Although the basic Incident Command System (ICS) is taught across emergency response disciplines, several shortcomings and constraints could lead to its downfall. Training for ICS is not a one-time occurrence, but should be an ongoing process of expanding knowledge, exercising skills, and passing on these abilities for the benefit of future generations.
Following the 9/11 terrorist attacks, the National Incident Management System (NIMS) was promulgated by the issuance of Homeland Security Presidential Directive 5 (HSPD-5) on 28 February 2003. The purpose of HSPD-5 was, “To enhance the ability of the United States to manage domestic incidents by establishing a single comprehensive national incident management system.” With the adoption of the Incident Command System (ICS) as a cornerstone, HSPD-5 states that, “To provide for interoperability and compatibility among federal, state, and local capabilities, the NIMS will include a core set of concepts, principles, terminology, and technologies covering the incident command system.”
Initially published in March 2004, Appendix B of the NIMS doctrine specifically delineates the ICS for use with “a broad spectrum of incidents, from routine to complex, both naturally occurring and manmade, by all levels of government – federal, state, tribal, and local – as well as nongovernmental organizations, and the private sector.” This appendix adds the following “transitional steps” that are needed when applying ICS to an incident environment:
Recognize and anticipate that organizational elements may need to be activated and take the necessary steps to delegate authority, as appropriate
Establish and position incident facilities to support field operations as needed
Establish common terminology for organizational elements, position titles, facilities, and resources
Develop a written incident action plan
Shortcomings & Constraints
Despite significant strides in training in the fundamental nuances of the ICS since 2004 – and thousands of people completing this training – there appear to be shortcomings or constraints in these efforts, which include: limited training for sufficient numbers of personnel; atrophy of knowledge, skills, and abilities; lack of succession planning; and ongoing distrust for ICS.
One of the first challenges is the inability of some personnel to recognize and/or anticipate the need to activate organizational elements when assessing an incident’s potential. The core ICS training curriculum provides students with an array of terminology related to functions, positions, facilities, and actions. However, little attention has been given to developing the students’ ability to recognize an evolving situation in which more formalized implementation of the ICS should be undertaken.
Simply put, the average student of ICS learns about what ICS is, but not so much about when to use it. Although it could be argued that ICS should be employed all the time, in reality, only the core functions can be employed routinely. There are fewer instances to staff most of the other positions within the ICS organization. Exactly when to transition from routine operations to more urgent conditions – and designate personnel to serve in positions such as incident commander, operations chief, and planning chief – remains unclear.
Second, the number of personnel trained in intermediate (ICS-300) and advanced (ICS-400) ICS are inadequate to ensure that trained and experienced staff will be available to assume the leadership roles needed for many instances. Dating back to around 2005, most agencies at all levels of government – as well as nongovernmental organizations and private sector response support organizations – undertook extensive efforts to provide introductory and basic ICS (ICS-100 and ICS-200) and intermediate and advanced ICS for supervisors and managers, which is often subject to agency leadership’s definitions of these roles.
However, over the past several years, less attention has been focused on maintaining or upgrading training or on providing opportunities for new personnel to develop experience as they replace those who have moved up or moved out. There appears to be inadequate succession planning to maintain minimum skill sets for ICS among personnel who are moving into positions requiring intermediate or advanced ICS training.
Additionally, training for personnel who will serve in specific command and general staff functions has been secondary. With the exception of local, regional, or departmental organizations that elect to establish an incident management team, a majority of personnel who complete ICS training stop training once they complete ICS-300 or ICS-400. This shows that there is less focus on performance competencies in functional responsibilities than on federal stipulations to adopt NIMS.
Limited Training to Manage Civil Unrest
One report highlights these issues: “Recommendations for Enhancing Baltimore City’s Preparedness and Response to Mass Demonstration Events (Based on a Review and Analysis of the Events of April 2015),” which was prepared by faculty and staff at Johns Hopkins University in Baltimore. In this report, a number of deficiencies regarding the city’s training, application, and use of ICS were identified, including Recommendation 2.4, which states:
“BPD [Baltimore Police Department] personnel deployments during mass demonstration and critical incident response should utilize fundamental ICS principles governing chain of command, including span of control and unity of command. BPD should continue to enhance its ICS capabilities through more training and through more frequent utilization of ICS principles in routine incident management. BPD should also continue to develop the ICS capabilities of its senior leadership personnel.”
In the rationale for this recommendation, the report noted:
“While incident management in general is not a forte of police departments, ICS principles and training would facilitate BPD’s management of multiple-officer response incidents on a daily basis. Not only would it be an effective, systematic approach for those incidents, this daily practice will familiarize personnel with ICS concepts and procedures and strengthen response capacity and efficacy during larger incidents.”
Another report, “Lessons Learned From the 2015 Civil Unrest in Baltimore,” issued in September 2015 by the Police Executive Research Forum, stated that:
“Many of the key individuals who had practiced specific ICS positions were assigned to the Freddie Gray Investigation Task Force, leaving vacancies in key spots in the structure. As a result, individuals who had never practiced a particular role as a prime or as a backup were learning it throughout the unrest.”
