New Campus Security Regulations from the U.S. Department of Education

The U.S. Department of Education yesterday published new federal regulations dealing with campus emergencies among other topics. The final regulations take effect on July 1, 2010 and implement laws enacted in 2008, including amendments to the Jeanne Clery Act adopted in the wake of the shootings at Virginia Tech and other campuses.

Section 668.46(e) of the regulations clarifies the difference between the existing timely warning requirement and the new requirement for an emergency notification policy. The regulations state that, “While a timely warning must be issued in response to specific crimes, an emergency notification is required in the case of an immediate threat to the health or safety of students or employees occurring on campus.”

The regulations distinguish between a timely warning notification and an emergency notification, which previously were often confused with each other. Campuses are not required to issue immediate (emergency) alerts if there is no immediate threat to the health or safety of students and employees. However, the institution must provide an adequate and timely follow up.

Section 668.46(g) of the regulations describes the elements an institution must establish and release in its annual security report:

- “Procedures to immediately notify the campus community upon the confirmation of a significant emergency or dangerous situation involving an immediate threat occurring on the campus.”

This is largely a restatement of the Jeanne Clery Act, amendment of August 2008. However, the regulations do go into more details.

- “A description of the process that (1) confirms that there is a significant emergency or dangerous situation, (2) determines the appropriate segment or segments of the campus community to receive a notification, (3) determines the content of the notification, and (4) initiates the notification system.” (emphasis added)

Not only is an institution required to confirm that there is a significant event, decide on the content of the notification and execute it, but they also must define an appropriate segment or segments of the campus community to receive a notification.

The most obvious difference is that while the Clery Act establishes the obligation to notify “the campus community”, the final regulations clarify that appropriate segment or segments of campus community must be notified.

It would appear as if the segmentation of the campus population is dictated by the emergency event, and both demographic and geographic segmentation is possible. It seems appropriate to notify the entire community via SMS, email and other personal notification channels in case of a weather emergency or other global events where the same message can relay clear information to the entire population.

However, isolated incidents such as shooter on campus require geographic segmentation of the campus community. Conceivably, people in the same building with a shooter might be advised to lock the doors and stay hidden, while people outside the building would be advised to stay away.

This point is reinforced in the new 2010 edition of the NFPA 72 code, which states that two tiers of communications are ideal for effective coverage. As an example, Tier 1 of In-Building Mass Notification Systems, or the immediate and intrusive alerting, includes sirens, LED signage and indoor/outdoor loudspeakers, or broadcast units.

An audible or visual notification issued to a geographic section or area is much more precise and efficient in situations where different groups of people must receive different instructions depending on their physical location.

You can read more about the NFPA 72, 2010 edition in this blog post, or on our website.

The U.S. Department of Education regulations also stipulate that not every emergency situation requires a mass notification. If the emergency procedures are being followed and it is determined by the responsible authorities to the best of their professional judgment that the notification would hurt the safety of a community, such notification does not have to be issued.

- “A statement that the institution will, without delay, and taking into account the safety of the community, determine the content of the notification and initiate the notification system, unless issuing the notification will, in the professional judgment of responsible authorities, compromise the efforts to assist a victim or to contain, respond to, or otherwise mitigate the emergency.”

According to final regulations the plan should also specify:

- “A list of the titles of the persons or organizations responsible for carrying out the actions required.”

- “Procedures for disseminating emergency information to the larger community.”

- “Procedures for testing its emergency response and evacuation procedures on at least an annual basis with at least one test per calendar year, and be documented, including a description of the exercise, the date, time, and if it was announced or unannounced.”

The regulations also specify the testing requirement of emergency response and evacuation procedures, which should be performed at least once per calendar year and be fully documented.

It would appear that the final regulations are consistent with a comprehensive layered approach to Mass Notification, where both geographic/area and demographic/personal notifications must be utilized to effectively reach the community in every emergency situation.

It will take time and effort to comply with the new law by the set deadline, but it is a change for a better and safer life on campus.

For further information refer to 42 CFR Part 668.

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This document is not intended to, and does not, constitute legal advice of any kind, and should not be relied upon as such. Readers are encouraged to contact their own counsel regarding such issues.

Copyright Talk-A-Phone Co., 2009. This material may not be published, broadcast, rewritten or redistributed without prior permission.

NFPA 72, 2010 Edition, Chapter 24: Mass Notification

With inclusion of the Mass Notification technology in the NFPA72: National Fire Alarm and Signaling Code, 2010 edition, it became clear that Mass Notification went mainstream. Now more then ever it is important to understand the strengths and weaknesses of each notification medium. Which ultimately leads to the question: how many notification layers should be utilized to adequately inform the entire population at hand?

The new NFPA 72 Chapter 24 is entitled Emergency Communications Systems (ECS). For the first time, the NFPA Code itself is dealing with issues of Mass Notification Systems, their design, installation and use, as well as their relationship with Fire Alarm Systems, which has historically been the main concern of NFPA.

NFPA also for the first time begins to deal with the issue of intelligibility of voice messaging, rather than just loudness. See for example:

• Section 24.3.1: “Designers and installers should understand the importance of a good distribution of speakers rather than a higher power output of a few speakers.”
• Section A24.3.1: In certain situations, it is important to provide a distributed sound level with minimal sound intensity variations to achieve an intelligible voice message. This differs from past fire alarm design practice that used fewer notification appliances, but with each having greater sound pressure output levels.
• Also see Annex D, Speech Intelligibility. Although it clearly states, “This annex is not a part of the requirements of this NFPA document but is included for information purposes only”, it is rather informative and may points a way to future Code changes.

