Incident Command System Should Not Be Used For Continuity Of Operations

Curtis BartellHere is the backdrop for common understanding: INCIDENT Command System (ICS) is a nationally adopted standard command-and-control hierarchical structure for multi-agency RESPONSE during an incident. Continuity of OPERATIONS is a highly customized and personalized process to SUSTAIN/RECOVER your operations/business after a disruptive event. 

Let me reiterate, the ICS should not be used as the organizational structure to continue operations. No way, no how. I promised a few articles ago I was going to tackle this issue – an issue which has evolved over the last 20 years or so. I will add my theories on why a preponderance of well-intentioned folks have advocated the ICS structure be used as the “logical” (to them) structure to continue the operations of an organization. I believe I speak authoritatively on this having had both feet squarely planted in emergency management and continuity communities over the past 33 years.

The ICS is a standardized approach to the command, control, and coordination of emergency response providing a common hierarchy within which responders from multiple agencies can be effective. By design, it has a wind down and cessation component and is not designed for sustained operations. The goal and intent of ICS is to mitigate the incident (put out the fire, rescue the flooded, find the trapped, etc.). 

The system is not "recovering" anything. ICS can wind down and leave with the earth scorched, buildings in ashes, businesses shuttered, etc. It is designed and intended as the national system allowing emergency responders to integrate resources and respond under one directive authority. It is outstanding for its purpose. Command…control…coordination, the same things required in a continuity situation. But under the surface, they are nothing alike.

Albert Einstein once said, “man should look for what it is, not for what he thinks it should be.” Curtis Bartell says, the resilience community (is there such a collective? --- wishful thinking) should look at each sub-discipline for what it is, not apply unique constructs elsewhere because the good idea fairy waved its wand. To paraphrase, you can’t fit a square peg in a round hole just because you wish it was round or wish it would fit anyway. 

ICS’s focus on emergency response is designed for time-urgent integration of life-saving resources and responders nationwide are trained and certified so, for example, a forest fire unit from Idaho can walk in and seamlessly integrate with a unit from New Mexico. I use this example to take us back to the origins of ICS in the U.S. Forest Service in the 1970s as a tactical field operational structure.

Albert Einstein once said, “man should look for what it is, not for what he thinks it should be.” Photo public domain

Similarly, the National Incident Management System (NIMS) was designed to integrate federal resources into State and Local responses utilizing the ICS constructs. As one of the significant contributors to the NIMS concept and development after 9/11, I know what it was intended to do, as well as not do. Both are very effective in my view and have enhanced emergency response activities substantially.

Continuity of Operations and Business Continuity are part of the spectrum of resilience elements, just like emergency response. Continuity’s goal is to re-establish the organization’s day-to-day operations with one focus: continuing essential functions. Essential functions differ between government entities and commercial industries but are alike in that those functions are critical to the sustained viability of the organization’s missions.

Let’s rattle off a few common essential functions: decision making, funding, human resources, facility operations, and systems and networks to name several broad arenas. Wait a minute, ICS provides management hierarchies to control funds, personnel, facilities, equipment, and communications. Eureka! That was an easy fix. Unfortunately, far too many come to this obvious, but incorrect, conclusion. 

First, ICS is a “temporary” management hierarchy to do all these things for emergencies, or, as the name suggests, “incidents.” The only things temporary about continuity of operations is perhaps alternate locations and systems…but it definitely is not management. In practice, management (or those fully delegated authorities) and its structures remain intact.

Second, is continuity an incident? Ah hah! I caught you all looking at each other to see which way to nod your head. Let me save you the embarrassment --- it is not. Continuity is a condition, not an incident. An incident can force a continuity condition…so can a threat. In some instances, I suppose a threat might require the ICS structure to help organize response elements in waiting.

However, I can assure you that continuity must consider emergency response as an essential function. And, within that essential function, and only that essential function, ICS should be used. It should not be applied to other essential functions nor the overarching management/decision making of the whole organization. Why would a “temporary” and foreign management hierarchy suddenly be used to continue the same functions you were doing yesterday? Nothing like adding another layer of complexity to an already complex recovery.

As outlined in my last article Resilience Must Be Blind to Catalyst - Part II, this scenario would imply the fire chief or chief of police or other incident commander might be running a Cabinet Department’s essential functions or a global technology company or a hazardous industrial complex. I am simply stating ICS is for a very specific, temporary purpose…and that is most certainly not to make all day-to-day decisions on the strategic and operational directions of an organization. 

So why am I spending a couple hours on a Sunday afternoon musing about this? Because it has been said the continuity community “eschews” ICS and emergency response. Yes, this insult was hurled at me in an online, public forum. Hurtful words they were…but I got over it with a few minutes of therapy. That comment is not typically true, at least not from this emergency management and continuity professional. ICS has its well-established place and that should never change.

Daytime wildfire in California. ICS is designed to coordinate emergency response. It is not designed for Continuity of Operations following a disaster. Photo credit BLM public domain

In a continuity condition, that place is to manage the incident. I have also heard it said that ICS "can be used to manage my kid's birthday party." Admittedly, a kids birthday party is fraught with potential incidents but I would think common sense would prevail in this situation. It was a horrible analogy and spoke of the true misunderstanding of how ICS is to be used.

I believe much of the cross pollination of concepts and nomenclature came out of the post-9/11 “great idea” factory, some of which landed in the homeland security, public safety, and other similar educational and planning arenas. Thankfully, I have not seen much of this in the national policy discourse where any such mixing of right structures for wrong purposes would really become a mess. If that happens, I just might retire. “Good” ideas do not hold up to experience and knowing what it is, not what one thinks it should be.


Author: Curtis Bartell is the President and CEO of Covenant Park Integrated Initiatives, Inc and Managing Partner of Covenant Park Preparedness Systems Integration, LLC. Special thanks to the contributions of Mr. Dean Gallup and Dr. Jeremy Boccabello.