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Federal Coordination of All-Hazard Incident Management Teams

Tim Riecker, The Contrarian Emergency Manager 9 Comments

A few months ago the FEMA administration decided that the US Fire Administration (USFA) would discontinue their management of the All-Hazards Incident Management Team (AHIMT) program, which they have developed and managed for years. While I was never in favor of the USFA managing the program (AHIMTs are not fire-service specific), the staff assigned to the program did an admirable job of growing the AHIMT concept to what we have today.

The All-Hazards Incident Management Team Association (AHIMTA), which has been a vocal proponent of the development of AHIMTs, has thankfully been working to make people aware of this change. As part of their advocacy, they also wrote to FEMA Administrator Deanne Criswell regarding their concerns with the dissolution of this formal program. Administrator Criswell responded to AHIMTA, indicating that despite successes, the AHIMT program has “not been able to establish a sustainable or robust AHIMT program with long-term viability.” She did indicate that the USFA will continue providing related training to state, local, tribal, and territorial (SLTT) partners (though she specified that USFA training efforts will apply to fire and EMS agencies) and that she has directed the USFA to collaborate with the FEMA Field Operations Directorate to continue support to AHIMTs.

This change and some of the wording in the Administrator’s response is obviously very concerning for the future of AHIMTs. I first question the Administrator’s statement about the AHIMT program not being sustainable long-term. Not that I’m doubting her, but I’m curious as to what measures of sustainability she is referring. I’m guessing most of the issue is that of funding, along with this never having fully been part of the USFA’s mission. Everything really does boil down to funding, but how much funding can a small program office really need? I’m also concerned about the USFA continuing with the AHIMT training mission (as I always have been), and even more so with the Administrator’s specification of fire and EMS (only?) being supported. While I have no issue at all with the USFA, and think they have done a great job with IMT and related training, their primary focus on fire and EMS (even absent the Administrator’s statement) can be a barrier (real or perceived) to other disciplines obtaining or even being aware of the training.

I firmly believe that a federal-level program office to continue managing, promoting, and administering a national AHIMT program is necessary. I do not think it should be in the USFA, however, as it has been, as their mission is not comprehensive in nature. It’s a program that should be managed properly within FEMA, though not by the FEMA Field Operations Directorate, which is primarily charged with FEMA’s own field operations. While this does include FEMA’s own IMATs, their focus is internal and with a very different purpose. My biggest inclination is for the program to be placed within the NIMS Integration Center, which already does a great deal of work that intersects with AHIMTs. On the training side of things, I’d like to see AHIMT training moved to FEMA’s Emergency Management Institute (EMI), to emphasize the inclusion of SLTT participants regardless of discipline. Incident management, as a comprehensive response function, is inclusive of all hazards and all disciplines and practices, just like emergency management.

The dissolution of the AHIMT program at the federal level makes no sense to me at all. The absence of a program office not only degrades the importance of incident management teams, but of incident management as a concept and a skillset – which I think also needs some vision beyond the current IMT model to support local incident management capabilities. I’m appreciative of the AHIMTA and their advocacy for a federal AHIMT program office, and I’m hopeful that they will be able to convince FEMA of this need and that a program office is properly restored.

© 2022 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Incident Management is a Technical Skill

Tim Riecker, The Contrarian Emergency Manager 1 Comment

Last week I had the pleasure of speaking with Rob Burton on his Tea and Chaos webinar. We talked about the Incident Command System (ICS) and what can make it successful. Since our conversation, I’ve had some continued thoughts about ICS and the complaints people have about it. One of the complaints I hear more often is that it is the system that is flawed because it’s too challenging for people to use. They argue that it should be easier to implement with little training.

I believe I mentioned in the webinar that using ICS is not like riding a bike or tying a shoelace. It’s not something you can be trained on then expect to be able to perform years later (with no interim training and application) with little to no difficulty. ICS, a tool of incident management. Incident management is not only a perishable skill, but also a technical skill.

A technical skill is something you are trained on and hone with practice over time. Technical skills are typically industry specific and require a specialized knowledge set. It could be anything from video editing to surgery. In either of these examples, people learn the knowledge needed and acquire the skills to implement. They learn and perform every detail, becoming proficient in the practice, processes, and associated tools. If they want to stay current and relevant, they take opportunities for continuing education. They learn about new approaches and tools. They maintain proficiency through repetition and application of new knowledge.

Incident management is no different. ICS is just one of the tools we use in incident management, and as such it is something we must learn, practice, hone, and maintain. If you aren’t using it and learning more about it, those skillsets will diminish.

Let’s continue to change our perspective on preparedness for incident management. If you aren’t familiar with my years-long crusade to improve ICS training (ICS Training Sucks), here is some background reading. It’s not only the curriculum we need to change, but also our expectations of learners. What do we want learners to be able to do? Continuing on with one of the examples… not every doctor is a surgeon. So not every responder or emergency manager is an incident manager. They should know the fundamentals, just as most doctors are trained in the fundamentals such as anatomy and physiology, cell biology, etc. We certainly want our responders and emergency managers to have awareness of incident management concepts, as they may certainly be called upon to play a role in a greater organization, though if incident management isn’t their specialization, they likely won’t actually be part of the core ICS or emergency operations center (EOC) staff, even though they will be functioning within the system.

