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Board of Governors of the Federal Reserve System
DATE: September 27, 2013
TO: Melissa Heist, Associate Inspector General for Audits and Evaluations
FROM: Michell Clark, Director, Management Division /signed/
CC: Don Hammond, Chief Operating Officer
SUBJECT: Response to OIG Draft Report of September 10,2013, The Board Should
Improve Procedures for Preparing for and Responding to Emergency Events
We appreciate the opportunity to comment on the draft report of the OIG's review of the
Board's policies, procedures, and communications protocols for responding to unexpected
emergency events. Thank you for the time and effort that OIG has afforded this important
I have discussed the draft report and its recommendations with Don Hammond, COO, and
Management Division staff including David Capp, Deputy Director, Management Division;
Curtis Eldridge, Chief, Law Enforcement Unit; Tim Markey, Manager, Board Internal
Communications; Katherine Perez, Assistant Chief, Law Enforcement Unit; and Andrew
Rahaman, Ed.D, Manager, Safety and Emergency Preparedness Bureau. Below are the
Management Division's responses to the seven recommendations to the OJG Draft Report.
OIG Finding 1: Drills and Exercises to Prepare for Emergencies Did Not Incorporate All Components of the OEP
Recommendation 1: Require the Crisis Leadership Team to convene in evacuation drills, regardless of duration.
The Crisis Leadership Team (CLT) currently participates in all emergency drills. However, we do not believe it is practical or even feasible for the CL T to muster in a single location for all drills or emergencies, particularly for events at New York A venue or International Square.
The Law Enforcement Unit (LEU) and the Crisis Support Team (CST) are able to utilize the emergency blast dial conferencing system to coordinate its efforts with the CLT members. As such, CL T members will be advised to muster for drills in their designated areas or an alternate location, and those who are unavailable to convene in a single location will participate via blast dial.
It is the COO's role to convene the CLT when he determines that decisions concerning lengthy building evacuations are required. We are currently discussing several drill options 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 COO to develop an annual program that includes the opportunity for the CLT, CST, and other groups to participate in emergency exercises.
Recommendation 2: Develop a Board policy for approval by the Executive Committee of the Board that requires each division to account for employees immediately after drills and emergencies.
We concur with this recommendation with modifications. A written employee accountability procedure has been finalized by Human Resources. The Deputy Director responsible for Human Resources will present this document to the Management Division Director as a policy recommendation and we will follow the Board's normal approval process. The Executive Committee of the Board (ECB) has the opportunity to review and provide input on new policies and procedures, but it is not a decision-making body. New policies and procedures such as this change will be approved consistent with the Board's Delegations of Authority.
Recommendation 3: Develop specific procedures for full-scale tabletop exercises, conduct tabletop exercises, and develop a formal process for reporting the results to the Executive Committee of the Board for review.
We concur with this recommendation. Tabletop exercises play a critical role in the preparedness process, and we currently incorporate these as part of emergency preparedness planning on an as-needed basis without a set schedule or reporting requirement. Pursuant to this recommendation, the LEU 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.
OIG Finding 2: The Floor Warden Program Has Recruitment, Training, and Retention Challenges
Recommendation 4: Provide records of completed floor warden training to all Board division directors and emphasize to them the need to have trained floor wardens to assist in evacuations.
We concur with this recommendation. The LEU Safety Bureau will develop a training compliance report specific to the floor warden program and disseminate that report twice annually.
Recommendation 5: Develop a Board policy for approval by the Executive Committee of the Board that requires Board division directors to:
a. recruit floor wardens from their divisions to fill floor warden vacancies.
b. enforce floor warden training compliance.
We concur with this recommendation. Policy codifying the floor warden program to include participation from each division and emphasize training will contribute to a robust emergency preparedness program. We will develop a policy that will apply to all divisions asking division directors to appoint adequate floor wardens and enforce training.
As noted in the response to Recommendation 3, the ECB is not a decision-making body, but will have the opportunity to, review and provide input on the new policy.
Recommendation 6: Ensure that the Law Enforcement Unit reconciles the floor warden roster with Board personnel records and Safety Bureau training records on a biannual basis.
We concur with this recommendation. Updates will be coordinated twice annually to coincide with the dissemination of the training compliance report referenced in the response to Recommendation 4.
OIG Finding 3: The Board Cannot Send Voice Announcements Simultaneously to All Employees in Leased Office Space
Recommendation 7: Establish a mechanism by which Board employees working in leased office space will receive critical information simultaneously and in a timely manner.
We concur with this recommendation. The Facility Services Space Planning Office is working with the design team for 1801 K Street to incorporate a stand-alone P A system into the buildout of the new space. We also will design and submit a proposal to incorporate installation of a P A system in the Board-occupied spaces of International Square.
In the interim, the LEU and Internal Communications will continue to utilize the group page; conference blast dial; and the e-mail and text message functions of the Twenty-First Century Communications system to disseminate emergency messages to the entire Board population. Additional options are being explored, such as the feasibility of a scrolling PC banner and/orthe use of the network telephone system.