K-12 Safety Center Shares 7 Recommendations for School Emergency Operations Plan

The TxSSC audit found that only 67 Texas districts—out of 1,022—had sufficient EOPs, meaning they met best practices, state mandates, and had items such as: a basic plan, hazard analysis, communicable disease annex, and a continuity of operation plan, among other core components.  

“Having a plan that is actionable and accessible to adequately address disasters or emergencies is vital to the sustainability and wellbeing of each district,” according to the report. To accomplish this, the EOP must address all five phases of emergency management. This includes prevention, mitigation, preparation, response, and recovery efforts. The district must also practice through drills and exercises, taking lessons learned to assess and improve the EOP. 

Each Texas district is required to have one individual responsible for making final decisions during emergencies. In their review, the TxSSC found that 304 Texas districts do not meet this requirement. “During a disaster or emergency, it is imperative not only to know who has the final decision-making authority, but for these individuals to be available,” the report states. 

The center recommends schools designate a primary, secondary, and tertiary individual for this role. Kevin Burd, a 23-year police veteran and owner of Priority of Life Training and Consulting, advises schools to follow this best practice. He notes that some designated team members may be unavailable to assist in the emergency response, whether that’s because they are out sick for the day or injured in the crisis. The designees and their information should clearly be included in your EOP.    

Schools with campuses within 1,000 yards of a railroad track are required to have a train derailment protocol. There are 545 Texas districts that must follow this law, but an overwhelming 305 of them do not have a policy, and therefore, do not comply. The report notes that train derailments are rare, but “the types of cargo involved, such as hazardous material and overall nature of a train derailment, make this a hazard that poses significant risk.” 

This recommendation further shows how important it is to understand the risks and hazards that are unique to your school. It also signifies how critical it is for schools to understand laws that affect their districts and work with school safety experts who can help them stay in compliance.  

An active shooter is a very difficult incident to consider, so some schools simply choose to delay thinking about it. Some schools have the mindset of, “well, this won’t ever happen at my district.” These teams then fail to prepare for the worst-case scenario. The reality is an active shooter or violent intruder can happen anywhere at any time.  

In their review, the TxSSC found that over 625 districts do not have an active shooter policy in place. These districts are severely risking the safety of their students, staff, and community members. Without a plan—and without practicing—it makes it very difficult for anyone in the school to know how to respond and ultimately save lives. 

A hazard analysis is what makes the EOP unique to each school. “Creating an EOP without a hazard analysis renders the EOP ineffective,” the TxSSC says. “Essentially, the district would only have a basic EOP structure without assessing the critical information that truly informs the content.” 

The review found that 284 districts have not completed a comprehensive analysis, and of those that did, nearly 200 of them were determined to be insufficient. Some examples of insufficient analyses were schools that simply copied and pasted example templates without tailoring it to their specific school needs. 

A Continuity of Operations Plan (COOP) is “a plan that provides the best opportunity to continue operations during an emergency or disaster and during the recovery period afterwards.” 

Over 510 Texas districts do not have a COOP and 241 have insufficient COOPs. A COOP is important, as we especially learned in the COVID-19 pandemic, to ensure that students and staff continue to receive critical resources during school closures. This includes things like meals, homework, equipment, learning opportunities, and mental health support. 

Communicable Disease Annex
In the early stages of the pandemic, many schools realized they were unprepared to address COVID-19’s impact. TxSSC recommends schools have a communicable disease annex (CDA) that details the decisions, communication components, and roles and responsibilities of addressing a disease outbreak or incident. This is ideally created before any incidents. “Taking these and many other items into consideration while not involved in an ongoing response action is extremely beneficial for districts.” 

At the time of the report’s release, 423 districts do not have a CDA, even two years after the COVID-19 pandemic began.