Some will need to learn more, though. Which means they need training – not just on WHAT incident management is, but HOW we manage incidents. Much of our core ICS training is focused on what ICS is, with very little on how to use it. Expecting people to become good incident managers just by taking ICS courses is foolish. It would be like expecting a doctor to become a proficient surgeon because they have learned about the tools in the operating room. So before we even get to the tool (ICS), we need to be teaching about the function (incident management). Incident management is composed of a variety of capabilities and skillsets, such as leadership and project management, which are barely touched upon in existing training. Once those are learned, then we can teach the tools, such as ICS.  

Most who are candidates for incident management should become generalists before they become specialists. General surgeons have a broad knowledge and perform the vast majority of surgeries. Some go on to be specialists. In incident management that specialization could be subject matter expertise in the management of certain hazards or impacts, or performing in a specific function. I see this as being the difference between local incident management capabilities and formal incident management teams. Specialization is supported by position-specific training, among other mechanisms. Yet we don’t really have anything to support incident management generalists.

For all that we’re accomplishing with building incident management capability, we still have a significant gap at the local level across the nation. To expect specialization within most local jurisdictions simply isn’t realistic. We define a lot of the practice through NIMS position descriptions and task books, yet we are skipping some critical steps. We are going right to focusing on the tool instead of the practice, yet at the foundational levels we aren’t teaching enough about how to implement the tool – and in fact spending far too much time on higher level implementations of the tools that most will never see (that’s the ICS 400 course, by the way). We are wasting time and resources by training people in position specific courses when what they really need for their jurisdiction is to become good incident management generalists.

Those complaining that ICS is too difficult, are failing to see the bigger picture the technical skills needed to build professions. Professionals must keep up on the rigors and requirements of their technical skills. If you don’t want to keep up on these things, then I’ll argue that you aren’t dedicated to the profession.

While I feel that what we are doing to build formal incident management teams is great and largely on target, it’s everything that comes before that which needs to be completely reimagined. We need a group of incident management professionals to come together on this. Professionals who understand the gaps that exist and are willing to deviate from current practices and expectations to build what is needed to address those gaps. They can’t be afraid of the traditionalists or those who are only focused on building high-level capability. All disasters begin and end locally, and we are ignoring the incident management needs of most local jurisdictions. We are also building a system focused on high-level capability that doesn’t have a firm foundation, which makes me question sustainability. We can do better. We must do better.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

NIMS Change – Information and Communications Technology Branch

Tim Riecker, The Contrarian Emergency Manager 4 Comments

FEMA recently released a draft for the National Incident Management System (NIMS) Information and Communications Technology (ICT) guidance, providing a framework for incorporating ICT into the Incident Command System (ICS). The draft guidance in many ways formalizes many of the functional changes ICS practitioners have been incorporating for quite a while.

Essentially, the guidance creates an ICT branch within the Logistics Section. That branch can include the traditional Communications Unit as well as an Information Technology (IT) Service Unit. They also make allowances for a Cybersecurity Unit to be included the branch – not as an operational element for a cyber incident, but largely in a network security capacity. The creation of an ICT branch is also recommended for emergency operations centers (EOCs), regardless of the organizational model followed.

The IT Service Unit includes staffing for a leader, support specialists, and a help desk function, while the Cybersecurity Unit includes staffing for a leader, a cybersecurity planner, a cybersecurity coordinator, and a cyber support specialist. The position descriptions and associated task books are already identified pending final approvals and publication of this guidance, with the Cybersecurity and Infrastructure Security Agency (CISA) seemingly ready to support training needs for many of the new positions.

I’m fully in support of this change. FEMA is accepting feedback through October 20, 2022, with instructions available on the website provided previous.

Not being a communications or IT specialist myself, I’m interested in the perspectives of others on this.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Bring MAC Back

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Multi Agency Coordination, or MAC, is a concept most frequently applied to incident management. MAC Groups are the most commonly defined, being a collection of executives from various agencies, organizations, and/or jurisdictions who may commit the resources of their respective agencies, and often provide high-level decision-making and policy coordination to support an incident. Multi Agency Coordination Systems (MACS) have also been commonly defined, essentially as the combination of resources assembled to support the implementation of multi agency coordination. Multi agency coordination, as a concept, however, transcends MAC Groups and MAC Systems. In incident response we see multi agency coordination occur at the field level and in emergency operations centers (EOCs), the latter of which is generally viewed as an operational extension of the MAC Group. We even see the concept of multi agency coordination specifically extended into Joint Information Systems and Joint Information Centers. Multi agency coordination can and often does also exist across all phases and mission areas associated with emergency management. This is simply a reinforcement that emergency management is a team sport, requiring the participation and input of multiple organizations before, during, and after a disaster as well as in steady-state operations. MAC can be applied in many effective ways to support all of this.

