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Circular 02-02


DEPARTMENT OF HEALTH AND HUMAN SERVICES
Indian Health Service
Rockville, Maryland 20852

Refer to: OD

INDIAN HEALTH SERVICE CIRCULAR NO. 2002-02

Effective Date:  08/09/2002

CONTINUITY OF OPERATIONS PLANNING PROGRAM

  1. PURPOSE:  The purpose of this Circular is to establish policies, procedures, and operational requirements for the implementation, management, and administration of the Indian Health Service (IHS) Continuity of Operations (COOP) planning program.  This Circular assigns COOP responsibilities to all levels of IHS management.  All IHS-wide COOP planning and coordination activities are extensions of the regular functions of IHS senior management officials and their organizations throughout the IHS.

  2. OBJECTIVE:  The principal objective of the COOP:

    1. Ensure the continuous performance of IHS essential functions/operations during an emergency.

    2. Reconstitute, as rapidly as possible, IHS operations that are adversely affected due to an emergency or disaster.

    3. Support regular training and exercises designed to enable all personnel to perform assigned COOP duties.

  3. SCOPE:

    1. Applicability.  This Circular applies to all levels of IHS management and addresses all COOP functions and activities to ensure business continuity.  As used in this Circular, preparedness functions and activities include, as appropriate, plans, procedures, and readiness measures, including mitigation strategies that enhance IHS ability to respond to and recover from a designated emergency.

    2. Contingencies.  The COOP planning requires the consideration of a wide range of possible contingencies that could disrupt the performance of minimal essential functions.  These possibilities include, but are not limited to:

      1. A national emergency such as a war involving the United States (U.S.) Armed Forces, an attack on the U.S., or any threat to the continuity of the Federal Government.

      2. Natural and technological disasters such as radiological incidents or emergencies, hazardous materials (HAZMAT) incidents, and environmental disasters.

      3. Events declared by the President to be major disasters or emergencies under Public Law (P.L.) 93-288, the "Robert T Stafford Disaster Relief and Emergency Assistance Act," as amended.

      4. Civil disorders, terrorism, or other violent acts.

    3. Primary Assumptions.  The COOP planning primary assumptions are:

      1. A major emergency or disaster that could happen at any time

      2. Adverse conditions could cause a much larger than expected demand for certain IHS services, internal, and external to the IHS.

  4. POLICY.  The IHS shall have in place a viable COOP plan, with the capability to ensure the performance of essential functions during any emergency or situation that may disrupt normal operations, as a baseline of preparedness for the full range of potential emergencies.  All IHS senior management officials will have sufficient capabilities to meet essential needs during a national emergency, including the capability to respond to the needs of individuals and state or local governments where required by law or binding policy.

    1. Delegation of Authority

      1. Senior management officials are authorized to re-delegate the functions assigned by this policy, and to authorize successive re-delegations to organizations or employees under their respective jurisdiction.  Copies of the written delegations shall be sent to the Director, IHS through the Director, Management Policy Support Staff.

      2. If, during a national emergency, an Area office is cut off from communications with the Director, IHS:  The Area Director is delegated any authority of the Director, IHS, with respect to all laws administered by the IHS to the extent necessary to carry out IHS responsibilities within the scope of the Area Director’s responsibility.

      3. Area Directors assuming authority under paragraph (2) above, will perform prescribed duties in accordance with existing governing statutes and regulations.  Any required referral to IHS Headquarters for the Director, IHS' approval is waived if the automatic delegation above is in effect and communication with the responsible official is impossible.

      4. In the event of a local disaster during a declared national emergency, IHS medical facilities may provide emergency medical care to civil and military authorities, and to injured persons regardless of statutory eligibility, as necessary to save lives and prevent suffering in accordance with existing Federal laws and regulations.

