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Board Report: 2013-AE-B-016 September 30, 2013
Our objectives were to evaluate the Board of Governors of the Federal Reserve System's (Board's) policies and procedures for responding to unexpected emergency events and to assess communications protocols for processing and disseminating information to Board staff during such emergencies.
The Board has a crisis management structure in place and procedures to prepare for and respond to emergency events. Key components of the crisis management structure are the Crisis Leadership Team (CLT), which ensures the continuity of Board operations and essential functions, and the Crisis Support Team (CST), which manages the actual emergency. During an emergency, the Law Enforcement Unit (LEU) Chief, serves as the CST lead and incident commander. Floor wardens assist the LEU during emergencies by ensuring that employee evacuations are quick, orderly, and safe. The LEU's Safety and Emergency Preparedness Bureau (Safety Bureau) performs considerable planning and other activities to prepare for emergencies, including conducting annual floor warden training. The Safety Bureau also prepares the Board's Occupant Emergency Plan (OEP), which describes the roles and responsibilities for employees, contractors, and visitors, as well as the responsibilities for components of the crisis management structure.
We found that drills and exercises to prepare for emergencies did not fully incorporate all components of the OEP. The CLT did not convene during drills to make critical decisions to ensure that Board operations and essential functions continued with minimal disruption, and employees were not fully accounted for after the drills. In addition, tabletop exercises, an emergency preparedness best practice, were not routinely performed, because there is no requirement to perform such practices. Incomplete drills and the absence of full-scale tabletop exercises to supplement the drills decrease the likelihood of appropriate responses to emergencies.
In addition, we found that the floor warden program has challenges with respect to recruiting and retaining volunteers, and floor wardens are not completing annual training. As the program is currently functioning, the Board lacks assurance that there will be a sufficient number of trained floor wardens available during actual emergencies to assist in the safe, orderly movement of employees, including those who require assistance due to physical limitations.
Finally, we found that the Board does not have the ability to send public address announcements to employees working in leased office space because the buildings lack such a system. Employees may receive crucial information via telephone, intranet, e-mail, text, or word of mouth. This limitation increases the risk that employees may not receive the appropriate instructions simultaneously and in a timely manner and may make uninformed decisions that could place them in harm's way.
We made seven recommendations to improve the Board's emergency preparedness. We recommend that the CLT convene during evacuation drills, employees be accounted for after an emergency, and full-scale tabletop exercises be conducted as an additional training tool. We also recommend that floor wardens complete annual training, division directors be required to recruit floor wardens, and that the floor warden roster be kept up to date. Finally, we recommend that all Board employees working in leased office spaces receive critical information simultaneously and in a timely manner. In comments to a draft of our report, management generally concurred with our recommendations.