Proceedings of a Workshop—in Brief

Contingency Planning and Training of Personnel Rule: One Year of Implementation

Proceedings of a Workshop—in Brief

The importance of structured planning to “minimize the impact of disasters on the health and welfare of all animals covered by the Animal Welfare Act” (Federal Register, 2012) emerged as a lesson learned from Hurricane Katrina in 2005. In response, the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) issued a final rule in 2012 requiring research facilities, dealers, exhibitors, intermediate handlers, and carriers working with regulated species to develop comprehensive contingency plans to respond to emergencies and ensure personnel are adequately trained to react when needed. This rule reflects insights gained from past experiences to better safeguard animal welfare during disasters. On July 31, 2013, the USDA stayed the regulation to allow for a comprehensive assessment of the unique circumstances and varying costs faced by different organizations affected by the rule. The stay was eventually rescinded, and the USDA’s Contingency Planning and Training of Personnel Rule (APHIS 2020-0101) (the Rule) went into effect on January 3, 2022. The Rule mandates that all regulated institutions that do not meet di minimis exemptions for implementing contingency plans ensure the humane care of their animals during emergencies or disasters as specified in its regulations (Federal Register, 2021).

APHIS requested that the National Academies of Sciences, Engineering, and Medicine’s Roundtable on Science and Welfare of Animals Involved in Research—under the Board on Animal Health Sciences, Conservation, and Research—convene a public workshop examining the successes, challenges, and lessons learned from the first year of the Rule’s implementation. The hybrid workshop was held on June 4–5, 2024, and included representatives from various sectors of the research community sharing their experiences, strategies, achievements, obstacles, and insights about the Rule. This Proceedings of a Workshop—in Brief provides an overview of the workshop, including a summary of presentations focused on the outcomes of two surveys. The surveys were conducted to solicit feedback on the Contingency Planning Rule, including the implementation of contingency planning and personnel training, lessons learned from real-world disasters, institutional roles and responsibilities for contingency planning, strategies for developing a successful training program for responders, and potential stakeholder needs for the future. Workshop speakers represented diverse sectors—including government, industry, and academia—and provided perspectives from their organizational roles. This multidisciplinary dialogue underscored the importance of cross-sector collaboration to address the complexities of effectively implementing

the Rule. This Proceedings of a Workshop—in Brief has been prepared as a factual summary of what occurred at the workshop. The planning committee’s role was limited to planning and convening the workshop. The views contained in this Proceedings of a Workshop—in Brief are those of individual workshop participants and do not necessarily represent the views of all workshop participants, the planning committee, or the National Academies of Sciences, Engineering, and Medicine.

REGULATORY OVERVIEW AND WORKSHOP CHARGE

Dr. Louis DiVincenti of USDA APHIS discussed the events preceding USDA’s decision to enact the Rule. He explained that USDA recognized the need for comprehensive contingency planning to minimize losses and reduce facility recovery time following an emergency. Specific requirements in the Rule provide a framework to assist facilities in developing practical and effective plans to safeguard the health and welfare of people and animals during a disaster or emergency. He added that it is important to reassure the public that regulated facilities have adequate measures to ensure animal safety during both common and catastrophic emergencies.

The term “contingency” was deliberately selected to broaden the Rule’s scope and avoid potential limitations that might accompany legal connotations associated with terms like “emergency” and “disaster.” DiVincenti said that the Rule does not attempt to impose a universal plan for all facilities, but instead provides a framework of four criteria that should have been incorporated into all plans starting July 5, 2022. The criteria are modified from the U.S. Federal Emergency Management Agency’s Ready Business campaign and include: (1) identifying reasonably anticipated emergencies that should be included in the plan; (2) outlining specific tasks; (3) establishing a chain of command for emergency response; and (4) addressing response and recovery efforts. Additional requirements include annual reviews of the plan and staff training within specified timeframes (see Table 1).

USDA initially estimated that most facilities could develop and document a contingency plan in 4 to 6 hours and provided an optional form (i.e., Form 7093) with the 2021 Final Rule intended to reduce that duration to 1 to 2 hours. DiVincenti concluded by explaining that the primary purpose of this workshop is to inform USDA about the Rule’s effectiveness and impact on the research community, focusing on the challenges experienced since implementation and specific opportunities for USDA to better prepare facilities for emergencies.