    2. Conflicting Civilian and Military Obligations.  Any IHS employee in the Ready Reserve, National Guard, or Commissioned Corps of the United States Public Health Service (USPHS) shall be available for deployment on active military duty status in a national emergency.  Deployments of commissioned corps officers under Commissioned Corps Readiness Force (CCRF) or other commissioned corps deployments that are not military deployments shall not be in conflict with normal duties, but the deployment is an acceptable “absence from normal duty, just as in a military deployment.”

  5. BACKGROUND.  All COOP planning is simply a good business practice that is a part of the fundamental mission of agencies as responsible and reliable public institutions.  For years, COOP planning had been an individual agency responsibility primarily in response to emergencies within the confines of the organization.  The content and structure of COOP plans, operational standards, and inter-agency coordination, if any, were left to the discretion of the agency.

    The changing threat environment and recent emergencies, including localized acts of nature, accidents, technological emergencies, and military or terrorist attack-related incidents, have shifted awareness to the need for COOP capabilities that enable agencies to continue their essential functions across a broad spectrum of emergencies.  Also, the potential for terrorist use of weapons of mass destruction has emphasized the need to provide the President a capability, which ensures continuity of essential government functions across the Federal Executive Branch.

    To provide a focal point to orchestrate this expanded effort, Presidential Decision Directive-67, “Continuity of Operations Planning,” dated October 21, 1998, established the Federal Emergency Management Agency (FEMA) as the Executive Agent for Federal Executive Branch COOP.  Inherent in that role is the responsibility to formulate guidance for agencies to use in developing viable, executable COOP plans; facilitate interagency coordination as appropriate; and oversee and assess the status of COOP capability across the Federal Executive Branch.  Additionally, each agency is responsible for appointing a senior Federal government executive as an “Emergency Coordinator” to serve as program manager and agency point of contact for coordinating agency COOP activities.

  6. PLAN DEVELOPMENT GUIDANCE

    1. Site or Activity-Specific COOP Plan.

      1. This section contains guidance and a format for completing a site or activity-specific COOP plan.  The guidance is provided in the form of comments below and a questionnaire (Circular Exhibit 2002-02-A).  The questionnaire will assist in organizing the information regarding IHS essential operations, staffing, and equipment.

    2. Site Vulnerability.  Effective COOP planning begins with an analysis of the hazards and vulnerabilities specific to an operating site.  Threats to the Federal government structure and functions may originate from natural disasters and accidents, technological emergencies, military or terrorist threats, or attacks.

      1. Hazard identification and vulnerability assessments combine probabilities of event occurrence with risk factors relevant to the specific site e.g., nature of the operation and structural characteristics, to determine the level of risk.

      2. Secondary hazards should also be taken into consideration.  A secondary hazard is one that arises from the impact of a primary hazard.  For example, an organization may be well protected from fire; however, if an earthquake broke power cables, disrupted water lines, and blocked streets, then the organization’s reliance on paper files, or its use of flammable materials otherwise carefully protected, could make fire a serious secondary hazard.

      3. The assessment of hazards to a specific site should include consideration of off-site hazards that can pose on-site risks.  As an example, an organization located outside an earthquake area, whose mission-essential Automated Data Processing support center is located inside an earthquake area, should consider that an off-site hazard.

    3. Effectiveness.  The IHS COOP plan requires:

      1. Identification of functions to be performed during an emergency.

      2. Development of plans for performing these functions.

      3. Development of the capability to implement the plans.

      4. Analysis of events to formulate mitigation strategies that would lessen the impact of future events.

      5. Identification of an off-site emergency center for continuity of operations.

    4. Planning Considerations.  In accordance with current guidance, a viable COOP capability:

      1. Must be maintained at a high level of readiness.

      2. Must he capable of implementation both with and without warning.

      3. Must be operational no later than 12 hours after activation.

      4. Must maintain sustained operations for up to 30 days

      5. Should take maximum advantage of existing IHS field infrastructures

    5. Multi-year Plan.  The IHS shall develop and maintain its COOP capabilities using a multi-year strategy and program management plan.  The plan shall outline the process the IHS will follow to:

