in your annexes and the supporting department plans. If you’ve got money to spend, spend it there.
• Remove information that doesn’t need to be in the plan. Things like phone numbers and position assignments belong in separate documents. Also think about all that “must include” gobble gook you find in most plans. NIMS has been around for almost 15 years; do you really need 10 pages on ICS in your base plan to convince the reader you’re using the system?
• Consider moving into the 21st Century by using online plans and apps that can be quickly updated. Most programs also allow you to print hard copies if necessary

Yes, plans need to be updated but this should be as the result of a regular review process not someone else’s idea. Revisions should be driven by changes to your operating environment that reduce your plan’s effectiveness.  

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