TABLE 1
Timeline of Required Actions after Rule Implementation

Dr. Taylor Bennett of the National Association for Biomedical Research provided a comprehensive summary and analysis of USDA-issued citations on contingency planning since the Rule went into effect. Concerns with “contingency planning” [9 CFR § 2.134] were the leading cause of citations issued to all licensees and other registrants in fiscal year 2023, Bennett said. In fiscal year 2023, a total of 152 citations were issued and a majority of those citations were given to exhibitors.

Bennett pointed out that research facilities were cited for Rule-based noncompliance [9 § 2.38(l)] a total of 37 times in fiscal years 2022, 2023, and the first half of 2024. Table 2 provides a comparison of the types and numbers of citations issued to research facilities in fiscal year 2023, with deficiencies related to contingency planning ranking sixth overall. Common reasons for citation that Bennett noted included: (1) failure to have a plan; (2) no plan available for inspection; (3) no documentation of training; and (4) failure to review the plan. Bennett said, in his analysis and perspective, the majority of the research facilities receiving citations were smaller programs, most likely because they lack the programmatic expertise commonly associated with larger programs. Seven of the facilities that received citations were veterinary technician training programs, and an additional seven cited for training deficiencies were accredited by AAALAC International.

TABLE 2
Number and Types of Citations Issued to Research Facilities in FY 2023

DiVincenti clarified that USDA does not dictate how facilities develop their contingency plans, although animal facilities staff should probably be heavily involved in the process. DiVincenti also clarified that organizations are free to refer to their contingency plans as an “emergency plan” or “disaster plan” if that is more appropriate. He also acknowledged that emergency conditions may force facilities to deviate from their established plans and that none have been cited for “not following their plan,” although citations may result if preventable animal welfare concerns are noted.

COMMUNITY INPUT: RESULTS FROM TWO NATIONAL SURVEYS

Two surveys were independently conducted prior to the workshop to gather feedback from the research community on challenges encountered during the first year following the implementation of the Rule (see the supplemental material for the results of the survey that was conducted by the Workshop Planning Committee). Over 80 percent of the workshop audience had not participated in either survey.¹ In a live poll conducted at the beginning of the workshop, workshop participants self-identified as veterinarians, Institutional Animal Care and Use Committee (IACUC) staff, IACUC members, institutional officials, university leadership, and other. The live poll respondents communicated through the poll that they were aware that USDA published the final Rule in 2021, and a majority (80 percent) of workshop attendees were involved in contingency plan development at their institutions.

Federation of American Societies for Experimental Biology Survey

Dr. Naomi Charalambakis of the Federation of American Societies for Experimental Biology (FASEB) presented preliminary findings of a survey focused on the impact of the Rule on research programs that work with animals.² The survey aimed to gather feedback on Rule-based implementation experiences, training program effectiveness, and ways to enhance guidance across various institutions. Participants included IACUC members (25 percent), IACUC administrative staff (21 percent), veterinarians (19 percent), animal care staff (14 percent), researchers (11 percent), institutional officials (4 percent), university leadership (3 percent), emergency response representatives (2 percent), and environmental, health, and safety (EH&S) personnel (1 percent). Universities and colleges (69 percent), biotechnology companies (10 percent), federal facilities (7 percent), state facilities (6 percent), pharmaceutical companies (6 percent), and animal breeding facilities (2 percent) submitted responses. Most respondents indicated they had disaster response plans in place prior to the Rule’s implementation but struggled with the Rule’s requirement to train new employees on emergency response within 30 days of their hire date. Charalambakis described the collaborative but time-consuming process of developing contingency plans and emphasized the diverse approaches taken by different organizations to establish their plans. She observed that a majority of institutions had existing plans that aligned with the Rule’s new requirements, which streamlined adoption. However, according to the FASEB survey, nearly half of the respondents required more than 15 hours to develop their plans, compared to USDA’s estimates of 4 to 6 hours—or 1 to 2 hours when using Form 7093.

Charalambakis underscored the varied interpretations and implementations of the Rule, including how different institutions designed plans to align with unique operational procedures and requirements. The FASEB survey showed that more than 90 percent of respondents were familiar with the Rule and more than half of those found it moderately or very easy to understand and implement. However, obstacles were also highlighted, including difficulties in anticipating every possible emergency

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and creating an appropriately detailed yet flexible plan. She reviewed challenges and successes noted by survey respondents and underscored the importance of continuous refinement—especially following a plan’s initial activation. Charalambakis suggested that regulatory authorities should provide clear and effective guidance to ensure institutions understand these responsibilities and produce contingency plans that meet USDA’s expectations. Survey respondents highlighted tools that could assist their efforts, including sample contingency plans, a centralized frequently asked questions (FAQ) resource, training videos and classes, and additional guidance documents.

