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When Federal Guidelines Conflict With the Objectives of Emergency …

In 2008, during the aftermath of the Virginia Tech tragedy, the Emergency Notification requirements were added to the Clery Act alongside the longstanding timely warning requirement. The 2008 amendments also required all public and private institutions of postsecondary education participating in federal student aid programs to have emergency response and evacuation procedures in place. The 2008 linkage between mass notification, timely warning and the campus community response to immediate emergencies is based on the presumption that you can better protect lives by promptly notifying the appropriate audience of an emergency situation while instructing them on what actions should be taken.

Yet years later, the intention of mass notification and common concepts practices are in direct conflict with the active shooter federal emergency guidelines.

Since the inception of the Department of Homeland Security s (DHS) introduction of the Active Shooter Awareness Guidelines 1 in 2008 and FEMA s Active Shooter2 response program of 2011 , these concepts of Run-Hide-Fight have been adopted by many law enforcement agencies, government and educational institutions. These guidelines have also served to raise public awareness through various media platforms under the assumption that by focusing on self-preservation, the federal program provides a useful decision making tool to those individuals confronted with extreme life threatening situations. Interestingly, utilizing the same rational detailed above, in 2010 British police instructed members of parliament and their staff to flee for their life in the event of a Mumbai-style armed attack.

In the higher education environment, the pragmatic result of the Run-Hide-Fight system is a shift in decision making from the campus administration, law enforcement and first responders to each and every individual on campus.

Under these circumstances, emergency mass notification can no longer be used to effectively control and direct large groups of individuals. Hence, law enforcement and first responders can no longer predict group response or expect optimal conditions to allow for immediate threat neutralization. Moreover, in an unpredictable and rapidly evolving active shooter scenario, mass notification used to instruct the campus community can potentially contradict DHS guidelines and expose institutions to liability.

In a tragic way, due to the migration from a collective rational to private decision making, the utilization of mass notification over various platforms in an active shooter situation can now be expected to increase chaos and the appearance of random motion.

As a result, schools and law enforcement should no longer expect the campus community to act as a cohesive unit, but rather as a disorganized and unpredictable group. In light of the DHS active shooter guidelines and the Clery Act mass emergency notification language, the evolution of emergency mass notification should enhance the focus on providing informative content about the threat rather than instructional content. In addition, schools that chose to apply the Run-Hide-Fight system should also work closely with law enforcement and emergency responders and collaborate on mass notification messaging that allows for both sides to achieve their common goals.

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Oren Alter is an Associate Vice Chancellor of Crisis Management for a multi-campus University.

He has more than 20 years of international experience in Counter Terrorism, physical security and corporate security for both government and private entities.

Brandon Biederman is the Associate Vice Chancellor of Compliance for a multi-campus University.

He has more than 10 years of experience in the compliance arena.

Note: The views expressed by guest bloggers and contributors are those of the authors and do not necessarily represent the views of, and should not be attributed to, Campus Safety magazine.


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