      1. Designate essential functions and resources.

      2. Define short and long-term COOP goals and objectives.

      3. Forecast budgetary requirements.

      4. Anticipate and address issues.

      5. Anticipate potential obstacles.

      6. Establish planning milestones.

    6. Essential Operating Requirements.  Those operations that must be performed to meet the IHS mission will be identified and rated as full capability functions, limited capability functions, and core capability functions.  This is one of the more difficult planning tasks because the initial reaction is to assume that every operation is essential otherwise it would not be staffed or funded.  Further analysis usually reveals that some operations are indeed more essential to the organization’s core reason for existing than others, especially during a time of emergency.  Carefully identifying these essential functions assists in other COOP planning activities, such as identifying key personnel and equipment.  An emergency that is site specific, and affects only IHS and its support for its usual constituents, may have different essential operations than an emergency such as a declared disaster and/or the activation of the Federal Response Plan (FRP) for P.L. 93-288, as amended, which requires support to other agencies.  If the operations are significantly different, separate lists should be developed.  All IHS organizations shall identify and prioritize mission-essential functions that:

      1. Are required in the first 12 hours following an emergency or disaster.

      2. Can be deferred from 1-2 weeks.

      3. Can be deferred from 1-2 weeks up to a period of 30 days.  When identifying functions to be deferred, the impact on other IHS organizations should be considered.

    7. Essential Staffing.  All COOP plans shall specify emergency and alternate staffing necessary during the plan’s implementation.  This staffing should be the minimum necessary to execute the tasks required to transition or relocate from a primary to an emergency relocation site.

    8. Essential Equipment.  If a plan calls for relocation to an alternate site and equipment must be relocated, appropriate procedures must be followed for moving the equipment.

    9. Testing.  Emergency plans and programs will be developed and tested IHS-wide as an integral part of IHS continuing activities.

    10. Distribution.  Each IHS organization should determine the appropriate recipient of copies of its COOP plan, both internal to the site, organization, chain of command, and external agencies and other emergency response organizations.  At a minimum, distribution should include the next senior and next subordinate levels.  Distribution should be governed by a need to know and a list of plan recipients should be maintained.

  7. VITAL RECORDS PROGRAM.

    1. Identification and Protection.  The identification and protection of records containing vital information and the implementation of records disaster mitigation and recovery are essential elements of a vital records program that will offset a disruption of critical agency operations.  The IHS must act to achieve the aims of continuing operations, resuming normal business operations, protecting legal and financial rights, and recovering damaged records.  All IHS programs need to determine their most critical functions and identify those records needed for the performance of those functions.

    2. Vital Records.  The vital records program is intended to do two basic things.  First, the program provides the IHS the information it needs to conduct its business under other than normal operating conditions and to resume normal business afterward. Second, the program enables IHS officials to identify and protect the most important records dealing with the legal and financial rights both of the IHS and of persons directly affected by the IHS's actions.  Consequently, two types of vital records have been traditionally identified:

      1. Emergency Operating Records.  Emergency operating records are vital to continue essential functions or reconstitution of the Federal government for the duration of an emergency and must be available as needed at or in the vicinity of emergency operating centers.  They are required by top and intermediate commands to accomplish IHS essential functions.  Included are emergency plans and directives; orders of succession; delegations of authority; emergency staff assignments; file plans describing the record series and electronic information systems maintained at official filing stations for all IHS facilities; vital records inventories; copies of IHS program records (whatever the medium) needed to carry out continuing critical functions; system documentation for any electronic information systems designated as emergency-operating records; building plans and building systems operations manuals for all agency facilities; and equipment inventories for all agency facilities.

