A Federal Agency's Journey to Protect Its Workforce From Infectious Diseases

From a presidential executive order to comprehensive workforce protection, the U.S. Department of Homeland Security’s infectious disease protection process is constantly evolving. The department’s centralized guidance/decentralized execution planning paradigm with reliance on a robust lessons learned process ensures an increasingly resilient workforce against biological threats and hazards.

Businesses and government agencies alike have the responsibility to protect their workforces from events that can endanger safety and imperil the continuance of the organization’s mission. This responsibility is especially true at the U.S. Department of Homeland Security (DHS) where the continuity of operations officials, occupational safety and health specialists, medical providers, and operational planners work daily to improve the department’s preparedness against all threats and all hazards. However, prior to 2009, DHS struggled to provide the department’s component agencies useful guidance for specific biological hazards due to the diverse missions and the legacy capabilities and processes brought to the department when it formed in 2003. As a result, DHS-wide contingency plans were sometimes too vague to provide robust guidance or provided an onerous “one-size-fits-all” approach that was ill suited to the complex missions and unique missions performed within the department.

However, by late 2009, DHS had a cadre of experienced planners and supporting subject matter experts able to execute DHS-wide planning initiatives. When Executive Order (EO) 13527: Medical Countermeasures Following a Biological Attack was promulgated by President Barack Obama in late 2009 directing federal agencies to protect their workforce from the threat of an anthrax attack, a cross-functional group of planners and subject matter experts from across DHS set in motion the development of a workforce protection planning paradigm that continues today.

Anthrax – The Beginning of a Major Planning Initiative

EO 13527 required federal agencies to provide a rapid federal response in the event of a biological attack using deadly aerosolized Bacillus anthracis (anthrax) bacteria. The EO directed planning efforts to augment state and local governments administering lifesaving medical countermeasure antibiotics and also included a requirement for medical countermeasures to be provided to federal personnel following an anthrax attack, so they can continue to perform the mission-essential functions of their agencies.

The EO set in motion a major planning initiative across the federal government to include agency-internal preparedness activities consistent with the EO and complementary interagency plans. However, the size, breadth, and semi-autonomous nature of the DHS’s component agencies made the adoption of a comprehensive and detailed workforce protection plan difficult to develop. DHS spent the first six months of 2010 preparing a comprehensive anthrax response plan that prescribed protective actions the department would take in the event of an aerosolized anthrax attack. However, the [Draft] DHS Anthrax Response Plan failed to gain the necessary consensus from DHS component agency leadership who felt the plan limited their ability to tailor anthrax protective actions to their unique processes, structures, and missions. As a result, the plan did not proceed beyond the departmental review cycle. 

The lesson learned from this experience was that a comprehensive and prescriptive workforce protection plan would not suit the 28 components of DHS and ~250,000 members of the DHS workforce with a one-size-fits-all approach to department planning. This created an impasse, where the need for detailed guidance to be compliant with the EO clashed with the component need for flexibility due to their unique missions.

In the summer of 2010, the Plans Division at DHS headquarters in coordination with the DHS Office of Health Affairs, Management Directorate, and others initiated a new approach to the problem. Rather than develop a detailed department-wide plan consisting of 40-50 pages of prescriptive guidance for all DHS components, the team developed a Department Guidance Statement that established the minimum anthrax attack planning and preparedness requirements for each component, and allowed each component to implement that guidance in a manner that best suited their situations and needs.

Development of the DHS Component Anthrax Operations Plans Department Guidance Statement took four months (approved by Secretary Janet Napolitano on 10 November 2010), but it set in motion productive anthrax planning within DHS components. Component implementation of the guidance statement was supported by the team that developed the statement, which subsequently led two week-long Anthrax 101 planning workshops in December 2010 and developed planning templates, verification matrices, and fact sheets relevant to the effort to facilitate compliance.

The anthrax effort was a success. By mid-2011 the entire DHS workforce was covered under either an anthrax annex to a component continuity of operations plan or a stand-alone anthrax operations plan. Most components opted to develop their own methods for meeting the requirements, but several components took advantage of the flexibility offered by the statement to develop more efficient and timely anthrax response procedures. For example, most of the DHS support components that constitute the department’s headquarters jointly developed the DHS National Capital Region Consolidated Anthrax Medical Countermeasures Plan for Select DHS Support Components. As a result, current measures to protect the DHS workforce from an anthrax attack include timely distribution of post-exposure medical countermeasures through established points of dispensing, which are exercised at least annually, and with plan revision efforts that occur biannually.

Pandemics & Emerging Infectious Diseases – A Hybrid Planning Approach

DHS has long prepared its workforce against the threat of emerging infectious diseases. The 2009 H1N1 influenza pandemic led DHS to develop, among other actions, a workforce protection plan focused on maintaining all its essential functions during the outbreak. The DHS 2009-H1N1 Implementation Plan:

  • Built upon existing continuity of operations planning and emergency preparedness activities across the department;

  • Leveraged plans developed for possible pandemic strains such as H5N1 influenza;

  • Provided further guidance specific to the H1N1 influenza virus;

  • Described how DHS was to prepare for this emerging disease and, as necessary, respond to it; and

  • Complemented guidance from senior DHS leadership that every DHS component develop a pandemic annex to their existing continuity of operations plan.