Workshop Planning Committee Survey

In preparation for the workshop, members of the workshop planning committee independently conducted a second survey that was disseminated to a slightly different audience than the FASEB survey—including veterinarians, animal facility personnel, and IACUC members. The results were presented by Dr. Susan Harper of the National Institutes of Health (NIH), planning committee chair, and Dr. Lesley Colby of the University of Washington, planning committee vice chair. The survey results are summarized in this Proceedings of a Workshop—in Brief’s supplemental materials.

Harper began by describing the process used to develop and disseminate the survey. The survey had a total of 195 respondents that were affiliated with a research program that involves animals and registered with the USDA. Many respondents were from academic institutions, while others represented industry/commercial, government, and other types of research programs that involve animals. Respondents were anonymous, with most identifying as veterinarians or IACUC administrators. Over 90 percent of the total respondents were familiar with the Rule, and more than half of the total respondents indicated that they found the Rule “moderately easy” or “very easy” to understand and implement. About 12 percent of respondents reported that they found it “moderately difficult” or “very difficult” to understand and implement the Rule’s requirements. Many respondents were aware of USDA’s optional Form 7093, and approximately half of those familiar with the form had used it as a reference or template. Harper noted that most respondents indicated their programs required more than 12 hours to develop a contingency plan and that it was difficult to design an adaptable plan that addressed the full range of likely emergencies. Generally, respondents across all organizational types said they needed more time to develop contingency plans than to complete other equally important responsibilities like updating their plans and training responders. Harper noted the benefits of a holistic approach that relies on a multidisciplinary team of subject matter experts with shared accountability for these functions.

Colby discussed survey feedback on the practical aspects of implementing and maintaining contingency plans. She noted that a majority of programs relied exclusively on didactic or lecture-based training formats and that very few programs involved outside authorities in their training. Respondents raised numerous questions about required training program content and components introduced by the Rule and commented that additional training resources could be beneficial. Colby also emphasized the importance of involving a wide range of organizational disciplines and expertise—from veterinary services to emergency management personnel. She highlighted the importance of integrating the unique needs of animal programs into broader institutional policies and plans and then described the iterative process for developing contingency plans, including ongoing evaluation and revision to maintain the plan’s value and relevance to evolving organizational needs and environmental shifts. Colby explained that a contingency plan’s effectiveness is revealed during actual emergencies, underscoring the importance of training and readiness. She urged research institutions to adopt a uniform process for developing and testing plans to ensure more consistent and dependable outcomes.

Community Input Panel Discussion

During the discussion, Charalambakis observed that while survey participants expressed confidence in their abilities to comply with the Rule, there is still a demand for more detailed guidance and easily accessible resources. Specifically, respondents indicated that standardized templates, comprehensive FAQs, and clearer instructions would be useful to facilitate more consistent and effective contingency plan implementation across diverse research insti-

tutions. Communication approaches may include a more accessible website where resources are clearly visible. Colby added that size and complexity may be why some institutions required more than 12 hours to develop their plans. Charalambakis suggested another reason might be differences in how respondents interpreted the question (e.g., number of cumulative hours between multiple persons or number of hours the group consumed as a whole). However, Charalambakis also noted that the significant time respondents spent developing contingency plans reflects their deep commitment to the welfare of their animals. Harper recognized that creating plans often demands considerable time and effort, although Colby noted that most institutions had already established plans prior to the Rule’s implementation and were minimally affected. Charalambakis felt that miscommunication—or lack of communication—between USDA and programs may pose further challenges in fulfilling Rule-based obligations.

Colby indicated that the requirement to train new hires within 30 days can be difficult and suggested that a longer deadline might yield better results. Several workshop participants agreed that the 30-day training requirement for new hires is overly stringent, and raised concerns about its practicality, especially for institutions with few staff or high turnover. Charalambakis suggested that USDA consult with stakeholders to determine an optimal timeframe for this requirement. Harper proposed other alternatives, such as using a phased or tiered approach for training or transitioning to a performance-based system that evaluates effectiveness. Finally, Colby and Harper discussed the importance of continuous improvement in contingency plans and the need to use real-world experiences and feedback to refine and adapt strategies. Colby noted, however, that some survey respondents seemed uncertain about who should be involved in contingency planning and what to expect from external partners. Many presenters, in addition to the session panelists, acknowledged the importance of continuous training for all team members and noted that an overall goal should be for all personnel to be thoroughly prepared to effectively respond during emergencies.