      2. Financial and Legal Rights Records.  Financial and legal rights records are essential to the preservation of the legal rights and interests of individuals and the U. S. Government and require protection. Storage points do not need to be at or in the vicinity of emergency operation centers.  They are required to carry out IHS-essential functions after a period of immediate emergency to protect the legal and financial rights of American Indians and Alaska Natives, IHS employees, and the IHS.  The following nonexclusive list of records needed to protect financial and legal rights include: accounts-receivable records, social security records, payroll records, retirement records, patient compensation, insurance records, and any records relating to contracts, entitlement, leases, or obligations whose loss would pose a significant risk to the legal and financial rights of the IHS or persons directly affected by its actions.

  8. CLASSIFIED INFORMATION.  All COOP plans must take into consideration the handling and management of classified information.  Classified national security information is marked as “Top Secret,” “Secret,” or “Confidential.”  The President appoints the original classifier.  The IHS does not have classification authority.

    1. National Security Classification.  Information that might be considered for national security classification includes the following:

      1. How and by whom people are alerted and individual alerting responsibilities.

      2. Listing and location of indispensable records.

      3. National security planning assumptions on nature of threat.

    2. Unclassified Information.  Information that may be generally unclassified includes the following:

      1. General duties of individuals, personal planning, advance financial arrangements, and other administrative matters that must be known by those involved in COOP planning unless classified due to other security requirements.

      2. General information on the overall COOP planning program, existence of IHS organization alternate plans and arrangements, means to protect vital records, and plans for periodic testing and conducting exercises to determine operational readiness.

      3. Matters of executive guidance, such as procedures for designating successors and delegating authority.

      4. The uses of titles including National Military Command Center, National Military Command Center B Site R, FEMA Special Facility, and the National Airborne Operations Center.

  9. RESPONSIBILITIES.

    1. Director, IHS.  The Director ensures that an effective IHS COOP plan is established.  The Director, IHS, shall approve a standing delegation of authority (DOA) to provide the authority necessary to ensure continuity of essential IHS operations during a period of national emergency.

    2. Director, Legislative Affairs.  Develops the COOP plans and procedures relative to congressional relations and congressional communications.

    3. Director, Public Affairs.  Provides public affairs policy guidance for all organizational levels.

    4. Office of General Counsel.

      1. Provides legal advice on proposed and ongoing IHS COOP policies and directives, to include identifying and acquiring additional legal authorities needed to assist the Director, IHS, Headquarters Office Directors, Area Directors, Service Unit Directors, and other key management officials in performing their duties during the activation of the COOP.

      2. Provides legal concurrence in, and coordinates the IHS's process for review of, proposed rule changes and internal or other Federal emergency management policy documents.  Drafts, furnishes comments on, or provides changes to, applicable emergency management legislation.

    5. Senior Management Officials.  Headquarters Office Directors, Area Directors, Service Unit Directors, and other key management officials.  The IHS's senior management officials shall:

      1. Identify IHS essential planning functions to be performed by their organizations and determine if they constitute lead or support roles within the IHS.

      2. Ensure that the costs associated with carrying out the IHS' approved multi-year plan for COOP, including exercise participation, are included in annual budget requests.

      3. Develop plans for the identification of costs related to any declared emergency response and recovery for possible reimbursement under the provisions of the FRP, P.L. 93-288 or other possible authorities.

      4. Develop plans to support their essential functions within the IHS and coordinate COOP plans with the Director, IHS.

      5. Develop the capability to support these plans.

      6. Exercise these plans at least annually and provide a critique of the exercise(s) to the Director, IHS.

      7. Establish standing delegations of authority and lists of successors to ensure continuity of essential IHS operations during any major emergency or disaster.

      8. Appoint in writing an individual to function as the COOP planner.

    6. Continuity of Operations Planner.  The Continuity of Operations Planner:

      1. Has the primary responsibility for planning and developing COOP procedures.

      2. In consultation with the IHS Records Management Officer (RMO), will ensure that plans and resources are maintained in a constant state of readiness to include the selection, shipment, maintenance, and cycling of emergency operating vital records at relocation sites.