Fortunately, the 2009 H1N1 did not cause symptoms as severe or workforce absenteeism as high as predicted. As the pandemic waned and vaccine became available, this strain-specific plan became less useful. Despite a thorough internal after action review of the DHS response to the 2009 H1N1, many of the planning and preparedness recommendations were not completed by the time H7N9 influenza and Middle East Respiratory Syndrome Coronavirus (MERS-CoV) emerged in the spring of 2013.

The initial plan at DHS headquarters for the response to these emerging threats was to use the 2009 H1N1 plan as a guide to address the current situation. However, it was quickly realized that simply updating the old strain-specific plan for a new crisis did not allow for pre-incident planning and preparation for multiple potential diseases. Instead, a hybrid was developed.

Since almost all the planners, component subject matter experts, and biological subject matter experts tasked to develop the plan for MERS-CoV and H7N9 had previously contributed to the 2009 H1N1 and 2010 anthrax efforts, the planning team was able to quickly gain consensus regarding the general outline of a new plan. Spurred by the threat posed by MERS-CoV and H7N9 but informed by the 2009 H1N1 and 2010 anthrax efforts, DHS broadened the scope of the 2013 effort to cover all emerging infectious diseases. In addition, the planning team decided to adopt the same centralized guidance/decentralized execution paradigm developed for the Anthrax Department Guidance Statement and apply it to pandemic planning. However, the PWPP went a step further and included overarching coordination and messaging guidance for the department. The plan’s development, coordination, and staffing took four months and was approved on 10 November 2013.

To assist in the development of the component PWPP support plans, the planning team took a few actions from the past success with anthrax planning – for example, holding a planning workshop for all DHS components to discuss and explain the specific requirements contained in the PWPP. In addition, the Plans Division distributed a compliance matrix, which:

  • Listed planning and preparedness requirements and annotated where those requirements were delineated in the PWPP;

  • Distilled the PWPP requirements to a few pages, which served as a quick reference for the component planners; and

  • Benefitted both the planning team who performed the compliance review of the component plans and the senior leaders who needed a concise reference that explained both the PWPP requirements and how their respective components met those requirements.

Another major carryover from the anthrax planning effort was the development of a large multifacility plan for the DHS headquarters components co-located at facilities in the Washington, D.C., area. The National Capital Region Consolidated Pandemic Workforce Protection Plan for Select DHS Support Components retained the location-specific design and administrative procedures related to the points of dispensing included in the anthrax plan. However, this new plan was considerably more detailed to account for the greater complexity posed by unforeseen infectious diseases.

The National Capital Region Plan, like all support plans, included an assessment of infectious disease risk for the personnel covered under it. The assessments allow DHS components to determine the protective measures – which include workforce and workplace processes, personal hygiene reminders, social distancing, and personal protective equipment when other controls are impractical and ineffective – for every job type, employee, and those in the care and custody of DHS.

Coordination of Plans & Actions

To facilitate intra-departmental coordination, planning, and reporting, the PWPP included a requirement for DHS to stand up an Internet-based virtual collaboration portal for pandemic planning, operations coordination, and reporting on the DHS-administered Homeland Security Information Network (HSIN). Concurrent with the development of the various PWPP component support plans, the Plans Division built a password-protected portal to:

Share relevant unified meeting notes, taskings, reference documents, and templates;

  • Allow real-time incident information to be shared through existing reporting processes; and

  • Provide a one-stop-shop for pandemic planning and response, built at no extra cost or appropriation within DHS’s existing information sharing architecture.

The compliance review, follow up, and improvement planning for the PWPP component support plans also took a page from the anthrax effort. As the Plans Division had done successfully before, a detailed review of each component plan was conducted to provide feedback and assistance to component planners. The compliance matrix mentioned above was returned for each plan, which saved a substantial amount of time and reduced subjectivity and bias in the review.

Individual feedback was provided by the planning lead to the individual components regarding their plans, to include the specific best practices and recommended areas for improvement identified for the respective support plan. In addition, those best practices and an aggregated list of areas for improvement/lessons learned was prepared by the planning team for use by the component planners via the collaboration portal. The summary allowed the component planners to contact each other to share ideas and best practices, and it allowed senior DHS leadership to take the lessons learned for action and resolution.

Workforce protection and pandemic preparedness is an ongoing process that requires constant efforts to maintain not only the plans, but the actions guided by the plans. The PWPP requires yearly reviews of the component plans to ensure they remain consistent with new or existing guidance, and a yearly exercise requirement ensures the component offices validate their plans and protect their workforce well into the future.

Since 2009, DHS has increased its workforce preparedness for biological threats through a sustained planning effort that leverages best practices and lessons learned (see Table 1). As a result, DHS has a sustainable, constantly improving preparedness capability for all emerging infectious diseases. The department is better prepared and the DHS workforce is better protected from potential pandemic events and emerging infectious diseases.


Robert J. (Bob) Roller

Robert J. (Bob) Roller serves as the Federal Emergency Management Agency’s (FEMA) National Planning Branch Chief and formerly served as the Planning Division Director within the DHS Office of Policy. He is a frequent contributor to Domestic Preparedness, and the views expressed here do not necessarily represent the views of FEMA or the United States government.



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