Just yesterday, the Canadian province of Ontario released an update of its Incident Management System (IMS) document. I gave it a read and have some observations, which I’ve provided below. I will say that it is frustrating that there is no Canadian national model for incident management, rather the provinces determine their own. Having a number of friends and colleagues from across Canada, they have long espoused this frustration as well. That said, this document warrants an examination.
The document cites the Elliot Lake Inquiry from 2014 as a prompt for several of the changes in their system from the previous iteration of their IMS document. One statement from the Inquiry recommended changes to ‘put in place strategies that will increase the acceptance and actual use of the Incident Management System – including simplifying language’. Oddly enough, this document doesn’t seem to overtly identify any strategies to increase acceptance or use; in fact there is scant mention of preparedness activities to support the IMS or incident management as a whole. I think they missed the mark with this, but I will say the recommendation from the Inquiry absolutely falls in line with what we see in the US regarding acceptance and use.
The authors reinforce that ICS is part of their IMS (similar to ICS being a component of NIMS) and that their ICS model is compatible with ICS Canada and the US NIMS. I’ll note that there are some differences (many of which are identified below) that impact that compatibility, though don’t outright break it. They also indicate that this document isn’t complete and that they already identified future additions to the document including site-specific roles and responsibilities, EOC roles and responsibilities, and guidance on resource management. In regard to the roles and responsibilities, there is virtually no content in this document on organizations below the Section Chief level, other than general descriptions of priority activity. I’m not sure why they held off of including this information, especially since the ICS-specific info is reasonably universal.
I greatly appreciate some statements they make on the application of Unified Command, saying that it should only be used when single command cannot be established. They give some clarifying points within the document with some specific considerations, but make the statement that “Single command is generally the preferred form of incident management except in rare circumstances where unified command is more effective” and reinforce that regular assessment of Unified Command should be performed if implemented. It’s quite a refreshing perspective opposed to what we so often see in the US which practically espouses that Unified Command should be the go-to option. Unified Command is hard, folks. It adds a lot of complexity to incident management. While it can solve some problems, it can also create some.
There are several observations I have on ICS-related organizational matters:
- They use the term EOC Director. Those who have been reading my stuff for a while know that I’m really averse to this term as facilities have managers. They also suggest that the term EOC Command could be used (this might even be worse than EOC Director!).
- While they generally stick with the term Incident Commander, they do address a nuance where Incident Manager might be appropriate (they use ‘manager’ here but not for EOCs??). While I’m not sure that I’m sold on the title, they suggest that incidents such as a public health emergency that is wide-reaching and with no fixed site is actually managed and not commanded. So in this example, the person in charge from the Health Department would be the Incident Manager. It’s an interesting nuance that I think warrants more discussion.
- The document refers several times to the IC developing strategies and tactics. While they certain may have input to this, strategies and tactics are typically reserved for the Operations Section.
- There is an interesting mention in the document that no organization has tactical command authority over any other organization’s personnel or assets unless such authority is transferred. This is a really nuanced statement. When an organization responds to an incident and acknowledges that the IC is from another organization, the new organization’s resources are taking tactical direction from the IC. Perhaps this is the implied transfer of authority? This statement needs a lot of clarification.
- Their system formally creates the position of Scribe to support the Incident Commander, while the EOC Director may have a Scribe as well as an Executive Assistant. All in all, I’m OK with this. Especially in an EOC, it’s a reflection of reality – especially the Executive Assistant – which is not granted the authority of a Deputy, but is more than a Scribe. I often see this position filled by a Chief of Staff.
- The EOC Command Staff (? – they don’t make a distinction for what this group is called in an EOC) includes a Legal Advisor. This is another realistic inclusion.
- They provide an option for an EOC to be managed under Unified Command. While the concept is maybe OK, ‘command’ is the wrong term to use here.