Harper stressed that the main priority of contingency planning is the physical safety and welfare of personnel and animals—however, program staff should also consider how emergencies can affect research integrity. She discussed responsibilities for aligning institutional policies with federal regulations and suggested stronger partnerships between research institutions and governmental agencies to improve contingency plan effectiveness. Harper also encouraged collaboration within the research community to address common challenges and exchange best practices that safeguard animal well-being and maintain research quality in the face of unforeseen events.

EXAMPLES OF LESSONS LEARNED FROM A VARIETY OF PERSPECTIVES

A panel of experts shared personal stories that underscored the importance of contingency planning. These lessons learned illustrated how the contingency planning process varies according to institution size and complexity, a person’s role within their organization, the type of research, and the workforce or population involved.

Attending Veterinarian

Dr. John Bradfield, formerly at the University of Nebraska Medical Center, explained the practical aspects of contingency planning from his perspective as a former Attending Veterinarian. He shared personal experiences from his previous involvement in real-life disaster responses, contrasting the gap that sometimes occurs between planning for hypothetical contingencies and the actual conditions and obstacles encountered while an emergency is in progress. In his experience, maintaining maximum flexibility and adaptability is critical because rigidly adhering to a pre-formulated plan may be impossible due to the high level of instability and unpredictability during these situations. Bradfield shared his perspective of disaster trends involving research animals and noted a majority were the result of internal institutional failures, such as mechanical system breakdowns.

Industry Representative

Dr. Gregory Reinhard of the University of Pennsylvania relayed his experiences as a former pharmaceutical industry employee. He discussed differences in resource allocation and management between major pharmaceutical corporations and emerging biotechnology firms,

contrasting how large companies with substantial capital investments, property, and in-house expertise can maintain essential functions during emergencies with minimal outside assistance compared to smaller businesses that rely on leased space and third-party support services. He said this disparity accentuates the importance of devising adaptable plans tailored to an organization’s needs. Reinhard noted that plans should be documented and integrated into everyday workflows and that all team members should be prepared to follow through without hesitation during emergencies. He also argued that plans should address both immediate and long-term needs so that tangible assets and operational capabilities can be maintained without compromising critical research activities during prolonged emergencies. He noted that activating contingency plans is often a balancing act involving proactive dialogue and collaboration among all stakeholders to negotiate a satisfactory outcome. Reinhard concluded with a reminder that “an ounce of prevention is worth a pound of panic later,” and reiterated the importance of backup systems for crucial operations, economical solutions for smaller facilities, and the value of pre-planning and cross-training.

American Veterinary Medical Association Representative

Dr. Warren Hess of the American Veterinary Medical Association (AVMA) emphasized the importance of effective communication and stressed the need for pre-prepared messages or briefs that can be easily disseminated during emergencies. He discussed various national- and state-level contingency planning resources, such as the National Alliance of State Animal and Agricultural Emergency Programs and the National Animal Rescue and Sheltering Coalition. These organizations promote preparedness and response capabilities across different jurisdictions and provide important mechanisms for networking with local, state, and federal authorities. Hess also highlighted AVMA’s educational initiatives, including the Disaster Business Continuity Certificate Program and the Veterinary First Responder Certificate Program. Both programs aim to provide veterinary professionals with essential skills to manage emergencies effectively. He reiterated that although written plans are necessary, it may not be practical to refer to them during an emergency, and personnel need to be adequately trained to make sound decisions and take appropriate actions instinctively. Hess also stressed the importance of building strong alliances with local emergency response networks, highlighting the need for clear internal communication and impactful public outreach that is sensitive to how this information might be perceived and understood by various audiences.

