The emergency response and evacuation regulations are intended to ensure that your institution has sufficiently prepared for an emergency situation on campus, that you are testing these procedures to identify and improve weaknesses and that you have considered how you will inform the campus community and other individuals, such as parents and guardians. The Clery Act requires you to disclose a statement of policy regarding your procedures in your annual security report along with your other security-related policy statements.
There is no prescribed manner in which to present the information as long as it’s accurate, complete and understandable. You can use lists, flow charts, maps or other means to describe what you do in emergency situations. The important thing is that you say what you do and do what you say. Just one of the components that your emergency response and evacuation procedure statement must include is your procedures to test the emergency response and evacuation procedures on at least an annual basis.
The Clery Act regulations define a test as regularly scheduled drills, exercises, and appropriate follow-through activities, designed for assessment and evaluation of emergency plans and capabilities. You MUST conduct at least one test a year and you can choose to announce it or not announce it. To comply with the Clery Act requirement the test must meet all of the criteria in the definition. It must:
Be scheduled. You cannot say that an actual emergency situation or a false emergency alarm served as a test of your institution’s procedures.
Contain drills. A drill is an activity that tests a single procedural operation (e.g., a test of initiating a cell phone alert system or a test of campus security personnel conducting a campus lockdown)
Contain exercises. An exercise is a test involving coordination of efforts (e.g., a test of the coordination of first responders, including police, firefighters and emergency medical technicians)
Contain follow-through activities. A follow-through activity is an activity designed to review the test (e.g., a survey or interview to obtain feedback from participants)
Be designed for assessment of emergency plans and capabilities. This means that your test should have measureable goals. For example, “Everyone involved in the emergency response and notification procedures will understand his or her role and responsibility.”
Be designed for evaluation of emergency plans and capabilities. Design the test so that, using the assessments, you can judge whether or not the test met its goals. For example, “The evacuation process accounted for/did not account for the diverse needs of all members of the campus community.”
You have flexibility in designing tests. For example, you may Conduct a tabletop exercise (i.e., a simulated scenario) or conduct a live test. Whichever method you use, your test must address emergency response and on a campus-wide scale. “Campus-wide” scale means that tests must address your plan for evacuating all of your campus buildings. This does not mean that your plan must involve evacuating the entire campus at once. Just have a plan for each building. A shelter-in-place contingency might be the best procedure to use in certain circumstances when evacuation is not a reasonable option.
Schools must also publicize its emergency response and evacuation procedures in conjunction with at least one test per calendar year. This part of your statement addresses how your school “gets the word out” about its emergency procedures. Time the publication to coincide with one test every calendar year. You may conduct more tests and you may publicize your procedures along with other tests, but you aren’t required to do so. Use a method that will attract attention to the information you’re disseminating; don’t make people search for it.
Sending a “blast” e-mail or text message containing a link to your institution’s procedures would suffice; however, simply posting a notice on your school’s website would not.
Finally, you must document, for each test, a description of the exercise, the date, time and whether it was announced or unannounced. Although the law requires only one test each year, if you have multiple tests in a year, you’re required to document each one. Be sure to address each component:
– A description of the exercise (i.e., the test).
– The date the test was held.
– The time the test started and ended.
– Whether the test was announced or unannounced.
As with all other Clery Act-related documentation, your institution is required to keep emergency test documentation for seven years.
Find a Sample Procedure for Testing Emergency Response and Evacuation Procedures in The Handbook for Campus Safety and Security Reporting at http://www2.ed.gov/admins/lead/safety/handbook.pdf
This handbook was developed by the U.S. Department of Education to present step-by-step procedures, examples, and references for higher education institutions to follow in meeting the campus safety and securityrequirements. It contains many sample policy statements and a checklist for Campus Safety and Security Compliance.