Clery Compliance Part 2: Emergency Response, Notification Guidelines

Under the Higher Education Opportunity Act (HEOA) of 2008, which went into effect this July, colleges and universities have new rules relating to emergency response, emergency notification, missing student notification, fire safety reporting and hate crime reporting. This special section will help your campus meet these requirements
Published: September 1, 2010

Emergency Response Policy, Notification and Testing Guidelines

The tragic shootings that occurred on April 16, 2007 at Virginia Tech resulting in the killing of 32 innocent students and employees as well as the wounding of approximately two dozen more forever changed campus security in the United States.

Ensuring that campus communities get immediate notification about such threats is the most widely known change to the federal Jeanne Clery Act (Clery Act) as a result of this tragedy, but the amendments that take full effect this fall are actually much broader in scope. They are intended to make sure that campuses are better prepared to respond to all types of emergencies—from active shooters to fires to infectious diseases—by establishing a framework for the response as well as campus community involvement and oversight.

Starting this fall, the Clery Act requires colleges and universities, both those with and without on-campus student residential facilities, to have emergency response and evacuation procedures in place. Institutions must also for the first time disclose a summary of these procedures in their annual security report (ASR) due to be disclosed to students and employees on campus by Oct. 1.

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Civilians Must Be Able to Easily Understand Policies

The statement of policy should contain a comprehensive synopsis of each institution’s full procedures in a format that can be easily understood by an incoming student or employee without public safety expertise.

Operational details that might compromise emergency response efforts or detailed step-by-step instructions should not be included here. More detailed or site specific instructions, however, can be included in postings or small manuals located in classrooms and other facilities across the campus. If an institution elects to use these options, this should be disclosed in the statement of policy.

Institutions have wide latitude to set their emergency response procedures, but they must address three specific requirements in order to fully comply with the new guidelines. The procedures must provide for emergency notifications of immediate threats, at least one test of the emergency response procedures annually, and procedures for publicizing the procedures in conjunction with the annual test.

In an effort to ensure both clarity of process as well as community oversight of it, institutions are required to disclose a good amount of detail about how their emergency notification policies work. The emphasis here is on having an efficient process rather than on the technology or channels that will be used to disseminate the message alone.

The policy statement must articulate how the institution will confirm there is “a significant emergency or dangerous situation involving an immediate threat to the health or safety of students or employees occurring on the campus.” While the process should be a quick one, it should also provide for consultation among experts who know best how to confirm various types of threats.

Campus police can readily confirm a threat from an active shooter but may well need input from physicians and public health experts about an infectious disease spreading throughout campus residence halls. Other officials, such as emergency management personnel, may need to be consulted regarding incidents such as weather emergencies, hazmat spills or, facilities issues.

Disclose How Emergency Notifications Will Be Handled

Unlike the longstanding timely warning that must be issued across the campus community, emergency notifications may be targeted to only a segment or segments of the campus community that are at risk. Each institution must disclose how it will assess which segment is at risk and how each segment will receive the notification.

A rapidly spreading fire in one residence hall, for example, wouldn’t necessitate warning the residents of another hall across campus unless it were likely to spread there.

The process for determining the content of the notifications and actually initiating the notification system must also be disclosed. The institution must disclose whether or not it uses a single office or position or a consultation process. It is recommended that a backup decision maker, such as an on-duty shift commander if the police chief is the main decision maker, be selected as well.

This should also address the various channels, such as text messaging and public address systems, that may be used, as well as how information will be shared with the greater community, including parents.

The titles of persons or the organization or organizations responsible for making each of these decisions must be disclosed. More than one process may be used, but all must be disclosed.

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