But where did MAC (the more formal version) go? MAC was one of the foundational aspects of the National Incident Management System (NIMS) at one time. But now if you look for information on MAC, you will be pretty disappointed. The NIMS doctrine provides barely a single page on MAC, which might be fine for a doctrinal document if there were supplemental material. Yet, when looking through FEMA’s page for NIMS Components, there are no documents specifically for MAC. There used to be a pretty decent independent study training course for MAC, which was IS-701. That course, and the materials provided, no longer exist as of September 2016. (side note… lots of states and other jurisdictions assembled NIMS Implementations Plans. Many of those have not been updated in years and still reference this as a required training course). You will find only scant references to MAC in some of the ICS and EOC courses, but not with the dedicated time that once existed.

So why is this a problem? MAC as a concept is still alive and well, but without doctrine, guidance, and training to reinforce and support implementation, it will fall into disuse and poor practice. Just in the past two weeks alone, I’ve had direct conversations about MAC with three different clients: one in regard to a state COVID AAR; the other for all hazard planning, training, and exercises; and the other for state-level coordination of a response to invasive species. Superficially, MAC seems an easy concept. You get a bunch of executive-level stakeholders in a room, on a call, or in a video chat to talk about stuff, right?  Sure, but there are right and wrong ways to go about it and best practices which should be embraced. There is no single true model for MAC, which is appropriate, but absent any reasonable guidance, MAC may be misapplied, which could become an impediment to a response – something we’ve certainly seen happen.

All that said, we need to bring significant MAC content and guidance back. One of the better resources I’ve found out there comes from Cal OES. It’s a bit dated (2013) but still relevant. While it does have some language and application specific to California, it is an all-hazards guide (actually adapted from a wild-fire oriented FIRESCOPE document). The document is good, but I’d like to see a national approach developed by FEMA (properly the National Integration Center). MAC is an incident management fundamental, with application even broader than response. Their importance for response, especially larger more complex incidents, is huge, yet the information available on MAC is fairly dismissive. While some content exists in training courses, most of the courses where the content is found are not courses which many MAC Group members would be taking. We must also not confuse training with guidance. One does not replace the other – in fact training should reflect guidance and doctrine.

© 2022 Tim Riecker, CEDP – The Contrarian Emergency Manager

Emergency Preparedness Solutions, LLC®

EOC Management Support Teams

Tim Riecker, The Contrarian Emergency Manager Leave a comment

I almost always catch the releases of the draft FEMA/NIC resource typing definitions, yet I clearly missed the one released in late February for EOC Management Support. Feedback on the draft is due by COB tomorrow, Friday (April 1, 2022).

This release is actually a significant update from an original resource typing definition for EOC Management Support Teams released in 2005. I’m not even sure what they were thinking with the 2005 version, in which a Type 1 EOC Management Support Team only addresses EOC Management/Command Staff.

This new version addresses EOC Management Support more broadly, tackling the challenge of addressing differing EOC organizational models (ICS-based, Incident Support Model-based, or Department/ESF-based). For ICS-based and ISM-based models, they stick to a minimum of six personnel, composed of the EOC Director (I still prefer EOC Manager, personally), a PIO, and the General Staff positions. The Department/ESF-based model identifies an Emergency Manager as providing oversight (not sure why they aren’t sticking with an EOC Manager/Director title), and five departmental/ESF representatives, which they rightfully indicate should be selected based upon the needs of the incident.

Unfortunately, this resource typing definition is extremely short sighted, providing the same structure across Types 1 through 3, with the only noted differences from Type 3 to Type 1 being a small bit of computer and communications equipment. I’m not particularly happy about this and I think it’s a discredit to skilled, trained, and experienced EOC personnel. This also does a disservice to the fundamental purpose of resource typing, being that incidents which have more demands require resources with greater capability. The simple addition of some computer monitors and a sat phone doesn’t provide any greater capability of the knowledge and skills of the personnel being deployed. I’m not sure why Type 2 and Type 1 EOC Management Support Teams wouldn’t be required to provide additional staff (to account for 24-hour operations, work load, etc.).

This document alone also paints an incomplete picture, citing positions that aren’t themselves defined in the library by position qualifications and corresponding position task books. As such, there are no training and experience requirements outlined for the positions identified. There is no typing that exists for these positions at all, or really any definition within the NQS of these positions. I think this document should have been released as part of a full package that includes the position qualifications and task books for each position.

As a positive observation, I do appreciate that this new document specifies that while Incident Management Teams (IMTs) have been deployed to fulfil EOC Management Support roles, requests should be first filled by actual EOC Management Support Teams. I appreciate this recognition, especially considering that IMTs are not fundamentally designed to manage EOCs. While they often do, and are generally successful, this can be an underutilization of IMTs at best, and possibly the entirely wrong tool for the job.

All in all, while this is a step in the right direction for recognizing the need for personnel who specialize in aspects of EOC management, I’m disappointed with the lack of thought that has gone into this. It’s rather like ordering a new car and only being given four tires to start. There is no connection between those tires and nothing to make them go. There isn’t even a place to sit, much less any idea if those tires are suited for the vehicle you ordered. This is also long overdue. The effort to type resources by the National Integration Center is about as old as NIMS itself, yet this is the first REAL movement we have seen on defining and typing EOC personnel. EOCs are activated for most significant incidents, yet actually scoping these personnel has largely been ignored. Instead, time and effort has been put into position qualifications for positions which may certainly be important, but are rarely utilized. We need to do better and expect better.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Mutual Aid Preparedness

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Mutual aid is a great resource. We get help from our neighbors, or even those beyond our neighbors, providing additional numbers, capabilities, or support to aid our response to incidents and disasters. Mutual aid is mentioned in practically every emergency operations plan I’ve read, yet it’s clearly taken for granted. Most jurisdictions simply don’t have a plan for mutual aid, and most that do have a rather poor plan.