Based on these observations, one might surmise that the large-city (population 641,000) Baltimore Police Department did not train a sufficient number of supervisory personnel in the concepts or principles of ICS to ensure adequate personnel reserves with the training or experience to assume command and/or general staff functions during the incident(s).
Law Enforcement Lessons in Virginia
Bristol, Virginia, is a small city (population 17,750) having a police department with a full-service force of 56 sworn officers and 21 full-time support personnel (compared to Baltimore’s nearly 4,000 uniformed/sworn and civilian staff). Darryl Milligan is a captain with the department. During a December 2015 discussion with Milligan, he offered several observations. First, he noted that resistance to ICS training might be “a more prevalent problem in large agencies than small agencies.”
In an era of specialization, departments with large staff rosters may have the ability to designate or assign personnel for specific tasks or functions, including implementation of ICS. Given this philosophy, they may train a full cadre, including reserves. Alternatively, they may determine that, since an ICS-type incident is relatively rare, training will be limited to a small cadre to allow more personnel to be trained in other departmental tasks or functions that are deemed higher priorities. An agency the size of the Bristol Police Department does not have the “luxury” of assigning personnel to special assignments. Consequently, personnel must be cross-trained and qualified in multiple disciplines, tasks, or functions.
Milligan also added, “Police officers in general are brought up through their career being taught to get to the problem and handle it.” Most law enforcement officers are conditioned to take immediate action based on visible, audible, and other clues at that moment. This conditioning certainly merits respect because the typical police officer responds alone and cannot rely on others for immediate assistance in urgent situations. The ICS is often perceived as a slow and deliberate process. Thus, to some extent, law enforcement agencies may be less favorably disposed toward adoption and use of ICS, whether for routine or emergency situations based on the assumption that it will take longer to implement an incident command organization and process than to address the situation.
However, law enforcement agencies are, by no means, the only agencies that have encountered problems with the implementation and use of the ICS. Large and small departments have demonstrated or experienced shortcomings and constraints in applying or using the fundamental principles of the ICS.
Atrophy of Knowledge, Skills, and Abilities to Manage Explosion
On 17 April 2013, the West Fertilizer Company Fire and Explosion resulted in 15 fatalities, including 12 emergency responders, and more than 260 documented injured persons. The town of West is a relatively rural and remote community in Texas with an all-volunteer fire department. However, that department reportedly conformed to Texas fire service training standards including training in NIMS and ICS. In its final Investigation Report on the incident released in January 2016, the U.S. Chemical Safety and Hazard Investigation Board cited among its conclusions that, “Despite being trained for the ICS and NIMS process, none of the certified firefighters had prior practical experience in establishing incident command.” The report further stated that, “emergency response personnel who responded to the [West Fertilizer Company] incident did not take time to set up, implement, and coordinate an effective incident management system plan.”
That situation revealed another challenge to successful implementation of ICS that is often encountered, a “Good News–Bad News” situation. The good news is that, nationwide, the occurrence of major or catastrophic incidents is relatively rare. The bad news is the same. Hence, the opportunities to apply principles and practice skills associated with managing such incidents are rare. Therefore, even after receiving good training, many individuals’ knowledge, skills, and abilities atrophy from lack of application. In many cases, opportunities for review or practice (exercises) must be “manufactured” in order to maintain or improve an individual’s abilities in using the ICS.
Training in the concepts, principles, and protocols of ICS is only a small part of the process. What follows is often more important. After the training, trainees should be practicing – or exercising – to reinforce the training. Too often, once the training is completed, no further follow-on is provided. As has been said many times over the years, “If you don’t use it, you lose it.” This applies to ICS. Training should include ways for “reading the tea leaves” to identify indicators that a situation may escalate or expand to a significant extent. This training should be reinforced periodically. A minimum requirement for annual refresher training in ICS is just a start. At a minimum, an annual exercise should be conducted in which participants are given the challenge of identifying: (a) when an expanded ICS framework is needed; and (b) the appropriate steps and protocols to follow to establish that framework, given a realistic scenario.
Lack of Succession Planning & Ongoing Distrust for ICS
Finally, a potentially critical challenge to successful implementation and use of ICS in the future is simply attrition. NIMS is now 12 years “young.” Employees who were just starting their careers in 2004 are at or beyond the halfway mark in their careers. An employee who had five years of experience on the job in 2004 will likely be eligible to retire in three years. The math is relatively simple. The number of personnel who trained in ICS when it was first implemented will be moving up, moving on, or moving out in a short number of years (if they have not already done so). Plans must be in the works now for succession planning to ensure that an ample number of personnel are trained in ICS and given sufficient opportunities to reinforce, refresh, and strengthen their competencies – not only in establishing ICS for their needs, but in recognizing when it is needed.
In summary, although ICS is a valuable tool for managing significant incidents, attention must be focused on developing and extending training for enough personnel to ensure that adequate numbers of qualified and experienced personnel for potential needs are locally available. This includes addressing how to provide mechanisms for maintaining competencies, to ensure that succession planning is in place, and to remove any inherent misunderstandings and distrust in NIMS-ICS before a need arises.