Creating an Emergency Plan in the IEP
While schools can provide safe havens for children — a natural place to find community, peers, two square meals, and trained adults to help guide them through childhood — children confront plenty of dangers at school, too. In this article, we’re taking a look at the work of keeping our kids physically safe during drills and emergencies.
For some kids with disabilities, the challenge is exiting the school when elevators are inaccessible. For others, the challenge is staying still and quiet in a dark room. While every IEP team should develop a plan specific to each child that addresses how to keep them safe, this is not usually done, is done insufficiently, or works better in theory than in practice.
3 key takeaways
- The IEP team should discuss the school’s emergency plan, accessibility issues the student may face during an evacuation or lockdown, and what supports the student may need related to their disability.
- An Independent Emergency and Lockdown Plan (IELP) can be included in a student’s IEP or 504 plan.
- Both staff members and kids should practice the emergency plan, and parents should follow up.
Do you have an emergency plan in your IEP?
It can be tricky when a parent asks this question because there are three distinct things that people refer to as an “emergency plan” in the IEP.
Individualized School Health Plan (IHP)
The first ‘emergency plan’ that can be in an IEP is really called an Individualized School Health Plan (IHP), and that is a document created by the school nurse with input from the child’s doctor and the parent. For example, for a student who has seizures or diabetes, an IHP would detail for the school staff what to do if that student has a health emergency at school. Any student with a health condition can have an individualized school health plan, but if a student has an IEP, it can also be added to that document.
Individualized adaptations to the school emergency plan
The second ‘emergency plan’ that parents can add to an IEP is making individualized adaptations to the school emergency plan. For example, if there is a fire or an active shooter, the school site council has created a school-wide plan to cope with different emergencies, evacuations, and drills. Your child’s disability may require that your child’s unique needs be documented in the IEP. For example, your school may have a run, hide, fight plan, but a student with a mobility issue is instead expected to shelter in place. The plan should detail who is going to accompany them and what the plan is to rescue them. Make sure this is not only discussed in the IEP but also gets recorded in the school-wide safety plan, and that the first responders are aware of the exception. This plan should ensure that special accommodations are integrated into the school’s broader safety protocols and communicated to first responders.
IEP Emergency Plan
Lastly, your California IEP contains a page that is titled “IEP Emergency Plan.” This was mandated by Cal. Ed. Code § 56345(a)(9) after the COVID-19 pandemic. This plan details how the IEP will be provided if there is an emergency situation that shuts down schools. For example, it should detail how special education and related services are provided remotely, synchronously and asynchronously, and how accommodations are provided. This is a good place to address the need for students to develop independent working skills, given that aide support may be limited in such situations.
Where and how to start with school emergency response plans
Emergency preparedness is an integral part of a school’s daily operations, but because there is no federal mandate dictating what emergencies students should practice and prepare for — or a universal model for school-based crisis preparedness that integrates the varied safety needs of all students, including students with disabilities — it is up to the districts and individual schools to decide what to practice and what to do during an emergency.
Here are some tips and suggestions from Dr. Pelangka to help you get started, ask questions, and plan ahead:
Know your school’s emergency plan
Every school and school district should have a plan in place to prevent, prepare for, respond to, and recover from a crisis situation. Check your district’s website, ask your child’s teacher or a school administrator about the plans the school has in place, and keep an eye out for notices and emails. Make sure you’re aware of how emergency planning will affect your child.
Inclusion in the classroom and in emergency preparedness is a matter of law. Title III of the 1990 Americans with Disabilities Act addresses discrimination on the basis of disability in places open to the public, governments, and schools. “If a child with a disability is specifically excluded from activities or protocols that benefit all students,” Collin says — for example, telling a child who uses a wheelchair to shelter in place during emergencies when everyone else is told to exit the building — “there is likely discrimination occurring.”
Another example of non-inclusive thinking is how students are expected to respond in the event of an active shooter. The Department of Homeland Security advocates the “run, hide, fight” strategy — in other words, running away when possible, hiding somewhere safe if you can’t run, or fighting the shooter if you can’t run or hide. But for students with disabilities, running and safely hiding may not be feasible.
Lockdown plans can also ignore the needs of students who, in addition to mobility needs, may have adverse reactions to loud alarms, an inability to remain quiet or still, or difficulty processing information or calling for help. All kids should be taught what will happen in an emergency situation, and individual plans need to take into consideration the child and their needs.
Know your child’s needs
To develop an appropriate individualized emergency plan unique to your child’s needs, it’s important to work at the individual level. First, think about what supports your child will need should an emergency happen:
How will your child react to loud alarms/sirens/screaming/gunshots? What is your child’s natural reaction to a crisis (flight, fight, or freeze)? Will your child need medication? Will your child pick up on social cues, such as how others are responding to the emergency? Will your child need to be physically moved during an emergency? Can your child follow multi-step directions? Will your child benefit from a buddy system? The more you know about your child’s response to emergencies, the better you can convey the information to the IEP team.