The fire service is by far the most frequent user of mutual aid. Most fire service mutual aid is for short-duration incidents, meaning that they’ve only scratched the surface in mutual aid management issues. Most fire departments don’t have their own mutual aid plans in place, instead relying on a county-based or regional plan. These also vary rather wildly in content and quality. It’s largely fine to use and be part of a county or regional plan, so long as SOMEONE is responsible for implementing the plan and all participants are familiar with it. Given issues of liability, there should also be a mutual aid agreement to which members are signatories consenting to the terms and conditions of the agreement as implemented by the plan.

The best mutual aid practitioners I’ve had experience with are utility companies, especially electric utilities. Be it hurricanes, winter storms, wildfires, or other hazards, most electric utility infrastructure is highly vulnerable to physical disruption. Even if not involved in managing or responding to an incident, we’ve all seen out-of-state utilities responding to our own areas for a major disruption, or utility trucks on the highway headed elsewhere toward a disruption. Utilities have highly detailed plans, often of their own as well as being part of regional consortiums. Those regional consortiums are then part of national-level mobilization plans. While the response details of the incident will change based on each deployment, the managers of every deployment know what to expect in terms of business operations. More strictly in the emergency management world, only the Emergency Management Assistance Compact (EMAC), used for inter-state mutual aid, is as thorough and well-used on such a large scale.

The foundation of mutual aid, regardless of duration or resources shared, is a written agreement. This is something that emergency managers and first responders have been beaten over the head with for years, yet so few actually have written agreements in place. There is no downside to having written agreements. While they may be combined into a single document, agreements and plans really should be different documents, as they have entirely different purposes. Agreements are attestations to the terms and conditions, but plans describe the means and methods. The provisions in a plan, however, may be the basis for the agreement. FEMA provides the NIMS Guideline for Mutual Aid that identifies all the necessary elements of a mutual aid agreement (and plan). The development of a mutual aid plan, just like any other emergency operations plan, should utilize FEMA’s CPG 101: Developing and Maintaining Emergency Operations Plans to guide development. Yes, many FEMA preparedness documents are actually complimentary!

So what about mutual aid planning is so important? Consider that you are having a really big pot-luck party, with hundreds of people invited. Everyone wants details of course: when should they arrive, where should they go, where should they park, how long will the party run? What food should they bring? Is there storage for cold food? How about frozen food? Are there food allergies? Is there alcohol? Are kids welcome? Will there be activities? Can I show up late? Can I show up early? What if I have to leave early? What’s the best way to get there? Are there any hotels in the area? Can I set up a tent or a camper? Can I bring my dogs? What if the weather is bad? You get the point. While most of these questions aren’t the types of questions you will get in a mutual aid operation, some actually are likely, and there will be even more! These kinds of questions are fine and manageable when it’s a few people, but when there are hundreds, it feels like asking for help is an entirely different incident to manage – that’s because it is! Of course, good planning, training, and exercises can help address a lot of this.

Mutual aid plans should address receiving AND sending mutual aid. There are dozens if not hundreds of bad stories coming from incidents like 9/11, Hurricane Katrina, and other benchmark incidents that involve poor mutual aid management – on the part of the receivers as well as those providing resources. Every agency should have policies and procedures in place about responding to mutual aid requests. There were numerous departments on 9/11 that were left non-operational because personnel responded to NYC, Shanksville, or the Pentagon, taking so many resources with them that it crippled their home department’s ability to respond. I wrote about deployment issues back in 2021.

Who will be responsible for receiving dozens or hundreds of resources if you ask for them? I’m not just talking about appointing a Staging Area Manager (something else we do VERY poorly in public safety), but is your organization prepared to receive, support, and manage all these resources? If you expect the operation to be longer than several hours, you may need to consider lodging. How about food and water? Supplies? Specialized equipment? Will you be ready to assign them, or will they languish in a Staging Area for hours? If these aren’t volunteers, who is paying them? How will reimbursement for expenses work?

What if something breaks? What if someone gets hurt? These are important questions not only from the perspective of actions to be taken, but also liability. How will you handle HR types of issues (substance abuse, harassment, etc.) involving mutual aid personnel? Are you prepared to provide these resources with critical incident stress debriefings?

How will mutual aid resources be accounted for and credentialed? What authorities, if any, will mutual aid resources have? What documentation will they be responsible for? How will you communicate with them? Do you have the essential ability to integrate them into your operations?

The bottom line is that if you invite someone to your party, you are responsible for them. It’s a matter of operational necessity, legal liability, professionalism, and respect.

What best practices have you seen when it comes to preparedness for and management of mutual aid resources?

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

ICS – Assistant Section Chiefs

Tim Riecker, The Contrarian Emergency Manager 2 Comments

Somehow this one snuck past me, but luckily I have some friends and colleagues who brought it to my attention and talked it through with me. The latest ICS curricula (not consistently, however) identifies that Section Chiefs can have Assistants. It’s been a long-standing practice for General Staff to have Deputies rather than Assistants. So where did this come from?

