Quis custodiet ipsos custodes?
Let us look at this question in the context of the ongoing debate (at least on LinkedIn), as to whether Emergency Management is a profession, rather than just a set of tasks (or some other belittlement or denigration, IMHO). I have already staked my position in another EMN post for The CEMIR, that Emergency Management is really a profession, and therefore Emergency Managers are in fact, professionals. I have made the point that Emergency Response Services and Emergency Responders can be elements of, and in many cases subordinante to Emergency Management, but that it is not the other way around. When you see leadership in Emergency Services, the public may see them in their response leader roles only, but they are in fact full cycle and full command:
Full Cycle: They look at the totally of the disaster cycle phases, the preparedness (what I like to call Readiness) missions, etc. They are as much into Protection and Prevention against adverse impacts before they occur, as they are keeping everyone safe in Response. They are also helping their community Recover and Mitigate against future incidents, emergencies, disasters, etc.
Full Command: They look at the totally of the functions needed, beyond Operations. They are keenly aware and assist in furthering cost-effective solutions through their community’s Financial and Administrative departments. They coordinate with urban and community Planners, they partner with public works, health, and work closely with other departments in their jurisdiction (and above) who are not normally traditional “first responders” to gain coordination and collaboration for Logistics. And the wisest Emergency Services leaders quickly realize they are not experts in everything and surround themselves with Intelligent people - including Liaisons from other organizations - who can provide them the essential elements and knowledge which they need to serve their communities, helping to Communicate all of this to the public, while keeping all their community group’s workforce Safe.
When you see a leader in Emergency Services do all of this – and collaborate, coordinate, cooperate, and communicate with their peers, partners, stakeholders, etc. – then you see professional Emergency Management taking place. And those leaders in their respective professions, are the Watchers over others – advocating for the best support by organizations to serve the public fairly - so they may remain vigilant in their ethos.
Compared to just about every other Emergency Response Services group (police, fire, EMS, etc., even expanding this view into healthcare, national guard units, public works, private utilities, and beyond), Emergency Management is quite a young profession in the United States. Originating in the civil defense days from World War II, and then becoming more formalized in the 1970’s, we do not have a rich history of professionalism. Rightfully so, they do not name things like buildings and ships after us. We are not journeymen, nor do we formally apprentice for years, as a requirement to be considered a ‘master’ of our profession. I dare say, neither do information technologists or accountants, either. Again, we do not have to be heroic to be professional (and I will again make the point that if a professional Emergency Manager is really doing their job the right way – even during the worst disaster - they should remain safe themselves, and not have to be in the position to do anything heroic). It can be as simple as this: if you are not wearing comfortable shoes to work every day, you are not in Emergency Management.
Sometimes Emergency Managers may wear a different hat – such as managing a shelter, running a warehouse, or writing mitigation grant funding applications – those roles all still require a high degree of professionalism – and for the Emergency Manager, an opportunity to share their overarching and holistic wisdom with others. We are big-picture thinkers (and achievers). If a fire chief rushes into a burning building to safe a child, no doubt that is heroic (and in a dramatic and very tangible difference between Emergency Services and Emergency Management, they are almost always in positions to put the life safety of others ahead of their own – some would say, even obligated to). That takes valor. And I have deep respect and admiration for those professionals who do Emergency Response Services, and who have significant penalties when either they – or their Emergency Response Service organizations act unethically.
The bottom line is that we need to have this same type of accountability for our actions, being Emergency Managers and Emergency Management organizations.
Back to the question of “Who watches the watchers?”
While I have mixed feelings about requiring an oath to an ethics statement (see my previous blog post, again), I also still stand by the need for there to be consequences for both the unethical Emergency Manager and the organization where they work/volunteer. For me, I can align this with the financial services profession (i.e., stock brokerage). In that profession, you need a license from each state where your clients reside to sell stocks, bonds, mutual funds, etc. – and your firm needs to be licensed in those places, as well. You may see “independent” financial advisors out there, but if they are selling anything – they must do it through a firm, which is licensed as well. Yes, this licensing feature is different from Emergency Management (as are other licensed professionals), but that is a legislative action, which was taken to protect the public. Does our profession need this type of licensing? An open question, to which I certainly welcome the thoughts and opinions of other Emergency Management professionals to comment on. Regardless of the licensing question (think back to the accountants and IT folks I compared us to, earlier for some examples of unlicensed professionals); in the financial services field, if you do something unethical in your dealings with the public – including certain illegal activities in your personal/private life – someone can file a complaint against you, which can result in fines, suspension of your licenses, even expulsion from the profession. And this is all done as a very transparent process.