      3. Provides counsel to IHS senior management and other key officials, and field organizations regarding COOP procedures, authorities, and recommended actions.

        1. This responsibility requires that they have direct access to their respective office directors.

        2. In developing plans or communicating emergency messages pertaining to National Security COOP, COOP planners are to interact directly with the Director, IHS, and/or any element delegated by the Director, IHS.

        3. Will inform the Director, IHS, of any emergency situations originating at the field level and provide appropriate status reports to ensure intra-agency and inter-agency coordination.

      4. Maintains a list of essential personnel within his/her respective organization by occupation and skill that would be needed in the event of a national emergency.

      5. Advises essential personnel of their responsibilities on a periodic basis.

      6. Ensures that IHS vital records, Emergency Operating Records (Category A) and, if applicable, Legal and Financial Rights Records (Category B), are accessible at IHS relocation site(s).

      7. Makes periodic and special appraisals and reports of COOP program readiness capabilities, to include operational elements in the field, reporting on objectives, program activities, deficiencies, and problems relating to COOP responsibilities.  These appraisals and reports will provide the basis for IHS-wide evaluation of the COOP program.

      8. Ensures appropriate intra-agency and inter-agency coordination of COOP planning, and that there is clear understanding on the part of all concerned as to the conditions and limitations under which any emergency plan, procedure, policy, program, or course of action shall be put into effect.  The respective organizations will ensure that individual IHS facility COOP plans are developed and currently maintained.

      9. Ensures that emergency coordinators and all employees whose responsibilities include COOP, will take the “Vital Records Management Program Training” through the IHS Records Management Program.

      10. Identifies and ensures that an emergency relocation center is available (if required).

      11. Identifies and ensures that sufficient equipment and supplies are available for the continued operation of IHS essential functions and operations at the emergency relocation center (if required).

    7. Director, Office of Public Health.  The Director:

      1. Verifies that IHS medical facilities develop and exercise site-specific emergency plans to provide for continuity of care to eligible American Indians and Alaska Natives in the event of war, national emergencies, and natural, technological, or manmade disasters including terrorist events.  Current copies of these plans will be maintained as Category "A" records at the IHS relocation site.

      2. Develops plans to provide emergency health care services, as resources permit, to civilian victims of disasters in accordance with the FRP.

      3. Promotes, in cooperation with the Secretary of Department of Health and Human Services (HHS), the development of state, Tribal and local plans for the provision of disaster medical services, as well as the development of national plans to mobilize the health care industry during national security emergencies in accordance with Executive Order (E.O.) 12656, “Assignment of Emergency Management Responsibilities,” November 18, 1988.

      4. Works in collaboration with the Division of Information Resources and the IHS Records Management Program to develop IHS-wide guidance on the protection and storage of vital records on data systems located at all IHS medical centers.

      5. Coordinates policy issues related to IHS’ responsibilities under the FRP with the Director, IHS.

      6. Prepares plans to release Public Health Service Commission Corp Officers to the Office of COOP under the CCRF for use in providing emergency medical care during a national emergency or other official means.

      7. Prepares plans to release other personnel for emergency duties as may be required during an IHS or national emergency.

      8. Conducts for IHS in conjunction with Office of Emergency Preparedness (OEP) training and education focusing on public health COOP.

    8. Director, Office of Management Support.  The Director, OMS, will collaborate with the IHS RMO in developing IHS-wide policy and operational guidance related to the maintenance and protection of IHS Personnel, Financial, Acquisition, and Information Technology Systems.

    9. Director, Division of Financial Management.  The Director, Division of Financial Management, will collaborate with the IHS RMO in developing IHS-wide policies and procedures for the protection and storage of financial records.

