Emergency Response Plan

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It starts as a typical day in the clinic; medications have been administered and clinics are being conducted. Without warning, inmates in general population begin banging forcefully on a cell door. You know immediately that these are not the usual sounds heard in a jail—this is much more urgent and serious. Smoke begins to fill the corridors and the medical clinic. Custody staff are frantically trying to evacuate inmates to a safe location when more banging begins from other cells. An inmate has set a populated cell on fire, which is quickly spreading to other areas of the facility. Are you ready to respond?

Standard A-07 Emergency Response Plan requires that health staff are prepared to implement the health aspects of the facility’s emergency response plan. To comply with this standard, health staff must first have a written plan in place.

Components of an Emergency Response Plan
The standard requires that, at a minimum, the plan include the responsibilities of the health staff, procedures for triage, predetermined sites for care, telephone numbers and procedures for calling health staff and community emergency response systems, procedures for evacuating patients, alternate backups for each of the plan’s elements and time frames for response. Each of these components should be addressed in a policy and procedure format or in a separate written plan and must be site specific for each facility. For example, a predetermined site for care at a main facility may be in a court holding area, whereas the predetermined site for care at the satellite facility may be in a large hallway between pods.

Simply having a policy that lists the components of a plan (compliance indicators #1a through #1g) without elaborating on each does not meet the intent of the standard. Health staff should be able to read the plan and understand their responsibilities and where to set up triage if the clinic areas cannot be used. Telephone numbers should be readily available.

Once developed, the plan must be approved by the responsible health authority and facility administrator. Care should be taken to ensure that the emergency response plan for health staff does not conflict with the response plan for custody staff (i.e., predetermined sites for care and evacuation plans should match).

Practicing the Emergency Response Plan
The next step in compliance is to practice the emergency response plan through two types of planned drills: mass disaster and man-down drills.

A mass disaster drill is a simulated emergency potentially involving mass disruption and/or multiple casualties that require triage by health staff. It frequently involves a natural disaster (e.g., tornado, flood, earthquake), an internal disaster (e.g., riot, arson, kitchen explosion) or an external disaster (e.g., mass arrests, bomb threat, power outage). It is important to note that a mass disaster drill must have multiple casualties in order to meet the intent of the standard. However, an actual event (mass disaster, mass disruption) without multiple casualties may be critiqued and shared with health staff. For jails and prisons, the mass disaster drill must be conducted annually in the facility so that over a three-year period, each shift has participated. For juvenile facilities, at least one mass disaster drill must be conducted annually for each shift that has health care personnel working in the facility.

While it is ideal to coordinate drills with community emergency services such as the fire department or first responders, facilities should not delay drills while waiting for plans to be developed. Delaying drills for this reason may result in compliance concerns for this standard if drills are not conducted annually as required. Fire drills that are conducted by custody staff without the involvement of health staff do not meet the intent of the standard for mass disaster drills, nor do classroom instruction and tabletop exercises where health staff’s projected response to emergencies is discussed.

A man-down drill is a simulated emergency affecting one individual who needs immediate medical intervention. It involves life-threatening situations commonly experienced in correctional settings such as suicide attempts, seizures and diabetic emergencies. Actual events are often critiqued to meet the requirement of this standard. Regardless of the type of facility, these drills must be practiced once per year on each shift where health staff are regularly assigned.

If there are no full-time health staff in a jail or prison, then drills are not required.

Documenting Drills
Both mass disaster and man-down drills or actual events must be critiqued and should document activities such as response time, names and titles of health staff, and the roles and responses of all participants. The critiques should contain observations of appropriate and inappropriate staff responses to the drill. The date, time and shift should also be noted on the critique.

For continuous quality improvement purposes, the critiques may be compared to the written emergency response plan to identify any areas of concern. For example, the written plan may specify a time frame for response, but during the drill the response time may have been slower than expected. A process CQI study may be implemented to examine the reasons for longer response time and possible solutions.

It is recognized that not all health staff on a particular shift may be present when a man-down or mass disaster drill takes place. The standard requires that the critique be shared with all health staff. To document this review, it is recommended that staff members who are not present during a drill later review and initial the written critique.

New to the 2014 jail and prison standards and 2015 juvenile standards is the requirement that recommendations for health staff be acted upon. For example, if during a drill the health staff find that the emergency response equipment was missing or not in working order, the written critique should state how this problem was resolved and the steps to ensure it doesn’t occur again.

Are You Ready?
Practicing the emergency response plan improves health staff’s ability to respond to disasters when they occur, and drills help to identify weaknesses in the plan. The scenario described at the beginning of this article could happen at any time. Are you ready to respond?

[This article first appeared in the Spring 2016 issue of CorrectCare.]

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