If your child needs assistive technology, medication, or other items, they should have an emergency bag ready to go in their classroom(s). The bag can be filled with needed items like soundproof headphones, sensory toys, and extra medication, especially if there’s no access to a nurse or medicine during the emergency. Your school might already have emergency go-kits in their classrooms, so don’t hesitate to ask about adding to it.
We’ve put together a checklist below to help you take notes on what your child needs and how you and the team can support it.
How to add emergency and safety plans into the IEP
Disaster preparedness and safety plans can and should be included in a student’s IEP or 504 plan. The National Fire Protection Association (NFPA) suggests that, “while not explicitly stated, the related services component must consider the particular needs of the child to ensure his or her safety during a building emergency that includes an evacuation.” Dr. Pelangka says in her experience, the emergency plan is often included in the accommodations section. While a good emergency plan may have both related services and accommodations to support it, districts take different approaches to how the plan is incorporated into the IEP.
Developing an Independent Emergency and Lockdown Plan (IELP)
Organizations like Safe and Sound Schools and the ALICE Training Institute recommend the use of Independent Emergency and Lockdown Plans, or IELPs. An IELP is “is an individualized plan that addresses the unique strengths and needs of individual students with disabilities with regard to the skills needed to survive a life-threatening crisis in school,” and it encompasses a student’s medical, sensory, and communication needs. IELPs were created by special education teachers Laura Clarke and Dusty Columbia Embury, who noticed that IEPs lacked plans for helping students during an emergency. The IELP should include everything a student needs to stay safe during a drill or crisis situation.
Teachers, parents, and students can work together to create an IELP that meets the school’s emergency protocols and the student’s needs. The following list from Clarke and Columbia Embury’s TEACHING Exceptional Children (TEC) article can help you explore what considerations your child might need in a crisis situation based on their disability:
- Autism: Frequent practice with emergency procedures. Task analysis of discrete responses, with systematic prompting, use of least intrusive prompts, and error correction. Tasks should be differentiated with predictable routines.
- Low vision or blindness: Multiple opportunities to explore the facility when it is in lockdown mode to understand which exits might not be available. Strobe lights or vibrating pagers to supplement audible alarms; braille signage or audible directorial signage; prerecorded directions on a CD.
- Deaf-blindness: Opportunities to explore facility, practice moving to safe locations and positions. Paired with a sighted partner to get to safety. Strobe lights or vibrating pagers to supplement audible alarms; braille signage or audible directorial signage; color-coded routes; prerecorded directions on a CD.
- Emotional/behavioral disability: Systematic instruction and practice with self-management skills.
- Hearing impairment: Alternate communication system (use of alternate lighting or alerts sent to phone or communication device).
- Intellectual disability: Explicit teaching of desired skills paired with active response opportunities; practice opportunities to build fluency (speed) of responses; programming for generalization of skills over settings.
- Orthopedic impairment: Adaptive equipment such as wheelchair, positioning device, crutches, or braces to move to or maintain a safe position. Accessible routes to safe locations. If exits or escape are blocked, may need additional supports, including alternate lifts; may need to be carried to exit facility.
During the IEP meeting, the team should discuss the school’s emergency plan, accessibility issues, and what challenges the student may face related to their disability. As Dr. Pelangka explains, some students need to be primed when to expect a fire drill. Some students may need to be removed from the classroom if the drill sounds are too loud for them. Other accommodations might include access to headphones or a fire drill tote to pick up on the way to lining up on the blacktop or grass, so they are occupied and stay in line. The IELP should contain specific information about the equipment or devices needed, which staff will provide assistance, the procedures to be followed to ensure the student’s safety, and any accommodations and related services that support the plan.
It’s important for parents of children with mobility issues to know that unless a parent requests otherwise, the school will most likely default to the “shelter in place” procedure for children who are unable to safely use the stairs to evacuate the building. As mentioned earlier, not only is this discriminatory (though currently legally acceptable), in practice it often fails. While the fire department will have the procedure for that student on record, whoever is working the day of the fire drill or actual emergency will need to know (and remember) the plan, and if they don’t, school administrators must notify the fire department when they arrive that a student is waiting for rescue.
Instead, consider asking the school to purchase an emergency evacuation chair (ideally, one for each set of stairs). They are easy for one person to use, can be easily wall-mounted at the top of the stairwell, and once practiced with staff members, will become part of the evacuation routine. If your child is ambulatory with assistance, you can also ask that working on stair use be added to the IEP as a PT goal.
