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We found that drills and exercises designed to practice appropriate emergency responses need improvement. All of the drills that we evaluated did not fully incorporate all components of the OEP. The CLT did not convene during drills to make critical decisions regarding Board operations and essential functions because the CST did not advise it to do so. Further, the OEP requires Employee Relations to collect and reconcile accountability for all Board employees immediately following an emergency; however, employees were not accurately accounted for after drills because there is no official procedure explaining how that accounting should be accomplished. Finally, although the OEP does not require the Board to engage in tabletop exercises to prepare for emergencies, we have identified such exercises as a best practice. Incomplete drills and the absence of full-scale tabletop exercises to supplement the drills decrease the likelihood of appropriate responses to emergencies.
The CLT members did not convene during any of the four evacuation drills conducted during our review period. Drills were conducted in May 2012 at each of the three Board-owned buildings, and another evacuation drill was conducted in October 2012 in the building where the Board leases workspace for over 650 of its employees. We found that the CLT did not convene during any of the evacuation drills because the CST did not advise it to do so. Members of the CST stated that during the October 2012 evacuation, the CLT was not advised to convene because the drill was unannounced and of such short duration that there was insufficient time for the CLT to convene. We also found that the four newest members of the CLT have never convened during a full-scale evacuation drill. To increase the effectiveness of the Board's evacuation drills, the CLT should convene during these exercises so it will be better prepared to assess the Board's ability to continue essential functions in the event of a real emergency.
Employee Relations did not perform a full accounting of employees who were on duty during the 2012 drills. In addition to the floor wardens' responsibility for ensuring that offices and conference rooms are evacuated during emergencies, an accounting of employees helps assure the CST that all who were in the building prior to an evacuation or a shelter in place are safe. According to the OEP, Employee Relations should account for Board employees immediately following any evacuation or shelter-in-place event and report the information to the CST. Employee Relations relies on representatives within each Board division to confirm that their employees are accounted for, but it has not developed formal Board-wide procedures specifying how the representatives are to report this information.
The Safety Bureau's evaluation of the May 2012 evacuation drill identified the accounting for employees as an ongoing problem and stated that the issue was being addressed by the LEU, the Safety Bureau, and Employee Relations. Similarly, in its evaluation of the October 2012 evacuation drill, the Safety Bureau reported that Employee Relations did not receive headcounts from three Board divisions. The report noted that one division was unaware of its responsibility to provide this information and did not specify why the two other divisions did not provide an accounting. The Safety Bureau stated that it planned to conduct a follow-up meeting with Employee Relations to determine the status of the accountability procedure.
Evacuation drills reinforce employees' awareness of evacuation routes, emergency exits, and safe assembly areas. These drills also provide the Safety Bureau an opportunity to evaluate the evacuation process and make suggestions for improvement to the CST and others within the crisis management structure. Industry best practices suggest that conducting full-scale evacuation drills is an effective means of preparing staff for emergencies. To increase the effectiveness of the Board's evacuation drills, formal guidance on conducting and reporting headcounts immediately following emergencies should be issued to all Board divisions.
The Board does not routinely conduct full-scale tabletop exercises, and there is no formal reporting protocol designed to notify senior leadership of the results of such exercises. Tabletop exercises are scenario-based discussions among crisis management personnel and other emergency preparedness staff about the various types of potential threats and unexpected emergencies. Each of the three Reserve Banks we visited conducts tabletop exercises periodically as a best practice to supplement its evacuation and shelter-in-place drills and to evaluate readiness for a comprehensive list of emergency scenarios, including an office fire, a violent protest, a disgruntled armed tenant, a water main break, a fuel spill, a bomb threat, or a chemical or biological attack. At the conclusion of these exercises, Reserve Bank emergency preparedness personnel prepare a written report and submit the results to senior officials and managers. The Board could improve its emergency preparedness by adopting tabletop exercises as a best practice and submitting the results to the Executive Committee of the Board for review.
We recommend that the Chief Operating Officer
We recommend that the Director of the Management Division
The Director of the Management Division's response addressed the intent of recommendation 1. In his response, the Director stated that the CLT currently participates in all emergency drills and does not believe it is practical or even feasible for the CLT to muster in a single location for all drills or emergencies, particularly for events at New York Avenue or International Square. The Director also indicated that it is the Chief Operating Officer's role to convene the CLT when he determines that decisions concerning lengthy building evacuations are required. The Director indicated that several drill options are under discussion that would involve partial mustering of the CLT depending on the location, severity, and Board impact of a scenario. In addition, the Management Division will coordinate with the Chief Operating Officer to develop an annual program that includes the opportunity for the CLT and other groups to participate in emergency exercises.
The Director of the Management Division concurred with recommendation 2, with modifications. The Director stated that a written employee accountability procedure has been finalized by Human Resources. The Deputy Director responsible for Human Resources will present this document to the Director as a policy recommendation for approval consistent with the Board's delegations of authority.
The Director of the Management Division concurred with recommendation 3. The Director indicated that the Safety Bureau will develop a tabletop exercise program to include an annual schedule of events as well as a process and parameters for reporting exercise findings. This program will be designed to test the existing emergency plans, assist in the development of new or revised emergency plans, and focus on the operational response to unexpected incidents.
In his response to recommendation 1, the Director of the Management Division did not consider it practical or feasible for the CLT to muster in a single location. However, the Director agreed to develop an annual program that includes an opportunity for the CLT to participate in emergency exercises. This action addresses the intent of our recommendation.
The actions described by the Director are responsive to the recommendations in this finding. We plan to follow up on the Management Division's actions to ensure that the recommendations are fully addressed.