Full disclosure, I was once a licensed financial advisor/branch office manager and had a financial advisor in my office receive an unfounded claim against them. As their supervisor – and receiving a small portion of the compensation for the sale of the product to the client (I think it was under $500) - I too, received a complaint marked on my record. My firm investigated the client complaint and found it unfounded, FINRA reviewed all the reports – including the client’s complaint – and also found the allegation without merit. Still, both I and the financial advisor had permanent marks on our records for “client complaints: yes”, for at least 10 years, after the complaint. I looked at the FINRA records recently – and am no longer listed, since I have not held any securities licenses in the last 10 years.
Physicians have something similar, but I believe it is state to state. I know there is talk about something like this nationally for police officers, but that has not yet come to fruition. My point is that it is also the firm which is held liable for any ethics violation or other breach of professional conduct. In Emergency Management, this should mean, for example in egregious situations (not for me to decide, of course) that an Emergency Manager might lose not only their job, but their CEM® credential, and that an organization not only be subject to civil court penalties (consent decrees, fines, etc.) but also lose their EMAP accreditation.
We need an independent group, like FINRA, to watch the watchers. And with the teeth to hold organizations who force Emergency Managers perform unethical actions, accountable.
The IAEM-USA, led by its 1st Vice President, is now looking at adding processes for protecting its in-person conference attendees from unethical behavior (one of those negatives from being a ‘profession’, actually: when you put a bunch of professionals together – mixed with alcohol - at an offsite conference, you get unprofessional behavior from a small few – but even one is intolerable. This aspect of being part of a profession is in no way unique to our field or practice. I have volunteered to help them, but from a bigger picture kind of thing, which I am describing in this post. I look forward to both tactically punishing those who behave badly and strategically deterring others from doing so in the first place (look ma, it’s Protection and Prevention, from a non-Law Enforcement/Homeland Security perspective). In my undergrad days, I spent two years as a student member of the university’s judiciary hearing board. As part of a three-member panel, we heard complaints against students, where they risked being suspended or expelled for breaking the university’s rules. It is a rude awakening to tell your parents you got kicked out of school, and not for failing classes. I do not know if it is part of freshman orientation to explain that the university’s rules and regulations are in fact independent from laws in the state, and that you can be punished and penalized, from both. Unethical behavior also does not have to rise to the level of illegal activity, either.
As a fairly new profession, we have the opportunity to be more transparent up front – to tell those who want to become professional Emergency Managers that there are duties and obligations to maintain high ethical standards – and to watch for others who do not.
What about Risk Management?
Also needed in Emergency Management is a clearer set of roles and responsibilities towards Risk Management. The NIMS/ICS for Responses places much of that responsibility on the designated Safety Officer. Too many times, there are commands stood up (in GO and NGO operations) without the designation of a Safety Officer. Then it falls back to Command (per NIMS/ICS), who is usually overworked and overwhelmed already. Should risk management be performed with ethical behavior in mind? Absolutely.
In the corporate world, risk management is a full-time job to protect the “bottom line” and (hopefully) their workforce and the public. Their version of the LIP is not the same prioritization as Emergency Management’s. At the Center for Emergency Management Intelligence Research, we are working to shift the paradigm in the corporate world, too – to show them the value of Emergency Management when they need to operationalize their Risk Management. In our Emergency Management world, think about Continuity of Operations/Government as Risk Management – and how critical it is for all of us to integrate those missions/roles into full cycle work. Our ethos means our priorities for Emergency Management supersede others, even elements of Risk Management.
What about Compliance?
Compliance is needed, too. In many cases, this is performed by Finance/Admin folks, both in steady-state and disaster-state. Emergency Managers need to consider aligning with and adhering to Compliance’s protocols, guidelines, etc. on a full-time basis. The Planning P should have Compliance baked into it. When Command “calls an audible” and goes against the plan, chances are they will be out of compliance – and possibly conducting something illegal or unethical. As an independent Emergency Manager (I am not employed by any Emergency Management organizations, other than my own), I am still subject to the rules, regulations, policies, procedures, ethical standards, etc. of the organizations I serve with – as a consultant or volunteer or both – and I have a duty of care to remain in compliance with the Emergency Management organizations I belong to as well – including my status as a Certified Emergency Manager®, from the International Association of Emergency Managers (another full disclosure, I am an IAEM-USA member, caucus chair, and the vice president for Region 2). I believe Emergency Managers need to stay within Compliance’s guidelines, as long as they do not conflict with our own ethical mandates. Hospital Regulators would never require a hospital and its doctors to violate the Hippocratic Oath, and neither should any level of government require the same of an Emergency Management group, nor its Emergency Managers.
Michael Prasad, MA, CEM® is the Executive Director of the Center for Emergency Management Intelligence Research, and is currently working on his first book – Emergency Management Threats and Hazards: Water.