    10. Chief Information Officer.  The Chief Information Officer:

      1. Works within the framework established by, and cooperates with those organizations assigned responsibility in E.O. 12472, “Assignment of National Security COOP Telecommunications Functions,” dated April 3, 1984, to ensure adequate national security COOP telecommunications.

      2. Develops plans and procedures to coordinate with Agency offices in developing and supporting requirements for National Security COOP Telecommunications.

      3. In collaboration with the IHS RMO, develops IHS-wide policies and procedures for the protection and storage of vital electronic records for computer systems maintained by the IHS.

      4. Coordinates with IHS senior management officials and other key officials in the development of their contingency plans for the retrieval of electronic records during or after emergency situations.

      5. Cooperates with HHS, General Services Administration, Department of Defense, and communications common carriers in the management and operation of elements of the National Communications System available to IHS under emergency conditions.

      6. Establishes policies and procedures reflecting the minimum information security requirements or critical/mission-essential Automated Information System's infrastructure in the IHS.

    11. Records Management Officer.  The IHS RMO is responsible for coordinating and providing IHS-wide planning, developing, and directing of a comprehensive vital records management program.  The RMO:

      1. Advises and works with appropriate officials throughout the IHS on how to identify, inventory, protect, store, make accessible, and cycle (update as needed) the copies of vital records required in an emergency, including records that document legal and financial rights.

      2. Provides guidance and assistance in inventorying records and determining appropriate maintenance practices for copies of vital records.

      3. Provides periodic briefings to senior managers about the vital records program and its relationship to their records.

      4. Assists in choosing protection methods, media, and storage sites for vital records.

      5. Conducts periodic reviews to determine whether the IHS vital records are adequately protected, current, and accessible to the staff that would use them.
  10. VITAL RECORDS MANAGEMENT PROGRAM

    1. Senior-Level Management.  The cooperation of IHS senior-level program managers is important throughout the life cycle of vital records.  Based on the contingency planning analysis and identification of both emergency-operating records and those needed to protect legal and financial rights, senior-level program managers must determine which records within their physical or legal custody are vital.  The IHS senior-level program managers, in consultation with the IHS RMO, will:

      1. Review current and requisite Headquarters/Area/Service Unit/Health Center file plan(s) and review the IHS Records Disposition Schedule and National Archives and Records Administration General Schedule to determine which record series potentially qualify as vital for their respective programs.

      2. Review statutory and regulatory responsibilities and existing emergency plans for insights into the functions and records that may be included in the vital records inventory.

    2. Vital Records Inventory.  The inventory should include:

      1. The name of the function file manager(s) responsible for the record series or electronic information system containing vital information.

      2. The title of each record series or information system containing vital information.

      3. The identification of each series or system that contains emergency-operating vital records or vital records relating to rights.

      4. The medium on which the records are recorded.

      5. The physical location for offsite storage of copies of the record series or system.

      6. The frequency with which the records are to be cycled (updated).

    3. Vital Records Contingency Planning and Risk Assessment.  Contingency planning is critical to laying the foundation for the IHS Vital Records Program and the implementation of records disaster mitigation and recovery.  The IHS officials must identify the types of risks to which each of its facilities may be subject, in planning to meet actual and potential risks to IHS operations and the records needed to support them.  They should also assess the level of each type of risk to determine the type of protection or response that may be required.  The planning includes:

      1. Determining the most critical activities that the IHS must perform if it must operate under other than normal business conditions and in a facility other than its normal place of business.

      2. Identifying which records support those critical activities and the resumption of normal operations.

      3. Identifying which record series or electronic information systems contain information needed to protect the legal and financial rights of the agency and person's directly affected by the agency's actions and preserving copies of such records.

      4. Establishing and implementing a plan to recover records, regardless of the medium of recording, that are damaged in an emergency or disaster.

    4. Special Vital Records.  Additional protective measures are needed for Federal records maintained on a medium other than paper.  These "special records" require specific environmental conditions and careful handling throughout their life cycle to ensure their preservation.  Temperature and humidity controls for special records such as photographs and negatives, microforms, audio and videotapes and disks, and electronic tapes and disks.