Page 82 of the NIMS document, as pointed out to me by someone at EMI, provides some language that seems to be the root of this. Here are the definitions provided:

Deputies are used at section and branch levels of the incident organization. A deputy, whether at the command, section, or branch level, is qualified to assume the position.

Assistants are used on Command Staffs and to support section chiefs. Unlike deputies, assistants have a level of technical capability, qualification, and responsibility subordinate to the primary positions and need not be fully qualified to assume the position.

None of those I spoke with are aware of the actual source of this change or why it was changed. Of course, I initially balked at it because it wasn’t the ICS I ‘grew up with’. Given some thought, however, it provides some organizational opportunities and certainly doesn’t violate any of the primary tenets of ICS.

There are absolutely some occasions in the past when, as a Planning Section Chief, I could have used this option. Planning Section Chiefs end up in a lot of meetings, and while I always felt comfortable with leaving the personnel staffing the section to their own tasks, it’s good to have another leader there in the absence of the Section Chief, both for the benefit of the section staff as well as the rest of the organization. However, if there was no one technically qualified to be a Deputy Section Chief but still capable of leading the staff and serving as an interim point person for the section, we would be (and have been) stuck in an organizational nuance. By definition, they couldn’t be assigned as a Deputy, but we didn’t have another option. This is a great opportunity to assign an Assistant. This is somewhat like an ‘executive officer’ type of position, whereas they have authority but can’t necessarily fill the shoes of the principal position.

To add to the myriad options for the Intelligence function, I also see the potential in the use of an Assistant, either in Planning or Operations, to be a viable option. This is someone qualified to lead the task, but not necessarily the Section they are organized within. I similarly see possibilities for addressing other defined needs within the incident organization. Sometimes we take some liberties, again for example in the Planning Section, to create Units that are non-standard, perhaps for tasks such as ‘Continuity Planning’, or ‘Operational Planning Support’ – of course being non-standard, you may have some different titles for them. There isn’t necessarily anything wrong with this, as we aren’t violating any of the primary rules of ICS, nor are we creating positions that actually belong elsewhere (as I often see). Planning is planning, and there may be necessity to have personnel specifically tasked with functions like these. Instead of creating a Unit, which could still be done, you could assign the task to an Assistant. Consider something like debris management. There is a significant planning component to debris management, separate from the operations of debris management. This could be tasked specifically to an Assistant Section Chief to handle.

Another consideration, and somewhat tied to my first example of a de facto leader/point of contact for a section in the absence of the Section Chief, is that an Assistant Section Chief seems to carry more authority than a Unit Leader. That level of authority may need some doctrinal definition, but I think is also largely dependent upon the task they are given and the desires of the Section Chief assigning them – though this can make for inconsistencies across the incident organization. Having someone with a measure of authority, depending on the needs of the task, can be extremely helpful, particularly with the bureaucracies that incident management organizations can sometimes evolve into.

It’s important for us to recognize the need for doctrine to evolve based on common sense approaches to addressing identified needs. That means that the ICS we ‘grew up with’ can and should change if needed. As NIMS/ICS (and other standards) continues to evolve, we need to have discussions on these needs and potential solutions. Every change, however, has consequences, or at least additional considerations. I don’t feel this change should have been made without further exploration of the topic and answering questions such as the level of authority they may have, qualification standards, and support staff assigned to them (let’s be honest – things like this were never well defined for Assistant Command Staff positions either).  I also see a lot of value in doctrine offering best practice examples of use. Once doctrinal changes are made, curriculum changes certainly need to follow. In just examining the ICS 300 and ICS 400 course materials, the inclusion of Assistant Section Chiefs is simply not consistent or adequate.

Where do you find yourself on this topic? For or against Assistant Section Chiefs? What potential uses do you see? What potential problems do you see? How can we address these and ensure good implementation?

© 2021 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

ICS 400 Training – Who Really Needs It?

Tim Riecker, The Contrarian Emergency Manager 6 Comments

A few days ago I had a bit of discussion with others on Twitter in regard to who actually has a need for ICS 400 training. I think a lot of people are taking the ICS 400 (Advanced ICS for Command and General Staff) course for the wrong reasons. While I’d never dissuade anyone from learning above and beyond what is required, we also, as a general statement, can’t be packing course offerings with people who don’t actually need the training. There is also an organizational expense to sending people to training, and the return on that investment decreases when they don’t need it and won’t apply it. Overall, if you are a new reader, I have a lot of thoughts on why our approach to ICS Training Sucks, which can be found here.