National Research Facility Director

Dr. Kasi Russell-Lodrigue of the Tulane National Primate Research Center (TNPRC) addressed the audience as the director of a large national nonhuman primate breeding and research facility. She described how the TNPRC contingency plan was required to conform with standards and industry best practices adopted by various external authorities including AAALAC International, and that the plan was implemented before the Rule went into effect. The TNPRC has proactively approached regional threats like severe weather and hurricanes by actively tracking them and incorporating effective mitigation strategies into existing contingency plans. Russell-Lodrigue emphasized the value of developing targeted and adaptable components within the larger overarching plan to address specific incidents like utility disruptions and equipment failures. She explained that some of the components in TNPRC’s plan apply to a variety of events and can be deployed across various emergencies, like how their influenza outbreak plan was used as the foundation for a subsequent COVID-19 pandemic response. Russell-Lodrigue urged organizations to regularly review and update their plans to maintain a constant state of readiness to respond to a wide range of threats.

Institutional Official

Dr. Oliver Garden of the Louisiana State University School of Veterinary Medicine focused on the challenges he encountered as the leader of a large complex academic program. He reflected on managing complex emergencies like hurricanes and flooding that have wide-ranging consequences for animals, students, staff, faculty, and the public. Garden recalled the harsh realities of responding to emergencies and praised the cohesive community spirit he witnessed during these events. His examples were intended to showcase the value of effective preparation and rapid resource mobilization and highlighted the benefits of developing strategic partnerships outside the institution to overcome these challenges. Garden noted that effective emergency management in a diverse aca-

demic environment requires a multifaceted approach to maintain critical services, protect people, and safeguard valuable assets like ongoing research. He discovered that keeping accurate contact information is crucial, yet often overlooked, as it is necessary for maintaining seamless communication with all members of the academic community. An inclusive approach to contingency planning ensures the institution has access to a broad pool of talent ready to contribute to planning and response efforts, facilitating an agile and effective response regardless of the nature of the emergency.

Information Technology Expert

Charles Benson of the University of Washington highlighted rapid technological advancements that have reshaped how organizations approach contingency planning. He explained the crucial role that the Internet of Things (IoT) and operational technology systems play in the routine operations of research laboratories and animal facilities, including remote sensors and automated systems for controlling differential room air pressure, temperature, air quality, water quality, and lighting. Benson shared examples of how programs increasingly depend on these technologies and how the interconnected nature of these systems present exploitable vulnerabilities and cybersecurity threats. Effectively managing these threats requires management of both internal and external factors. External factors include supply chain disruptions and internal factors include gaps in personnel technical expertise and improving coordination between information technology and facility operations teams. Benson noted that organizations should conduct regular inventories of IoT systems, maintain active relationships with vendors, keep software updated, and conduct tabletop drills to expose potential vulnerabilities. Benson introduced a four-pillar approach to risk mitigation, including: (1) policy; (2) education and outreach; (3) vulnerability and threat awareness; and (4) inter-organizational coordination. He echoed previous speakers’ focus on being proactive instead of reactive, emphasizing that having an established plan allows for more robust and flexible responses when unexpected emergencies occur. Benson concluded by acknowledging that new technologies are often powerful tools but must be thoughtfully implemented to avoid introducing unforeseen risks.

Lessons Learned Panel Discussion

After their presentations, panelists shared their thoughts on common errors in contingency planning and their unique successes. Hess commented that success lies in continuous improvement because planning is an ongoing process and does not have a finish line. Garden emphasized the importance of leaders adopting a holistic view during emergencies and encouraged them to celebrate successes and show appreciation for team efforts rather than focusing on shortcomings and setbacks. Hess added that mistakes are inevitable, but rigorously exercising and testing the plan often pinpoints unanticipated deficiencies that can be corrected before the plan is activated. Reinhard added that gathering input from maintenance, security, and other departments helps to ensure a comprehensive plan that accounts for all viewpoints. Bradfield suggested adding After-Action Reviews (AARs) as another option to improve contingency plans, with Russell-Lodrigue volunteering that AARs helped her institution navigate the logistics of feed transport when transportation routes were blocked or inaccessible.

Russell-Lodrigue also commented on the importance of establishing collaborative relationships with external partners through formal inter-institutional agreements developed with the input of key stakeholders, including veterinarians, IACUC members, program staff, and legal advisors. Bradfield noted the advantages of incorporating redundancy by establishing multiple agreements and backup plans, rather than relying on a single agreement, since some partners may also be affected during a large-scale emergency and unable to assist.

Finally, panelists reflected on the human dimension of emergencies and the profoundly personal effects on staff during these events. Garden volunteered that his institution has often had to provide shelter and refuge for members of the community, students, staff, and faculty whose homes are damaged or inaccessible during an emergency. Russell-Lodrigue and Hess emphasized the importance of employees creating individual and family contingency plans to address personal needs and ensure that they are available to respond during an emergency.