- The title of Emergency Information Officer is used, which I don’t have any particular issue with. What’s notable here is that while the EIO is a member of the Command Staff (usually), the document suggests that if the EIO is to have any staff, particularly for a Joint Information Center, that they are moved to the General Staff and placed in charge of a new section named the Public Information Management Section. (a frustration here that they are calling the position the EIO, but the section is named Public Information). Regardless of what it’s called or if there is or is not a JIC, I don’t see a reason to move this function to the General Staff.
- Aside from the notes above, they offer three organizational models for EOCs, similar to those identified in NIMS
- More than once, the document tasks the Operations Section only with managing current operations with no mention of their key role in the planning process to develop tactics for the next operational period.
- They suggest other functions being included in the organization, such as Social Services, COOP, Intelligence, Investigations, and Scientific/Technical. It’s an interesting call out whereas they don’t specify how these functions would be included. I note this because they refer to Operations, Planning, Logistics, and Finance/Admin as functions (which is fine) but then also calling these activities ‘functions’ leads me to think they intend for new sections to be created for these. Yes, NIMS has evolved to make allowances for some flexibility in the organization of Intel and Investigations, something like Social Services (for victims) is clearly a function of Operations. While I appreciate their mention of COOP, COOP is generally a very department-centric function. While a continuity plan could certainly be activated while the broader impacts of the incident are being managed, COOP is really a separate line of effort, which should certainly be coordinated with the incident management structure, but I’m not sure it should be part of it – though I’m open to discussion on this one.
- I GREATLY appreciate their suggestion of EOC personnel being involved in planning meetings of incident responders (ICP). This is a practice that can pay significant dividends. What’s interesting is that this is a measure of detail the document goes into, yet is very vague or lacking detail in other areas.
The document has some considerable content using some different terminology in regard to incidents and incident complexity. First off, they introduce a classification of incidents, using the following terminology:
- Local, Provincial, and National Emergencies
Among these, Major incidents and Local/Provincial/National Emergencies can be classified as ‘Complex Incidents’. What’s a complex incident? They define that as an incident that involves many factors which cannot be easily analyzed or understood; they may be prolonged, large scale, and/or involve multiple jurisdictions. While I understand that perhaps they wanted to simplify the language associated with Incident Types, but even with the very brief descriptions the document provided on each classification, these are very vague. Then laying the term of ‘complex incident’ over the top of this, it’s considerably confusing.
**Edit – I realized that the differentiator between small incident and large incident is the number of responding organizations. They define a small incident as a single organization response, and a large incident as a multi agency response. So the ‘typical’ two car motor vehicle accident that occurs in communities everywhere, requiring fire, EMS, law enforcement, and tow is a LARGE INCIDENT????? Stop!
Another note on complex incidents… the document states that complex incidents involving multiple response organizations, common objectives will usually be high level, such as ‘save lives’ or ‘preserve property’, with each response organization developing their own objectives, strategies, and tactics. I can’t buy into this. Life safety and property preservation are priorities, not objectives. And allowing individual organizations to develop their own objectives, strategies, and tactics pretty much breaks the incident management organization and any unity of effort that could possibly exist. You are either part of the response organization or you are not.
Speaking of objectives, the document provides a list of ‘common response objectives’ such as ‘save lives’ and ‘treat the sick and injured’. These are not good objectives by any measure (in fact they can’t be measured) and should not be included in the document as they only serve as very poor examples.
So in the end there was a lot in this document that is consistent with incident management practices, along with some good additions, some things that warrant further consideration, and some things which I strongly recommend against. There are certainly some things in here that I’d like to see recognized as best practices and adopted into NIMS. I recognize the bias I have coming from the NIMS world, and I tried to be fair in my assessment of Ontario’s model, examining it for what it is and on its own merit. Of course anyone who has been reading my posts for a while knows that I’m just as critical of NIMS and related documents out of the US, so please understand that my (hopefully) constructive comments are not intended to create an international incident. I’m a big fan of hockey and poutine – please don’t take those away from me!
I’m always interested in the perspectives of others. And certainly if you were part of the group that developed this document, I’d love to hear about some of your discussions and how you reached certain conclusions, as well as what you envision for the continued evolution for the Provincial IMS.
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