Before we dig any deeper into the topic, let’s have a common understanding of what is covered in the ICS 400 course. The course objectives identified in the National Preparedness Course Catalog for some reason differ from those actually included in the current 2019 version of the course, so instead I’ll list the major topics covered by the two-day course:

  • Incident Complex
  • Dividing into multiple incidents
  • Expanding the Planning Capability
  • Adding a second Operations or Logistics Section
  • Placement options for the Intel/Investigations function
  • Area Command
  • Multi-Agency Coordination
  • Emergency Operations Centers
  • Emergency Support Functions

For this discussion, it’s also important to reference the NIMS Training Program document, released in the summer of 2020. This document states many times over that it includes training recommendations and that the authority having jurisdiction (AHJ) determines which personnel are to take which courses. This document indicates the ICS 400 is recommended for:

  1. ICS personnel in leadership/supervisor roles
  2. IMT command, section, branch, division, or group leaders preparing for complex incidents

Note that while #1 above seems to fully capture anyone in a leadership/supervisor role, the document also says that IMT unit, strike team, resource team, or task force leaders preparing for complex incidents do NOT need the training. I’d say this certainly conflicts with #1 above.

With that information provided, let’s talk about who really needs to take the ICS 400 from a practical, functional perspective. First of all, looking at recommendation #1 above, that’s a ridiculously broad statement, which includes personnel that don’t need to have knowledge of the course topics. The second recommendation, specific to IMTs, I’ll agree is reasonably accurate.

Having managed a state training program and taught many dozen deliveries of the ICS 400 course, I’ll tell you that the vast majority of people taking the course don’t need to be in it. I’d suggest that some deliveries may have had absolutely no one that actually needed it, while most had a scant few. Much of this perspective comes from a relative determination of need of personnel that fit within recommendation #1 above. Just because someone may be an incident commander or a member of command and general staff, doesn’t necessarily mean they need to take ICS 400. It’s very likely that through their entire career all of the incidents they respond to and participate in the management of can be organized using standard ICS approaches.

Interface with an EOC does not mean you need to take ICS 400. There is, in fact, a better course for that, aptly named ‘ICS/EOC Interface’. More people need to take this course than the ICS 400. I’m also aware that some jurisdictions require ICS 400 for their EOC staff. The ICS 400 course doesn’t teach you how to function in or manage an EOC. Again, the ICS/EOC Interface course is the better solution, along with whatever custom EOC training is developed (note that none of the FEMA EOC courses will actually teach you how to manage or work in YOUR EOC). If you feel that people in your EOC need to know about some of the concepts within the ICS 400, such as Multi-Agency Coordination or Area Command, simply include the appropriate content in your EOC training. To be honest, I can tell most EOC personnel what they need to know about an Area Command in about three minutes. They don’t need to sit through a two-day course to learn what they need to know.

Cutting to who does need it (aside from IMT personnel), personnel who would be a member of Command and General Staff for a very large and complex incident (certainly a Type I incident, and MAYBE certain Type 2 incidents) are the candidates. Yes, I understand that any jurisdiction can make an argument for their fire chief or police chief, for example, being the IC for an incident of this size and complexity, though let’s consider this in a relative and realistic sense. Most incidents of this size and complexity are likely to span multiple jurisdictions. Particularly in a home rule state, that fire chief or police chief is typically only going to be in charge of that portion of the incident within their legal borders. Although that incident may be a Type I incident taken as a whole, it will likely be managed in large part by a higher AHJ, which may use some of the concepts outlined in the ICS 400. While local government is still responsible for managing the portion of the incident within their borders, they are much less likely to utilize any of the ICS 400 concepts themselves. Along a similar line of thought, most jurisdictions don’t have hazards that, if they become incidents, would be of such size or complexity within their jurisdiction that would require use of these concepts. This leaves larger, more populous jurisdictions generally having a greater need for this level of training.

At some point, every state and UASI was required, as part of their NIMS implementation, to develop a NIMS training plan. Most of the plans I’ve seen further perpetuate the idea that so many people must have ICS 400 training. As part of this, many states require that anyone holding the position of fire chief must have ICS 400. Considering my argument in the paragraphs above, you can see why this is tremendously unnecessary. We must also consider erosion of knowledge over time. As people do not use the knowledge, skills, and abilities they have learned, that knowledge erodes. This is highly likely with the concepts of ICS 400.

A lot of states and other jurisdictions need to take a more realistic look at who really needs ICS 400 training. I’d also like to see some clarification on the matter in FEMA’s NIMS Training Guidance. It’s not about making this training elite or restricting access, but it is about decreasing the perceived and artificially inflated demand for the course.

What’s your jurisdiction’s take on ICS 400 training?

© 2021 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Preparing for Disaster Deployments

Tim Riecker, The Contrarian Emergency Manager 1 Comment

I wrote last year about my trepidation over Community Emergency Response Teams (CERT) being considered as a deployable resource. The problem is that even most professionally trained emergency personnel aren’t prepared for deployment. We need to do better.

One of the key aspects of a disaster is that it overwhelms local resources. This often requires help from outside the impacted jurisdiction(s). Working outward from the center, like the bullseye of a dartboard, we are usually able to get near-immediate assistance from our neighbors (aka mutual aid), with additional assistance from those at greater distances. When I use the word ‘deployment’, I’m referring to the movement of resources from well outside the area and usually for a period of time of several days or longer.

The US and other places around the world have great mutual aid systems, many supported by laws and administrative procedures, identifying how requests are made, discerning the liability for the requesting organization and the fulfilling organization(s), and more. Most of these are intended for response vs deployment, but may have the flexibility to be applicable to deployment. Some, such as the Emergency Management Assistance Compact (EMAC) are specifically written for deployments. While all this is certainly important, most organizations haven’t spent the time to prepare their people for deployment, which is a need that many organizations seem to take for granted. Those organizations which are, practically be definition, resources which are designed to deploy, such as Type 1 and 2 incident management teams (IMTs), often have at least some preparations in place and can be a good resource from which others can learn.

