The Roadmap for Colleges Creating Concealed Carry Policies on Campus

The DOJ-funded National Center for Campus Public Safety (NCCPS) released a campus carry report earlier this year to “provide informed guidance to institutions of higher education in the process of developing or anticipating the need to develop [concealed carry] policies.”

The center referenced background research, listed dozens of considerations for campuses and made “ideologically-neutral” recommendations for colleges and universities crafting concealed carry policies. It also referenced lessons learned from 27 college police and public safety executives who have experience developing and implementing policies to allow concealed guns on campus. Recommendations were also based on the insights of a forum of campus public safety executives, federal officials, and subject-matter experts on concealed carry.

The recommendations rest on three core concepts:

• Colleges must create a concealed carry policy that is consistent with state law
• There is no one size fits all policy. The authors noted the “significant physical, functional and cultural differences” among campuses that must be taken into account.
• Creating a concealed carry policy needs to be an institution-wide effort

A detailed summary of the 50-page report is below.

Research Surrounding Concealed Carry on Campus

The center found “virtually no empirical evidence to support” arguments that people with concealed handgun permits on campus make colleges any safer or more dangerous, but warned “campus leaders and public safety officials must nonetheless be prepared to respond to” people on both sides of the ideological spectrum.

Later on, the report states that the overall goal for campuses is to enforce a concealed carry policy that complies with state law and to provide information to the college community in response to issues that may arise because of the policy.

“In performing this role, institutions must be transparent, involve a diverse array of entities from the campus community, and communicate throughout the process, not just provide information after the fact,” the report states. We dive deeper into those tasks below.

Part 1: Beginning to Craft a Concealed Carry Policy

The NCCPS argues a committee consisting of critical stakeholders from across the campus must be involved in creating the concealed carry policy to ensure it is comprehensive and creates buy in. Interests that must be represented include campus police or public safety, the central administration, legal counsel, faculty governance, student governance, support staff and relevant special interests, which will vary by institution. Local law enforcement may also be present, particularly if campus public safety officers are non-sworn.

The report suggests colleges consider having a smaller committee for policy development and a larger committee for policy implementation to provide both expediency and representativeness.

The person who leads the committee will vary by institution, but the center notes “there tends to be heavy reliance on the campus public safety/police department to provide critical guidance, particularly on enforcement issues and capability.”

Understanding the Context of Concealed Carry Implementation

This is an area where a multidisciplinary policy development team can help assess the campus environment. The NCCPS identified several characteristics that may influence development and implementation of a concealed carry policy, including:

• Colleges with multiple campuses.
• Colleges that host large amounts of unaffiliated visitors
• Colleges with critical facilties on campus
• Geography
• Residential populations
• Culture
• Level of campus activism
• College population and campus size
• Extended campuses (such as an agricultural research station)
• Enforcement capabilities (the authority and capabilities of campus public safety forces)

Considering State Laws and Other Concealed Carry Policies

The NCCPS suggests college officials review the National Conference of State Legislators’ overview of concealed carry laws. The Quorum US bill-tracking database is another useful legislative resource, although most colleges have a legislative liaison office that will be the most effective resource for monitoring campus carry legislation in the state.

The center cautioned that preparing too much for laws that are still merely proposals can be a waste of college officials’ time, but there is value in soliciting and reviewing other college’s policies as they relate to provisions that are commonly seen in campus carry legislation.

“Similarly, peer exchanges with other institutions that have developed and implemented concealed carry policies can provide invaluable insight into implementation and permit a detailed exchange of information that cannot be duplicated in phone calls and e-mail exchanges.”

Part 2: Developing Your College’s Concealed Carry Policy

According to the report, the first step is understanding what’s required by law and what can be excluded, then college officials should do the following:

• Review other institutions’ policies for ideas and language
• Develop a consensus on exclusion zones and the rationale for them
• If the policy requires handgun storage options, develop explicit procedures and ensure the costs are clearly stipulated
• A Behavioral Intervention Team (BIT) could be formed to monitor “red flag” behavior related to concealed carry on campus
• If permitted by law, colleges could make a statement about liability noting the concealed carry policy is being implemented only as a result of state law, not proactively
• If the campus community must register their weapons, ensure registration records are kept secure and confidential. A gun records management system may need to be created to hold information about concealed carry permit holders

“Participants also cautioned not to make the policy too detailed or too complicated” because that will make it more difficult to enforce.

The report recommends separate policies for mechanisms of weapon storage and certain tricky situations.

For instance, in the event that law enforcement receives a call of an armed person on campus, dispatchers should be trained to get as much detail from the caller as possible to discern whether the person is posing a threat or just seen with a weapon. Another difficult situation is if a lawfully armed person encounters a person in a use-of-force situation (like an active shooter). The report recommends training programs and educational efforts be undertaken to prepare handgun carriers for such situations.

Legal

Members of the expert forum hosted by the NCCPS recommended stakeholders identify legal counsel to advise the committee during the development of the policy and identify legislative contacts and a liaison with the state Attorney General’s office.

Legal counsel can also help correct any inconsistencies with the new gun policy and existing ones that may have been in place in areas like the athletic department or a medical facility. When provisions in the state’s campus carry law lack clarity, legal counsel should provide arguments and rationale for different interpretations.

“Legal counsel should also aid in the wording of the provisions of the policy and provide language for the justifying rationale,” the report states.

Finally, forum participants said legal counsel can help develop a policy for lawfully prohibiting a person with a demonstrable history of violence or mental health issues, or others who may pose a threat to themselves or others, from carrying a concealed handgun.