    5. Vital Records Maintenance.  Take steps to ensure that copies of all vital records are properly managed throughout their life, as they are updated, stored, and cycled. In addition, ensure that original vital records are properly maintained until their authorized disposition.

    6. Training.  Ensure that employees receive training appropriate to their assigned duties, focusing generally on the identification, inventorying, protection, storage, and cycling of copies of the program's vital records.

  11. SUCCESSION OF IHS OFFICIALS IN AN EMERGENCY

    1. Operational Washington D.C., Headquarters.  The Deputy Director, IHS, shall succeed the Director, IHS, unless the President designates another officer of the government.

      1. Will move to the designated IHS COOP site and assume IHS command and control authority.

      2. Shall promptly report his/her status as Acting Director, IHS, to the Secretary, HHS, by the fastest medium of communication.

    2. Non-operational Washington, D.C., Headquarters.  The Director of Field Operations (if stationed outside the Washington, D.C., metropolitan area) will succeed the Director, IHS, in the event IHS Headquarters offices in the Washington, D.C., metropolitan area become non-operational.  If the Director of Field Operations is not stationed outside the Washington, D.C., metropolitan area, the Director, IHS, will designate an order of succession from among the IHS Area Directors.

    3. Succession to IHS Officials.

      1. The Director of Headquarters Operations, Director of Field Operations, and Headquarters office directors will each have a minimum of three successors.  At least one of the three shall be from permanent duty stations located outside of the Washington, D.C., area.  This may require offices in the Washington, D.C., area to make arrangements to have IHS offices outside of the Washington, D.C., area, assume IHS responsibilities in a major emergency.

      2. The IHS Area Directors will each have a minimum of three successors, one of whom shall be from permanent duty stations located outside the Area office.  This may require the Area Directors to make arrangements to have IHS offices outside of the Area office assume Area responsibilities in a major emergency.

      3. Succession will take place only when there is an emergency or when the principal is unavailable or a higher authority directs the succession.  Conflict of authority will be avoided by the use of all possible means of communication within the line of succession.  Tenure will continue until the successor is relieved by the principal, someone higher in the order of succession, or by orders higher authority.

      4. Principals are responsible for providing both general orientation and specific operational information that a successor will need in an emergency.
    4. Listing of Successors.  All IHS managers for whom emergency succession is required are responsible for the preparation and maintenance of a list of their successors.  Each list will be reproduced to provide, at a minimum, one copy for each principal and successor.  Headquarters and Area Office Directors, Service Unit Directors, and other key officials will ensure that their emergency planners file current copies of authenticated successor lists with the organization’s Directives and Delegations Control Officers.

  12. EMERGENCY ORGANIZATION AND OPERATIONS.

    1. Event Phases.  The COOPs shall be considered and addressed in three basic phases as follows:

      1. Pre-Event.  This phase consists of the mitigation activities to either prevent the occurrence of an emergency or minimize the adverse impact of the event.  This phase consists of preparedness activities such as planning, training, and conducting exercises to enhance the effectiveness of emergency or disaster response activities.

      2. Trans-Event.  This phase consists of the response activities addressing the immediate and short-term effects at the onset of an emergency or disaster.  Response activities include direction, control, warning, evacuation, and other similar functions.

      3. Post-Event.  This phase consists of the recovery activities that involve restoration of operations and all support systems to normal.

    2. Warning Conditions.  The COOP plan may be executed under several conditions that address whether or not warning can be given, e.g., a hurricane or earthquake.  In addition, a warning or the emergency itself, may occur either during normal duty hours or non-duty hours.  The COOP plan may be implemented under the following conditions:

      1. Condition One - With Warning.

        1. With Warning B During Normal Duty Hours.  (Between the hours of 7 a.m. and 6 p.m. Monday through Friday).  There are some threats to operations that may afford advance warning that will permit the orderly alert, notification, evacuation and if necessary the relocation of employees.  Situations that might afford such warning include a “Severe Weather Event,” a transportation accident resulting in a threat of release of a HAZMAT, or a warning of a terrorist incident.