What goes into preparing for deployment? First, the sponsoring organization needs to recognize that their resources might be requested for deployment and agree to take part in this. That said, some organizations, such as volunteer fire departments, might have little control over their personnel deploying across the country when a call for help goes out publicly. These types of requests, in my opinion, can be harmful as large numbers of well-intentioned people may abandon their home organization to a lack of even basic response resources – but this is really a topic to be explored separately.

Once an organization has made a commitment to consider future requests, leadership needs to develop a policy and procedure on how they will review and approve requests. Will requests only be accepted from certain organizations? What are the acceptable parameters of a request for consideration? What are the thresholds for resources which must be kept at home? 

Supporting much of this decision making is the typing of resources. In the US, this is often done in accordance with defined typing from FEMA. Resource typing, fundamentally, helps us to identify the capabilities, qualifications, and eligibility of our resources. This is good not only for your own internal tracking, but is vitally important to most deployment requests. Organizations should do the work now to type their resources and personnel.

If an organization’s leadership decides they are willing to support a request, there then needs to be a canvass and determination of interest to deploy personnel. This is yet another procedure and the one that has most of my focus in this article. Personnel must be advised of exactly what they are getting into and what is expected of them (Each resource request received should give information specific to the deployment, such as deployment duration, lodging conditions, and duties.). The organization may also determine a need to deny someone the ability to deploy based on critical need with the home organization or other reasons, and having a policy already established for this makes the decision easier to communicate and defend.

These organization-level policies and procedures, along with staff-level training and policies should be developed to support the personnel in their decision and their readiness for an effective deployment.

Many things that should be determined and addressed would include:

  • Matters of pay, expenses, and insurance
  • Liability of personal actions
  • Code of conduct
  • What personnel are expected to provide vs what the organization will provide (equipment, supplies, uniform, etc.)
  • Physical fitness requirements and inoculations
  • Accountability to the home organization

Personnel also need to be prepared to work in austere conditions. They may not have a hotel room; instead they could be sleeping on a cot, a floor, or in a tent. This alone can break certain people, physically and psychologically. Access to showers and even restrooms might be limited. Days will be long, the times of day they work may not be what they are used to, and they will be away from home. They must be ready, willing, and able to be away from their lives – their families, pets, homes, jobs, routines, and comforts – for the duration of the deployment. Their deployment activity can subject them to physical and psychological stresses they must be prepared for. These are all things that personnel must take into consideration if they choose to be on a deployment roster.

This is stuff not taught in police academies, fire academies, or nursing schools. FEMA, the Red Cross, and other organizations have policy, procedures, training, and other resources available for their personnel because this is part of their mission and they make these deployments regularly. The big problem comes from personnel with organizations which don’t do this as part of their core mission. People who are well intentioned, even highly trained and skilled in what they do, but simply aren’t prepared for the terms and conditions of deployment can become a liability to the response and to themselves.

Of course, organizational policy and procedure continues from here in regard to their methods for actually approving, briefing, and deploying personnel; accounting for them during the deployment; and processing their return home. The conditions of their deployment may necessitate follow up physical and mental health evaluations (and care, as needed) upon their return. They should also be prepared to formally present lessons learned to the organization’s leadership and their peers.

I’ll say that any organization interested in the potential of deploying personnel during a disaster is responsible for making these preparations, but a broader standard can go a long way in this effort. I’d suggest that guidance should be established at the state level, by state emergency management agencies and their peers, such as state fire administrators; state departments of health, transportation, criminal justice, and others. These state agencies often contribute to and are even signatories of state-wide mutual aid plans which apply to the constituents of their areas of practice. Guidance developed at the state level should also dovetail into EMAC, as it’s states that are the signatories to these agreements and often rely on the resources of local organizations when requests are received.

There is clearly a lot to consider for organizations and individuals in regard to disaster deployments. It’s something often taken for granted, with the assumption that any responder can be sent to a location hundreds of miles away and be fully prepared to live and function in that environment. We can do better and we owe our people better.

Has your organization developed policies, procedures, and training for deploying personnel?

© 2021 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

EOCs and IMTs

Tim Riecker, The Contrarian Emergency Manager 3 Comments

The world of incident management is foggy at best. There are rules, sometimes. There is some valuable training, but it doesn’t necessarily apply to all circumstances or environments. There are national models, a few of them in fact, which makes them models, not standards. Incident management is not as straight forward as some may think. Sure, on Type 4 and 5 incidents the management of the incident is largely taking place from an incident command post. As you add more complexity, however, you add more layers of incident management. Perhaps multiple command posts (a practical truth, regardless of the ‘book answer’), departmental operations centers, emergency operations centers at various levels of government, and an entire alphabet soup of federal operations centers at the regional and national levels with varying (and sometimes overlapping) focus. Add in operational facilities, such as shelters, warehouses, isolation and quarantine facilities, etc. and you have even more complexity. Trying to map out these incident management entities and their relationships is likely more akin to a tangle of yarn than an orderly spiderweb.

