The National Incident Management System (NIMS) and the National Response Framework are very important and overall well-constructed documents despite some past failures related to their implementation. However, one common denominator in disaster failures or successes is the people involved and the education and training of those personnel. Although federal mandates provide requirements for an initial certification, to date, no required refresher training exists. This article analyzes reasons that the NIMS Incident Command System (ICS) annual recertification should be required to maintain NIMS compliance.
At each level of government, emergency managers and responders have statutory responsibilities related to disasters. Each level of government has certain responsibilities that rely on the actions of other levels. This interconnected aspect of emergency and disaster management allows a failure at any level to compound to a failure at other levels. Hurricane Katrina in 2005 provided a great example of this compounding failure. The failure of the state of Louisiana was blamed on the Federal Emergency Management Agency’s (FEMA) tardiness, and FEMA stated it was awaiting decisions from the state. In 2015, NPR’s Maureen Pao described New Orleans Mayor Ray Nagin’s failures to have proper plans in place and execute them in a timely manner, thus creating the extent of the disaster. The disaster declaration process within the United States places the beginning of the response on the local government and, until the local government proves needs beyond their capabilities, the state does not provide assets. This is repeated at the state and federal levels, thus ensuring the management and resources for a disaster are provided by the lowest level of government possible.
Disaster Experience Levels
The federal government response system is made up of career employees that have varying lengths of time in their current positions, political appointees, and disaster assistance employees, as well as the potential for military personnel assigned to specialized Defense Support to Civil Authorities units, such as the Homeland Response Force. Each of these positions has varying lengths of commitment. Although the federal government should be well seasoned in disaster response, FEMA and other disaster agencies at the federal level do not respond in the early hours of an event and are often most associated with recovery efforts. This changed in the past few years under the direction of then FEMA Administrator Craig Fugate, but the emphasis is still on state and local governments to handle the response at their levels when possible.
At the state level, many career personnel within the state emergency management agency have many years of tenure and, as is the case in many state employment systems, time in grade is one of the biggest deciding factors to promotion. However, in many states, the state emergency management agency has many areas to oversee and has very few response personnel. In many cases, the response provided by the state is a coordination of other agencies and Intrastate Mutual Aid Compacts (IMAC), which brings emergency managers and responders from different areas of the state. Recently with the enhancements of national qualifications, Emergency Management Assistance Compacts (EMAC) are becoming more financially feasible for states. This system allows responders from neighboring states to provide response to the affected disaster area.
Local Level & Low Probability
This leaves the local level to provide the majority of the command and control, responders, and emergency management personnel for a disaster. A 2015 article, entitled “Comparing Collaboration Between the Fire Department and Emergency Management Agency to the Incident Command System,” found that the probability of a person at the fire department in the state of Ohio serving at a federally declared disaster in his or her current position was 0.0034. Although certain states are more prone to large-scale disasters, the majority of local responders and government officials are in line with this probability. Three factors contribute to this: (a) time in the position; (b) lack of regular disasters; and (c) use of NIMS/ICS outside of the fire department.
First, personnel remain in a certain position within the local government, specifically the fire department for only a few years. As the complete career time in many states is 20-30 years, a person who serves as fire chief for even a few years can only work through the ranks by remaining in any certain rank only a few years. The tasks and needed knowledge to fill positions at the various ranks vary greatly. For example, even if a person were to serve at a disaster as a company officer, his or her role as a fire chief would likely involve participation in the Multiagency Coordination System (MACS), which is an entirely different set of knowledge, skills, and abilities for success.
Second, the low probability of serving in a position at a federally declared disaster is due to a lack of regular disasters. According to FEMA’s disaster declarations, the year 2000 produced three federally declared disasters in the state of Ohio, but a typical year from 2001-2013 is only one or two, and no federal disasters were recorded in Ohio during a few years within that period. This lack of large-scale event experience prevents many of the concepts and structures discussed from the ICS-400 curriculum to be activated on a regular basis. Large-scale structures could be activated for smaller scale events or exercises, but the lack of familiarity tends to shy exercise designers and participants away from utilizing MACS, Unified Command, and/or Incident Complexes. Many exercise designers focus more on success of the participants based on their level of knowledge and experience with the NIMS/ICS than to push participants into a non-comfort zone to improve learning. This philosophy is understandable as discouragement can create apathy toward the system and defeat its implementation at lower level events, thus widening the knowledge and experience gap.
Third, although many fire departments utilize a pure NIMS/ICS or some slight variation, this is the only organization within the local government that likely utilizes the system on a regular basis. Because law enforcement officers often operate and arrive solo to events, there are not many instances to utilize NIMS/ICS. Other divisions and departments within local government do not have any daily use of NIMS/ICS outside of a few examples, such as the United States Park Police and Baltimore Mayor’s Office of Emergency Management’s use for special events. This creates a great deal of on the spot learning when any organization besides the fire department needs to utilize NIMS and its terminology. This can lead to communication errors and confusion during the first and most crucial hours of an event unless the local government regularly conducts drills and exercises.
The partial solution to the lack of use and knowledge retainment of NIMS/ICS is the implementation of an annual recertification course. This could be as simple as a 10-question pretest that adjusts the length of the re-certification course. For example, a correct score on 9 of 10 questions would result in the course only covering the information from the one item missed and increase to a full course depending on the number missed. A pretest would ensure that minimal time would be needed to refresh. This would also allow the after action reports of known issues to drive much of the curriculum.
Although the probability of needing enhanced ICS structures and systems is miniscule, examples show how the lack of competence in NIMS/ICS and the National Response Framework, as well as local disaster plans can have a devastating result that no level of government and resources can overcome. With the laws of the United States comes local control, but also local responsibility. Emergency and disaster management professionals must ensure communities are prepared.