Originally intended to bring greater transparency to campus crime reporting, especially around crimes against women, that law has been expanded in the decades since its inception. It now contains substantial language compelling schools to organize and document specific plans for issuing timely warnings and emergency notifications.
The Clery Act applies to some 6,000 colleges and universities that participate in federal financial aid programs. With the release of its latest handbook, the Department of Education says it is looking for these schools to take their emergency planning beyond the historic norms of academia.
“For years there wasn’t much activism on campus and so schools stopped planning for those issues. Now we look at Occupy Wall Street and we see those things are back on the table,” said James Moore, senior adviser for Clery compliance and campus safety operations in the Department of Education.
“Some schools haven’t really thought about things like pandemic flu and how you would deal with 10,000 sick kids on your campus. And then there are things like terrorism, but not in the traditional sense: We have schools that do animal research, and that is potentially a target,” he said. “We want to make sure that schools are thinking about all of this on a larger scale.”
Around the nation, emergency managers at both large and small schools say they are taking the big view. They’re using the Clery handbook as a springboard to hone their emergency communications plans and also as a means to deepen ties with emergency leaders in their surrounding communities.
The Clery Act doesn’t say when or how a campus emergency team should initiate critical communications. It doesn’t lay out the precise scenarios that might require a timely notification or prescribe specific means for reaching out to students and faculty. All it says, in effect, is that campus leaders need to have a well documented plan.
At the University of Massachusetts Amherst, that plan rests largely in the hands of Jeffrey Hescock, director of university emergency management and business continuity for Amherst and four other UMass campuses. While Hescock uses an emergency text notification system powered by Rave Mobile Safety software, he said the technology is not the most important piece of the emergency communications puzzle.
“The texting is great, but you also have to have the plans and procedures and protocols behind it,” he said. In most cases his emphasis is on timeliness, a process that ensures emergency messages don’t get held up by bureaucratic roadblocks. That means ensuring frontline campus police dispatchers are authorized — and trained — to call a general alert. “We make sure we can get that message out as quickly as possible and not have multiple layers of people needing to review it.”
Having the policy is great; having it documented, as per the Clery handbook, is even better. “We are big on standards — accreditation standards, best practices. We see a tremendous value in having a document that spells out clearly: Here is what we are going to do,” Hescock said. “Going through that exercise helps us to define our processes even better.”
AT A GLANCEThe Clery Act requires that campuses have documented plans for issuing both emergency notifications and timely warnings. What’s the difference?Emergency Notification Scope: Wide focus on any significant emergency or dangerous situation Why: Triggered by an event that is currently occurring on or imminently threatening the campus. Initiate emergency notification for any situation involving an immediate threat to the health or safety of students or employees. Where: Applies to situations that occur on campus. When: Initiate immediately upon confirmation that a dangerous situation or emergency exists or threatens. Timely Warning Scope: Narrow focus on Clery crimes Why: Triggered by crimes that have already occurred but represent an ongoing threat. Issue a timely warning for any Clery crime committed on campus that is reported to campus security authorities or a local law enforcement agency and is considered by the institution to represent a serious or continuing threat to students and employees. Where: Applies to crimes that occur anywhere on Clery geography. When: Issue a warning as soon as the pertinent information is available. Source: Handbook for Campus Safety and Security Reporting |
Her team pulled the alarm in early June during a severe weather event. While the heavy winds and dangerous thunderstorms hadn’t reached the Twin Cities yet, the timing looked bad, with the storm due to arrive just as people were leaving work. “It was coming in fast and coming in hard. We knew there would be downed trees and power lines,” Dressler said. “So even though it didn’t meet the threshold for an emergency in terms of wind severity, which is what we would normally use, we still wanted to get that message out.”
The incident went smoothly, with students, faculty and staff all alerted to seek shelter and keep themselves informed. It’s the kind of thing Dressler plans for all the time, and she said the Clery requirements help her to lay those plans. “As part of the annual planning process my emergency management team will cross-reference what we are doing to the new handbook as well as to all of our other requirements. We’ll make sure that we are collecting that information and rolling it into our already existing plans,” she said. “It is all part of the same continuous improvement process.”
At the Washington State University campus in Pullman, meanwhile, Director of the Office of Emergency Management Michael Gaffney casts a wide net to ensure he can get the word out to the roughly 28,000 individuals who populate the campus at the height of the school year.
Try to log into the main university portal for things like registration and finances, and you’ll be redirected to a site asking you to first choose your preferred mode of emergency contact. For those who don’t get pulled into the system this way, Gaffney also reaches out via the all-campus email list. He can push emergency messages on the university’s apps that normally deliver bus information and campus maps, and there’s also an emergency alert website. Miss all that, and there are still the loudspeakers and the sirens.