        2. With Warning B During Non-Duty Hours.  Fire and situations similar to the above that occur during non-duty hours may also afford advance warning.  The Designated/Senior Official will initiate the organization's recall roster (first reference to requiring a recall roster) and, in conjunction with the management team, will assess the situation to determine if it is necessary to activate the COOP plan and relocate essential personnel.

      2. Condition Two - Without Warning B During Normal Duty Hours.  Incidents may also occur with no warning during normal duty hours.  In these circumstances, execution of the COOP plan, if indicated by the circumstances of the event, would begin by execution of the site's Occupant Emergency Program (first reference to occupant emergency program) to move employees out of the building expeditiously.  (See 41 Code of Federal Regulations (CFR) 101-2, "Occupant Emergency Program, " July 1, 1998.)

      3. Condition Three - Without Warning B During Non-Duty Hours.  Incidents may not be preceded by warning, e.g., earthquakes, arson, or HAZMAT incidents; or may occur while the majority of on-site staff is not at work.  In these circumstances, while operations from the home site may be impossible, the majority of employees will be able to respond to instructions, including the requirement to relocate following proper notification.

    3. Alert, Assembly, and Relocation.  In a “With Warning” or a “Without Warning During Normal Duty Hours” condition, the following procedures will be followed:

      1. If an emergency situation arises that necessitates relocation, the Designated/Senior Official will initiate the organization’s recall roster.  Each recipient will see that the message is communicated as required by the cascade chart to those IHS organizations for which he/she is responsible.  Supervisory personnel are responsible for ensuring that the cascade system for essential personnel is complete and current.

      2. Essential personnel who are to be transported to a relocation site will meet at a pre-designated assembly point at a time given by their supervisor.

      3. Essential personnel who have been given prior permission to use their privately owned vehicle to relocate to their alternate sites may proceed at a time given them by their supervisor.

      4. In a “Without Warning During Normal Duty Hours” condition, it is possible that employees and/or clients will be evacuated from the building and execution of the COOP will commence.  Upon completion of assessments of damage and impact, and an estimated time for recovery, the designated/Senior Official will determine if relocation to the designated alternate locations is required and procedures outlined above shall be followed.

    4. Emergency Relocation Sites.  Emergency relocation sites will be identified.

    5. Emergency Response Coordination.

      1. In the event of a disaster affecting a field facility, the Director, IHS, will determine if the situation warrants implementing the IHS COOP or any portion thereof to perform disaster coordination in support of the affected activity(ies).  The Area Director, Service Unit Director, Facility Director, or other key officials whose facility or activity is principally affected has the prime responsibility for the emergency actions and recovery, with the support of other IHS Headquarters officials whether or not the IHS COOP is implemented.

      2. The Area Director, Service Unit Director, Facility Director, or other key officials whose facility or activity is principally affected shall appoint a senior member of his staff as “Disaster Control Coordinator.”

      3. Each Area Director, Service Unit Director, or other IHS official who receives notification of a major disaster affecting an IHS field facility or activity will ensure that the Director, IHS, and the Director, Office of COOP, OEP, are informed of the situation, action underway, and the extent of IHS Headquarters assistance required.  The IHS emergency management activity includes planning for a response to natural and technological disasters.  All IHS sites will have contingency plans.  Planning for this contingency will require extensive assistance coordinated by IHS Headquarters.

  13. SUPERSEDURE.  None.

  14. EFFECTIVE DATE.  This Circular is effective upon date of signature.

/Michel E. Lincoln/
Michel E. Lincoln
Acting Director, Indian Health Service


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