Making School Safety Plans Safe (again, for the very first time)

Schools in California are required to have a School Safety Plan… and that plan is required to have provisions to address the needs of disabled students.

This isn’t happening.

What do you do when you find a hole in a system?

• You can complain about it.
• You can do nothing
• or maybe you can propose a fix and get implemented and make things actually better.

… or do a bit of each… but let’s get started :)

How do we “hack” our disability systems to make them better?

I’m not sure, but maybe we can figure it out together.

The law says this, but….

(AB-1747 School safety plans –  Approved by Governor  September 27, 2018) 32282. (a) (2)(B) Disaster procedures, routine and emergency, including adaptations for pupils with disabilities in accordance with the federal Americans with Disabilities Act of 1990 (42 U.S.C. Sec. 12101 et seq.). The disaster procedures shall also include, but not be limited to, both of the following…

So, this isn’t happening 7 years later.

I’ve commented on this publicly at school board meetings and raised it at site council meetings a number of times to no real effect.

And I know this problem doesn’t just exist in my school district. It seems to be across-the-board.

What would a fix look like?

Instead of just complaining, perhaps we can offer an answer that is easy and ready to go?

So let’s start talking about what a fix is and see if we can get it get that implemented

… and do some level seven disability system hacking

What do “adaptions for students with disabilities” look like as a system?

• Actual incorporation of Disabled Students (both with IEPs and 504 Plans) into the School Safety Plan.
• Means for Parents/Guardians to verify that a Disabled Learner has appropriately consider in the SSP.
• Aggregate Reporting from School Districts on the compliance of their schools and remediation plans for non-compliant schools.
• Aggregate reporting by the state on the compliance and remediation plans for non-compliant school districts

The Easy Piece – Add a form to IEPs and 504 Plans

Let’s do the easy part first. Add a form into the IEP and 504 plan where parents can review and sign off on the School Safety Plan, and either agree that it meets their needs or document concerns that they may have.

Categories could be: Satisfactory. Satisfactory with Concerns. Unsatisfactory.

… with the school having 30 days to provide an updated plan for the parents review (no meeting necessary)… and an opportunity to update the parents’ response.

Easy Continues – Rolling it up – School Reports to School District and to the State

The school reports get aggregated along with the individual form responses into a report to the school district… and the school district rolls up their school reports to the state.

… which hopefully actually looks at the data to see if there are trends and pushes school districts to do better..

Woot … good government.

What does a better School Safety Plan look like?

The School Safety Plan is why we are here and of course needs the most attention. There are really only four new document sections:

• Standard procedures to maximize “accessibility” and address disability systemwide (default accessible for school safety – I need to write up “Schools need 504 plans not students” sometime !!!)
• A top-level schedule for finding disabled students on any given day at any time.
• Unique/specific needs and accommodations for individual students – with specific information for aides, teachers, and public safety personnel.
• * Traceability Matrix

NOTE – Actually if you are really good you would not need the separate standard procedures for accessibility but rather have accessibility organically already in your document but we’re probably not there yet :) !

And four areas where you would where we need to integrate disability into what is hopefully acting in existing parts of the school safety plan document:

• Adding Disability into School Training Program
• Adding Disability into School / External Agency Training and Coordination Program
• Reporting on Training Exercises (twice? a year)
• Reporting on External Coordination and Training (at least once? twice? a year)

* If you are doing a good job of integrating disability into the base document you likely would need or want a traceability matrix to allow you to track between disability requirements and the main document so that you can do auditing more efficiently.

Documentation Strategy – Minimize Separate Disability Documentation

The reason I strongly recommend minimizing separate documentation is based upon my decades of work in the information security field. When I started working on security issues for the National Security Agency, we actually had an entire parallel set of documents that were created just for us to address security matters.

On one hand, this made my life easier in that I could look at all this documentation all in one place just for me.

On the other hand, the problem was that the document was created just for me as the security reviewer and so was not part of the ordinary operations and software development practices of the people we work with working with.

The worst case of this was in one project where the security documents were all classified and kept in a separate vault in a separate room and the main documents were all unclassified which basically meant that the ordinary team never ever looked at them so security was not being integrated into the system at all.

Let’s not repeat the same mistake for disability documentation!

Next Steps…

It is time to build some templates! Let’s make it easy for schools, school districts, and states to do the right thing (my action, any and all help welcome!).

Work with your local school district to see where they are at on their school safety plan (if it isn’t functional for everyone, it certainly won’t be functional for disabled students!).

Not in California? What is the situation where you are at for contingency planning? Your school, workplace? city? state? country? (much less for disabled people and contingencies)… let me know!

Start working with the appropriate officials to implement good contingency plans / crisis management plans… and make sure disability is part of the process.

Work with elected leaders to require mechanisms to be implemented… and make sure there is real oversight and reporting!

I’m missing anything here?

If we don’t care enough to make these things better – no one else is going to.