The annual review of Clery compliance gives Gaffney an opportunity to run through all these outreach efforts afresh. “The minimum threshold level is compliance, but we want to know: Can we provide even better information? Do we learn lessons from our tests that ought to be captured?” he said. In fact, yes. In one recent test of a confirm-receipt function, his team found that students, more so than faculty, needed to be sent test messages more than once in order to gain their attention. Now he’s adding follow-up notifications into the broader warning procedure.
At the same time, Gaffney is working closely to communicate those changes to local emergency managers in the community. Campus emergency managers, along with their peers in city and county positions, agree that the Clery requirements can form a helpful foundation for their collaborative planning and communications efforts.
When Gary Jenkins took over as the Pullman, Wash., police chief and emergency management director in 2010 the city’s emergency plan had just been rejected by FEMA as insufficient. As he set out to reformulate it, Jenkins saw that despite its massive population base, the university had never been effectively included in the city’s emergency plan: In fact, the two had separate emergency plans.
As Jenkins set out to improve that situation, he found in the Clery Act a helpful ally. “Because of the requirements the schools have, they had a lot of things already put together, so that we just had to reformulate in terms of how FEMA wanted them to look, and that could then be the basis of our plans,” he said.
The cooperative planning proved so effective that the city and surrounding county eventually joined the university’s contract for emergency communications services. The Everbridge system allows university emergency leaders to send high-volume text, email and telephone notifications. As co-users on the same contract, city and county emergency managers can reach across in support of one another. “Each of the emergency managers for each of the entities has the ability to send an emergency notification to anyone on the system,” Jenkins said. “So if my staff or I were not available to send an emergency notification for whatever reason, one of the others could actually do it for me.”
That level of closeness makes sense to Gaffney. “Anything that affects us is likely to have an effect on the city and the county,” he said. As of mid-June the school’s Board of Regents, the City Council and County Board of Commissioners all were in the process of reviewing a first-ever joint emergency management plan. Gaffney said Clery’s documentation requirements were instrumental in bringing all the players together.
“The process of having to work out the details, to get it all written down, is really important. It requires strategic and tactical agreement on how things must and will operate between principle players,” he said. “And now, if the personalities change, if there is a new mayor or a new City Council member, we won’t have to repeat all of that process. We have the documentation as a starting point.”
While these Minnesota and Washington campuses may dominate their local scene, with their tens of thousands of students, faculty and staff, these same town-and-gown issues play out at smaller colleges as well.
Take for instance Michigan Technological University: With its 7,000 students, mostly non-residential, it’s located on the farther reaches of Michigan’s Upper Peninsula, some 10 driving hours from Detroit. While it may seem remote, this small school has many of the same cares as its big-city siblings.
“If there is an armed intruder, a hostile intruder, if there is a fire or a chemical spill, we plan for all of that. We have written scripts for bomb threats, hostile intruder,” said Jennifer Donovan, who as part of the public affairs team on campus also serves on the incident command team. “After Virginia Tech, campuses really started paying attention to all of these things. That was when our incident command team was developed.”
One of her team’s roles is to share what it knows with those off campus, supported in part by the Department of Education handbook. “It keeps us all on the same page. When we talk about what is required of us, our county emergency management people can see exactly what we are doing and why. The fire and police and ambulance people can see what viewpoint we’re coming at it from,” she said.
The Clery Act’s emphasis on communications has been especially helpful in allowing the school to work out crisis response protocols with the surrounding health-care community. “If we have an emergency that involves injuries or fatalities, we have to work very closely with the hospital on who tells the media what,” Donovan said. “So it helps to have that written policy that says what we are going to do. Then we don’t have to figure it out on the fly.”
Others point to the specificity of language as a boon. “It’s the difference between ‘lockdown’ and ‘shelter in place.’ A high school will use the terminology ‘lockdown,’ because it is just one or two buildings with controlled access — one way in and one way out. A campus like ours with 352 buildings, there is no button to push to lock that down. So we talk about sheltering in place,” Hescock said.
That can matter to an outside responder arriving on scene. “They need to know whether all the doors are going to be locked when they get here or whether those doors will be open,” he said. With help from the school’s Clery compliance, “that’s something they can know before they get here.”
As the new security handbook begins to circulate, Moore at the Department of Education said he is hopeful that city and county emergency leaders will engage with the document, using it as a springboard to strengthen emergency planning both for themselves and for their local colleges and universities.
“If you look at a small liberal arts college, a lot of them have never had to go through the steps. They may have a very small police force. They don’t know where their closest Level 1 trauma center is because they have never thought about it,” he said. “If that county or city emergency manager knows that, they might be able to help that campus emergency manager to fix the hole. Then they can bring the schools into their larger programs to make sure there are seamless connections between the plan for the large community and the plan for the school.”