Incident Management Teams (IMTs) (of various fashion) are great resources to support the management of incidents, but I often see people confusing the application of an IMT. Most IMTs are adaptable, with well experienced personnel who can pretty much fit into any assignment and make it work. That said, IMTs are (generally) trained in the application of the incident command system (ICS). That is, they are trained in the management of complex, field-level, tactical operations. They (usually) aren’t specifically trained in managing an EOC or other type of operations center. While the principles of ICS can be applied to practically any aspect of incident management, even if ICS isn’t applied in the purest sense, it might not be the system established in a given operations center (in whatever form it may take). While IMTs can work in operations centers, operations centers don’t necessarily need an IMT, and while (formal) IMTs are great resources, they might not be the best solution.  

The issue here certainly isn’t with IMTs, though. Rather it’s with the varying nature of operations centers themselves. IMTs are largely a defined resource. Trying to fit them to your EOC may be a square peg/round hole situation. It’s important to note that there exists no single standard for the organization and management of an EOC. NIMS provides us with some optional models, and in practice much of what I’ve seen often has some similarity to those models, yet have deviations which largely prevent us from labeling what is in practice with any of the NIMS-defined models in the purist sense. The models utilized in EOCs are often practical reflections of the political, bureaucratic, and administrative realities of their host agencies and jurisdictions. They each have internal and external needs that drive how the operations center is organized and implemented. Can these needs be ultimately addressed if a single standard were required? Sure, but when governments, agencies, and organizations have well established systems and organizations, we’ll use finance as an example, it simply doesn’t make sense to reorganize. This is why we are so challenged with establishing a single standard or even adhering to a few models.

The first pathway to success for your operations center is to actually document your organization and processes. It seems simple, yet most EOCs don’t have a documented plan or operating guideline. It’s also not necessarily easy to document how the EOC will work if you haven’t or rarely have activated it at all. This is why we stick to the CPG-101 planning process, engaging a team of people to help determine what will or won’t work, examining each aspect from a different perspective. I also suggest enlisting the help of someone who has a good measure of experience with a variety of EOCs. This may be someone from a neighboring jurisdiction, state emergency management, or a consultant. Either way, start with the existing NIMS models and figure out what will work for you, with modifications as needed. Once you have a plan, you have a standard from which to work.

Once you have that plan, train people in the plan. Figure out who in your agency, organization, or jurisdiction has the knowledge, skills, and abilities to function within key positions. FEMA’s EOC Skillsets can help with this – even if the positions they use don’t totally map to yours, it’s not difficult to line up most of the common functions. Regardless of what model you are using, a foundation of ICS training is usually helpful, but DON’T STOP HERE. ICS training alone, even if your EOC is ICS-based, isn’t enough. I can practically guarantee your EOC uses systems, processes, or implementations unique to your EOC which aren’t part of ICS or the ICS training your personnel received. Plus, well… if you haven’t heard… ICS training sucks. It can be a hard truth for a lot of entities, but to prepare your personnel the best way possible, you will need to develop your own EOC training. And of course to complete the ‘preparedness trifecta’ you should then conduct exercises to validate your plans and support familiarity.

All that said, you may require help for a very large, long, and/or complex incident. This is where government entities and even some in the private sector request incident management support. Typically this incident management support comes from established IMTs or a collection of individuals providing the support you need. The tricky part is that they aren’t familiar with how you are organized or your way of doing things. There are a few ways to hedge against the obstacles this potentially poses. First, you can establish an agreement or contract with people or an organization that know your system. If this isn’t possible, you can at least (if you’ve followed the guidance above) send your plan to those coming to support your needs, allowing them at least a bit of time in transit to study up. Lastly, a deliberate transition, affording some overlap or shadowing time with the outgoing and incoming personnel will help tremendously, affording the incoming personnel to get a hands-on feel for things (I recommend this last one even if the incoming personnel are familiar with your model as it will give an opportunity to become familiar with how you are managing the incident). Of course all of these options will include formal briefings, sharing of documentation, etc.

Remember, though, that there are certain things your agency, organization, or jurisdiction will always own, especially the ultimate responsibility for your mission. Certain internal processes, such as purchasing, are still best handled by your own people. If your operations are technical and industry-specific, such as for a utility, they should still be managed by your own people. That doesn’t mean, however that your people can’t be supported by outside personnel (Ref my concept of an Incident Support Quick Response Team). The bottom line here is that IMTs or any other external incident support personnel are great resources, but don’t set them up for a slow start, or even failure, by not addressing your own preparedness needs for your EOC. In fact any external personnel supporting your EOC should be provided with a packet of information, including your EOC plan and procedures, your emergency operations plan (EOP), maps, a listing of capabilities, demographics, hazards, org charts for critical day-to-day operations, an internal map of the building they will be working in, and anything else that will help orient them to your jurisdiction and organization – and the earlier you can get it to them the better! Don’t forget to get your security personnel on board (building access cards and parking tags) and your IT personnel (access to your network, printers, and certain software platforms). Gather these packets beforehand or, at the very least, assemble a checklist to help your personnel quickly gather and address what’s needed.

© 2021 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®