KBS Reference Desk: Emergency Operations Plan Updates

Q: We are getting a lot of questions from our community about school safety issues right now and the Board has asked me to report on our current emergency operations and plans. What aspects of our current plan should we consider updating and how do we go about it?

A: The Texas Education Code requires each school district to adopt and implement an Emergency Operations Plan (“EOP”). The plan must address emergency preparedness and response, as well as employee training.

Section 37.108 of the Texas Education requires EOPs to address:

  • Emergency response training for district employees;

  • Mandatory emergency response drills for students and employees;

  • Measures to ensure coordination with state and local agencies; and

  • Implementation of a safety and security audit.

Your district should already have in place an existing EOP, however Section 37.108(b) requires each school district to conduct a “safety and security audit” of the district’s facilities at least once every three years. The results of the audit must be reported the Board of Trustees and the Texas School Safety Center. The findings of your audit should be used in updated and revising your current EOP, paying particular attention to areas of vulnerability revealed during the audit process. Look to Board Policy CKC (LOCAL) for your district’s specific requirements regarding updating and approving the District’s EOP. Most local policies identify the Superintendent as the person responsible for updating the EOP and submitting it to the Board for approval.

Since your community is interested in the District’s safety measures, it is important to note that a school district’s EOP is considered confidential under the Texas Public Information Act (Chapter 552 of the Texas Government Code). A person requesting this information may be entitled to a record(s) that establishes only the existence of the EOP, and compliance with the legal requirements (e.g., Board meeting minutes approving the plan), but the plan itself is not subject to disclosure. Thus, if you publish your agenda and accompanying exhibits to BoardBook for the public to see before your meetings, be sure to not include the Emergency Operations Plan, or the safety and security audit results. The same is true for exhibits to the minutes. Discussion of your security updates can be held in closed meeting under the Texas Open Meetings Act, pursuant to Section 551.089 of the Government Code.

When considering the specific additions or modifications to your district’s current EOP, note that particular attention is being given to active shooter training in districts across the state due to the recent number of tragic school shootings (the most recent of which occurred in Texas). On May 30th of this year, in response to the Santa Fe ISD shooting, the Governor unveiled his “School and Firearm Safety Action Plan.” The plan provides districts with guidance and additional resources to use in combating school safety threats that could be useful when updating your EOP, including employee training resources, campus hardening measures and mental health screening techniques. You can read our summary of the Governor’s Safety Plan HERE.