Education

Educating faculty, staff and students should be an ongoing process that begins before the policy is implemented and incorporates different methods. The expert forum recommended providing the following:

• Online information, including a Frequently Asked Questions section
• Online training
• Mandatory training where permissible by law
• Use of social media platforms
• Signs and placards
• Public service announcements in conjunction with other news outlets
• Information pushed through the center for campus life or the office of student affairs
• Education and reinforcement through residence hall associations
• Awareness and reinforcement through counseling centers
• Targeted information for parents and student family members
• Education through employee collective bargaining units
• Education through academic governance mechanisms at the college

The forum also suggested colleges build off of active shooter response training to “inform those who carry handguns on expectations of their behavior and their responsibilities during these incidents.”

Finally, stakeholders should also be educated about campus police and local law enforcement’s response to an armed person or a use of force situation.

Implementation

Members of the forum stressed that budgetary considerations are top of mind when it comes to implementation.

“Virtually every aspect of the implementation plan will have direct or indirect costs associated with tasks, including: web development, social media presence development, printing brochures, making signs, hiring new staff to manage the concealed carry program, developing and presenting training and education sessions, and the purchase, management, and maintenance of the required equipment,” the report states.

Other factors that campus officials should consider include:

The behavioral and emotional impact the implementation. Officials should respond to campus community members experiencing fear by meeting with the community, presenting the facts and maintaining dialogue through social media, brochures and the campus counseling center.

Policy and pragmatic aspects of the implementation. Some forum participants made gun safes available as part of the campus carry policy or for convenience. Will colleges staff handgun safes or use keyed “self-service” gun safes? Will there be one centralized safe or smaller ones at each exclusion zone on campus? Another consideration is how campus police will respond to calls of persons improperly concealing their weapon: Is strict policy enforcement or a simple warning and “teaching moment” right for your campus?

Training for Campus Carry

Sometimes training is required or prohibited by state law. Forum participants said training should be incentivized, easily accessible, well-documented and multi-faceted, with programming for new students and employees, videos, roll call training and online training.

A training plan should be developed and include learning objectives, the training platforms to be used, a schedule, the instructor list and the budget. The funds for training should not be taken from existing public safety training funding if possible.

Student Training Considerations for Campus Carry

Students with concealed carry permits should be incentivized to undergo training if they are not required to do so by law. New students should immediately be made aware of the concealed carry policy and where they can get more information on campus carry. The report listed the following examples of student training topics:

• What is meant by “concealed” and the obligation to maintain concealment
• Obligations either to not enter an exclusion zone or to store the handgun
• Rules on firearms for residence halls visitors
• Rules on firearms storage on campus for those living in residence halls
• Rules on firearms storage in vehicles
• The need for a state concealed weapons permit, where required by the state, for a handgun
• Gun registration for campus residents
• What to do if confronted by a police officer concerning the handgun
• Actions if encountering a violent crime or use-of-force situation when no police officer is present
• Actions to take when a person is armed during a use-of-force incident and police officers are responding

Faculty and Staff Training Considerations for Campus Carry

State laws will vary in terms of concealed carry training requirements, but a unique consideration for faculty and staff is the liability of the school if an incident occurs. Sort this out before implementation. Other employee training topics listed in the report include:

• The role of a supervisor who has employees lawfully carrying concealed handguns
• What is meant by “concealed” and the obligation to maintain concealment
• Decisions either to not enter an exclusion zone or to store the handgun, even if a work assignment requires entry to the exclusion zone
• Rules on handguns in residence halls for employees who have to enter residence halls for a work assignment
• Rules on handgun storage in vehicles
• The need for a state concealed weapons permit for a handgun where applicable
• Mandatory registration and training for employees
• What to do if confronted by a police officer concerning the handgun
• Actions to take if encountering a violent crime or use-of-force situation when no police officer is present
• Actions to take when an armed employee encounters a use-of-force incident and police officers are responding

For concealed carry training and education for campus police and public safety officers, see Concealed Carry Policy Considerations for Campus Police later this week.

Part 3: After Implementing Your Campus Carry Policy

Once a policy for concealed carry has been implemented on campus, the report described the evidence-based evaluation college officials must undertake to make sure their policies are working as intended.

“Research needs to focus on procedures (Are they working as planned?) and effectiveness (Are the intended goals being achieved?),” the report states.

Colleges may want to employ a faculty researcher to help develop methods to evaluate the campus carry policy. Data collected on the campus community’s behavior must be confidential. Some data points that should be tracked are listed below.

• Officer encounters
• Stakeholder survey results
• Weapons violence on campus
• Stolen and lost weapons
• Gun brandishing calls or offenses
• Gun exclusion zone violations
• Local law enforcement agencies’ instances of firearm offenses
• Interview and case study results

Communication is also a crucial element of a successful concealed carry policy, as it is needed to resolve questions, fears and concerns that concealed carry opponents and advocates may have. Campus public safety departments will inevitably play a major role in the communication aspect, but colleges should also utilize social media, websites, brochures, placards and other channels to spread information about the policy.

Holding regular meetings with different campus stakeholders and creating an online channel dedicated to answering questions are also good ways to provide ongoing information. This will likely require partnering with the communications department at your institution.

Concealed Carry’s Effect on Campus Culture

Overall, all of these processes should also take into account your individual institution’s culture. A wide range of perspectives will present themselves with such a controversial policy, and it’s important to objectively consider all of them in an inclusive manner so that no one feels left out or threatened.

“The challenge for the institution is to forge a rational policy and pathway to lawful campus carry in an emotional environment,” the report states.

Maintaining a campus culture is just one of myriad challenges that institutions will have to overcome when developing a campus carry policy. The NCCPS’ report is a great start to taking an informed approach to navigating a difficult process. It clearly identifies each component of implementing a successful campus carry policy and acts as a roadmap for colleges across the country. Don’t go at it alone!

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