Compliance versus emergency management best practice

By Alain Normand

Speed limits on roads are supposed to be there for our safety. Over time, most of us – even the good drivers – have pushed the limit and drive much faster than the posting. We slow down and follow limits usually when there is a police car around. Instead of focusing on our safety on the roads, we focus on the compliance to the legislation for fear of penalty.

I see the same thing happening to a certain extent in the emergency management field. When the province developed the regulations for municipalities to have emergency management programs, the goal was to ensure all municipalities had an essential level of preparedness to cope with emergencies. Today, for many municipalities, the compliance is all about the checkmarks. Why do municipalities do a HIRA? Because the province requires them to do one. In the recent discussion at the engagement sessions set up by OFMEM, this topic came up. I know the people at OFMEM took notes and plan to act on it, I just want to make sure this is heard.

Doing a HIRA shouldn’t be about having a document to send to OFMEM at the end of the year. The HIRA should be the tool upon which your emergency management program rests. Your focus should be about prevention, mitigation, and preparedness for those higher risks identified through the HIRA. But if this is only a document you send to OFMEM once a year, and file into the archives, then you are not doing emergency management. You are following the speed limit only because the police car is there, not for your own safety.

A corollary of this is how I want to tailor my HIRA. If the HIRA is a tool for me to identify the emergencies upon which I am going to take action, towards which I will devote resources and time, then I want to prepare a HIRA that is meaningful. Since I know that there are some of those hazards on the list that I can do nothing about, why should I keep them on the list? The list may be useful for the province since there is the likelihood of any of these hazards occurring at least in one part of the province; for my municipality, not so much.

I am not talking here of avalanches, space objects, or tsunamis. I am referring to emergencies that can happen in my community but for which I have no resources or authority. Take terrorism for example. This is entirely a police matter. Police doesn’t even tell me what they are doing, at what level do they evaluate the risk, or what resources they are attributing to it. So if I can’t do anything about it except wait until the consequences to coordinate the clean up, then why should it be on my HIRA? Leave this for a police driven HIRA and keep it out of mine.

Take pandemics and epidemics. It is a public health response. I have no clinics, no medical professionals, and no medication, so there is nothing I can do about it except maybe a bit of business continuity. Why must I keep this on my HIRA? Leave it for a public health driven HIRA and keep it out of mine.

For those types of situation, my emergency management program becomes a support, not the lead. For those who tell me I still have to prepare for the consequences, I agree and that’s just it. I plan for the consequence management, not the cause so not prevention or mitigation. But consequence management for a terrorist event to me is the same as consequence management for an industrial explosion. I have victims that need to be treated, properties that have damages, people that are displaced, debris to be picked up, and traffic to be rerouted. Consequence management for a pandemic to me is the same as a labour disruption. I have people who can’t come to work, operations that are working on reduced staffing and some operations may be closed altogether.

Part of the difficulty as well lies with the impression that we do the HIRA with response in mind. The HIRA is actually more useful in terms of prevention and mitigation than response. I use all hazards response plans; these will be very similar regardless of the cause of the emergency. The HIRA doesn’t do a lot for me at that stage. I will use the HIRA however, if it tells me that putting a berm or a dam in one location will reduce the risk of flooding. I will use the HIRA if it tells me I should plant native species of trees that are more resistant to ice storm conditions.

This also leads me to the legislation that requires upper tier and lower tier municipalities to have matching programs. I dare to say that my HIRA should look nothing like the HIRA at the upper tier because we have very different focus in the delivery of services to our citizens, different categories of involvement within our communities and even different types of relationships with our citizens and businesses. I have community centres that can be used for sheltering but I don’t have clinics. I have firefighting equipment but no ambulances. The legislation must stop trying to put us all in the same basket and let us work towards regional programs that let the upper tier and the lower tier negotiate how together they will comply to legislation and more importantly, how they will manage emergencies within the overall jurisdiction.

I believe OFMEM needs to move from a mentality of compliance for the sake of the legislation and move towards promoting compliance for the sake of doing emergency management. There is a change happening at OFMEM and I am enthusiastic about it. That change needs to include a philosophy of being there as a promoter, not an enforcer. OFMEM needs to be there to provide tools, support, advice, education, training, and possibly funding so that municipalities use the compliance elements as tools for their own community to become safer rather than just the need to put the check mark in the box.

The series of engagement session were a good start in that direction and the various committees established through the OFMEM portfolios should continue that effort. Understanding the value of speed limits for our own safety has more to do with education than enforcement. I drive at a speed that I know I can maintain control of my vehicle, not necessarily the posted limit. Which means I drive slower in poor road conditions and at night. The speed limit doesn’t tell me to do that, the education about driving in bad road conditions does.






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