Above all, Arroyo adds, it’s important to keep the plan realistic. During real emergencies, people are running around and plans may not be followed. For example, if your child needs an aide during an emergency, Arroyo recommends utilizing a peer. “Inclusion is always so important because in a typical classroom, where a student with a disability is fully included, there are plenty of options available for other students who can help them out,” he says. “So in my mind, I would be looking for really feasible solutions that can be done in an actual emergency.”
The key is in the implementation. Teachers, students, and school staff must take the plan and find ways to implement it, such as making sure everyone is up to date and trained, as well as making sure the student is learning and practicing the plan — keeping in mind that students with disabilities may need more drills to prepare. The team should also plan for regular (at least annual) review of the plan to accommodate new placement, new classroom, new school, etc.
Here is an example template of what an IELP can look like. You might also consider creating a one-sheet emergency plan for easy reference that communicates your child’s primary support needs quickly. If you're an Undivided member, check out this emergency plan template.
Sample school safety checklist
To help prepare an IELP or safety plan, Undivided members can check out this list of questions and considerations to bring to the next IEP meeting.
How to talk to and prepare your child for safety measures
As difficult as it may be to talk to your child about disasters and safety, making sure that students are prepared and know how to keep themselves safe is vital in emergency planning and preparation. Dr. Pelangka recommends adjusting the conversations appropriately to ensure that your child is a meaningful participant and can digest the information at a level that is accessible to them, and encourage them to ask questions. It can be helpful to use tools such as Social Stories, visual schedules (here’s an example), priming, using less threatening language, and a lot of repetition when it comes to talking about why it's happening and why we practice it.
Here are a few examples of stories that talk about lockdown drills:
When it comes to practice, Dr. Pelangka says it’s a good idea to keep the drill as realistic as possible, making “almost like a muscle memory for them.” Asking the school for whatever resources they’re using and having copies at home can help maintain that consistency.
Arroyo adds that a training plan should include helping the child move themselves out of positions of danger and into positions of safety, learning to recognize when an emergency is occurring, and knowing when to speak up or make a noise so that they’re noticed and found by rescuers.
You may also want to create an emergency contact card to keep in your child’s backpack.
What to do if the school doesn’t create an adequate emergency plan for your child
If that doesn’t work, Collin suggests asking the school for a copy of the district's policy for addressing emergency situations. “You will likely be able to utilize this document to support the creation of a proactive plan that enables the student with a disability to participate fully in the emergency proceedings,” she says. “If the document specifies something different for all students with disabilities, or the school/district representatives refuse to create an appropriate plan to keep your child safe, or if you feel the plan that was created is unsatisfactory, I recommend seeking advice from an attorney who specializes in disability law.”
Another option is to file a discrimination complaint with the Office of Civil Rights (OCR). “That might be an appropriate option for people to exercise after they've tried to work with the school in a truly collaborative way,” Arroyo says.
How to be a meaningful member of the IEP team
During IEP meetings, teacher conferences, or other school events, make sure everyone is up to date on the emergency plan, especially if there are any new staff members working with your child.
Follow up with your child’s IEP team after a drill to see how it went, and whether there were any issues implementing the plan that should be addressed.
Consider inviting the school counselor to the IEP team to discuss the emergency plan. “The school counselor is a really big resource,” says Dr. Pelangka.
Call your police department, fire department, paramedics, and first responders and see if there is training in place that teaches them how to recognize when somebody has a developmental disability and how those people may respond to their instructions. It can also help to inform emergency personnel of your child’s plan each year.
While we can’t control external threats and monsters, we can be active in creating plans, resources, and tools for our children when these threats present themselves. Check out our back-to-school toolkit for other ways to help make your child’s school year as smooth as possible. For tips on navigating a school campus, check out our campus orientation checklist.
Have you heard about the new CA senate bill that aims to create inclusive emergency safety procedures?
There’s a new bill in town! On October 8, 2023, Senate Bill 323 was passed, which addresses the need for emergency safety procedures in schools for kids with IEPs. SB 323 is meant to address the lack of inclusive emergency plans in schools, which often results in students with disabilities being overlooked during evacuations, earthquakes, lockdown protocols, and other emergencies. SB 323 aims to help teachers, staff, and emergency responders keep all students safe.
Here are a few major provisions of SB 323:
- Requires school disaster procedures to include adaptations for students with disabilities in accordance with the federal Individuals with Disabilities Education Act and Section 504 of the federal Rehabilitation Act of 1973.
- Requires an annual evaluation of the comprehensive school safety plans which includes a review to ensure that the plans include appropriate adaptations for students with disabilities.
- Authorizes any students, employees, or parents to bring concerns about an individual student’s ability to access emergency safety measures described in the comprehensive school safety plan to the attention of the school principal. If the principal determines there is merit to the concern, the principal must direct the school site council, school safety planning committee, or charter school to make appropriate modifications to the safety plan as part of the annual evaluation process.
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