NFPA allows the Fire Alarm system to be used for “Ancillary Functions”, as well as reversing the previous relationship between Fire Alarm Systems and Mass Notification Systems in the same building. Recognizing that having two audio messaging systems operating at the same time in the same area would make both unintelligible and virtually useless, in the past priority was always given to the Fire Alarm System. Now, however, depending on the risk analysis and under certain circumstances priority may well be given to the Mass Notification System, and in fact the Mass Notification system may not only silence Fire Alarm speakers, but even take them over for distribution of a more important message to be transmitted.

• Section 24.4, et seq, reverses the relationship between In-Building Fire Alarm Systems and Mass Notification systems.

NFPA recognizes that a flexible, multi-layer integrated approach is desirable to deal with the complete Mass Notification issue. In addition, other aspects of communication are noted within this new Chapter. Ideally these elements, such as Area of Rescue and Elevator Emergency Communication, can also be included within this flexible, multi-layer integrated system.

• Section 24.3.6, et seq, emphasizes the value of multiple layers of various technologies for Mass Notification.
• Section 24.1.2, et.seq, notes the importance and role for not only in-building but also outside notification capability.
• Section 24.3.5.9 references Area of Rescue Systems as part of an Emergency Communications System (ECS).
• Section 24.3.5.10 references Elevator emergency communication systems as part of an Emergency Communications System (ECS).
• Section 24.4.2.19 incorporates Visible Notification (such electronic signage) as part of an Emergency Communications System (ECS).

While the new code clarifies many issues dialing with Mass Notification, there is one area that still remains unclear. Chapter 24 describes a product that can be confused with local area outdoor Mass Notification equipment, but in fact is very different in its philosophy of operation, function, and requirements.

Section 24.4.3 Wide-Area Mass Notification Systems states:

“Wide-area mass notification systems are often those such as campus giant voice systems, military base public address systems, civil defense warning systems, large outdoor visible displays, and so forth.” (Italics added).

We are all familiar with systems being described. As it clearly states, these are the systems that are activated to warn an entire town, or a section of a city, of an approaching tornado. These are the civil defense systems that we all became familiar with during the cold war, designed to provide a city with a warning of an impending attack.

Section 24.4.3.4.2 High Power Speaker Array (HPSA) describes the speakers used in such products, and the issues regarding their installation and use. Exhibits 24.10 and 24.12 show photos of typical High Power Speaker Arrays. They are mounted high up to transmit over the tops of trees and even buildings, to blanket a very large area with a common message.

Talk-A-Phone WEBS towers, on the other hand, are designed to provide a focused announcement to an outdoor area, and depending on topology and structures in the area, cover an area with as much as 1000 ft. radius. They can also be called in groups. This allows the broadcast of a different message to the quadrangle than outside to the dorms several blocks away. A campus giant voice system or civil defense warning system does not provide that specificity or granularity.

While there is a role for these massive announcement systems, they are quite different from a WEBS tower. The various concerns and requirements of Section 24.4.3 address those systems.

In this context it is worth noting that the U.S Department of Education released the Regulations for College Campuses Mass Notification Systems on October 29, 2009 (42 CFR Parts 600,668,675, et al.), stating that colleges must establish and release procedures that include:

“A description of the process that . . . (2) determines the appropriate segment or segments of the campus community to receive a notification . . ..” Such an appropriate segment, depending on circumstances, could be either a demographic or geographic segment of the community, furthering the concept of flexible layering of the Mass Notification System.

You can read more about the new Campus Security regulations from the U.S Department of Education in this blog post, or on our website.

For further information, the reader is referred to NFPA 72, 2010 edition, National Fire Alarm and Signaling Code Handbook, Lee F. Richardson and Richard J. Roux, NFPA.

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This document is not intended to, and does not, constitute legal advice of any kind, and should not be relied upon as such. Readers are encouraged to contact their own counsel regarding such issues.

Copyright Talk-A-Phone Co., 2009. This material may not be published, broadcast, rewritten or redistributed without prior permission.

Ways to improve your Emergency Phone investment

Emergency Communications plays an important role in today's busy and not always so safe campus environment. Acquiring Call Boxes/Emergency Phones is a great way to improve campus security and safety, but it also creates a powerful cross-functional platform that can maximize the potential of your investment for years to come.

Rule Number One – Let it be Heard

Despite the general belief, Emergency Phones are not just a way to connect to a security officer when an emergency situation arises: many Emergency Phone towers can be easily upgraded with high-power broadcasting speakers, ensuring that the campus personnel can issue a long-range mass notification broadcast in the event of emergency.

Rule Number Two – Let it be Seen

Emergency Phone Towers can also include LED signage, which can display critical information in case of an emergency. Utilizing both visual and audible sensory modalities can greatly enhance the chances of message delivery, especially to hearing impaired individuals.

Rule Number Three – Add a Set of Eyes

A simple upgrade can turn an Emergency Phone tower into an all-seeing verification and assessment device. By adding an embedded CCTV camera into an Emergency Phone unit, you can quickly verify the originator of the call and assess the urgency of the situation. Even a better use of video surveillance technology is adding a Pan-Tilt-Zoom camera atop the tower: giving security personnel situational awareness of the scene over greater areas.

Rule Number Four – Layers, Layers, Layers

Initial investment into Emergency Phones can prove to carry a lot more functionality with layered approach to Mass Notification, playing an important role in notifying faculty members, staff, students and visitors on your campus. Augmenting the existing equipment with broadcasting units, LED signage, or surveillance cameras can significantly improve the chances of reaching the intended audience, while keeping a close eye on the situation at hand.

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This document is not intended to, and does not, constitute legal advice of any kind, and should not be relied upon as such. Readers are encouraged to contact their own counsel regarding such issues.

Copyright Talk-A-Phone Co., 2009. This material may not be published, broadcast, rewritten or redistributed without prior permission.