What You Need to Know About Campus Emergency Drills: Compliance, Legal, Liability, and Operational Issues

Most campus administrators regard evacuation drills as a straightforward obligation on the school calendar. Activate the alarm; students file out bored; students file back in really bored; end of drill. A no-brainer, right?

Wrong!

Evacuation drills are a key element of your campus emergency response plan. Most campuses do not train or practice their plans with students, staff, faculty, and employees. Often, drills are the only operational exercise of your emergency response. This puts an enormous emphasis on the criticality of drills. Why? Because people respond the way they were trained, and untrained people panic or freeze.

What is a Drill?

Webster's defines a drill as: 1 a: to fix something in the mind or habit pattern of by repetitive instruction <drill pupils in spelling>

The objective of drills is to take a difficult or unfamiliar process and make it a habit by dint of repetition.

What Drills Aren't

Some want to believe that drills - even false alarms - are training. Drills are not training. No military, no emergency services, no state fire code, and no federal regulation or standard regarding emergencies recognizes a drill as training.

The proper sequencing of emergency preparedness is (a) create the plan; (b) train the plan; and then (c) drill the plan.

To train is to teach; to drill is to test.

Legal Definition of a Drill

Almost all state fire codes define a drill using The National Fire Protection Association's Standard 101 (NFPA 101®). The NFPA 101 defines the Life Safety Code® for all facilities including campuses. NFPA 101 states that your drills must include the following:

1. Require that all persons participate
2. Emphasize orderly evacuation rather than speed
3. Be held at expected and unexpected times
4. Simulate varying and unusual conditions that occur in actual emergencies
5. Be held with sufficient frequency to familiarize occupants with the drill procedure, and to have the conduct of the drill a matter of established routine. Almost all state fire codes require one drill a month when school is in session
6. Relocate to an assigned Assembly Area where occupants remain until recalled
7. Complete a written record of each drill.

Implicit in this definition is that you must have a headcount procedure that formally accounts for all personnel.

Now, let's add in federal law to these state requirements.

Every campus in the U.S. is under the jurisdiction of the Occupational Safety and Health Administration (OSHA). OSHA requires that every employer - your school - account for all employees during an emergency. Your headcount must include all employees, not just students.

So, the convergence of state and federal law requires that you must include in your drills every person on campus. Drills must not be focused just on students.

Let's break down what state and federal law requires of your school:

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