ROLES AND RESPONSIBILITIES IN CONTINGENCY PLANNING

A second group of panelists, representing disciplines vital to animal programs, described their roles and respon-

sibilities in the contingency planning process. Drawing from their respective areas of expertise, each shared the insights and specialized skills that they and other team members contribute. They explained how contingency plan effectiveness is strengthened and improved by the relationships and partnerships that develop during the planning process.

IACUC

Dr. Tracy Heenan of the University of North Carolina at Chapel Hill discussed ways the IACUC can be involved in contingency planning. Heenan’s survey of IACUC administrators confirmed that the IACUC’s role was typically secondary to veterinary and animal facility husbandry staff and varied from secondary review functions to active participation in plan development and implementation. Significant IACUC contributions included maintaining investigator contact information and other documentation, assessing plans during semi-annual program reviews, informing research staff about plans, participating in training exercises, and informing institutional leadership of potential threats. Heenan also discussed some of the IACUC’s challenges in participating in contingency planning, including its often ambiguous role in ensuring consistency between animal-specific and other institutional plans and its poorly defined training requirements. Heenan concluded her remarks by stressing the importance of having clear guidance on the IACUC’s specific contingency planning responsibilities and the value of additional resources like best practice guidelines, sample plans, and FAQs.

Animal Program Staff

Brian Ebert of AbbVie spoke about the value of engaging diverse stakeholders when multiple buildings and performance sites are involved in the contingency plan. His organization’s planning and implementation process includes veterinarians, facility managers, senior animal care technicians, group leaders, veterinary technicians, maintenance staff, security teams, and safety professionals. These multidisciplinary teams evaluate facilities, equipment, and infrastructure at least twice annually to characterize what has changed and how those changes may affect contingency plans. Ebert added that contingency planning is not a one-time obligation and stressed the importance of consistent and ongoing training for all employees, regardless of their experience level, to ensure everyone understands their responsibilities during an emergency. He discussed how infrastructure can be a significant factor during emergencies and suggested conducting regular drills—like simulated power outages—to ensure staff are familiar with emergency procedures and backup systems for critical operations. Ebert also suggested that institutions explore creative solutions to contingency planning, like sourcing supplies from alternate vendors during shortages. He concluded by sharing his philosophy for contingency planning success, which includes budgeting for future equipment upgrades, partnering with nearby programs to work together during emergencies, and maintaining accurate and current critical supply inventories.

EH&S Professionals

Katia Harb of the University of Washington highlighted the crucial networking function that Environmental Health and Safety (EH&S) professionals provide throughout the contingency planning process. EH&S professionals often function as intermediaries, linking internal stakeholders like institutional leaders, facility managers, veterinarians, and researchers to external entities like emergency responders, police, regulatory agencies, and local hospitals. EH&S professionals spearhead risk assessments, develop procedures, coordinate cross-cutting functions, serve on incident command teams, and ensure compliance with various regulations. Although their primary interest is the health and safety of humans, they also advise on risks to animals and the environment and are skilled in communicating these risks to stakeholders and the public. Harb emphasized the importance of keeping current records and inventories—especially for floor plans and chemicals—and reiterated the importance of contact lists that quickly become obsolete with personnel changes. She stressed that maintaining accurate plans is another critical aspect of contingency planning and underscored the value of regular training sessions, practice drills, and debriefing sessions to ensure constant preparedness.

Community Response Network

Roger Laferriere of the NIH Rocky Mountain Laboratories described how collaborative partnerships with local

authorities can bolster institutional capabilities during major incidents, drawing on his experience managing emergency responses. He described contingency planning as a cyclical process that includes risk assessment, capability estimation, identification of emergency response needs, cultivation of crucial partnerships, and conducting exercises. Creating a security and emergency management committee that regularly meets to assess risks and engage with stakeholders can be an effective way to manage contingency planning responsibilities. Laferriere noted that the Incident Command System (ICS)³ serves as a universal framework for emergency management and as such, the entire response team should be familiar with its principles.

Laferriere outlined a contingency planning best practice that includes creating streamlined plans emphasizing specific roles and responsibilities and avoiding excessive background details that can obscure critical information. He proposed strengthening relationships with external partners by actively participating in Local Emergency Planning Committee meetings, offering facility tours, and participating in community emergency drills. He stated that live interactions and practical exercises are more important than excessive digital or online communication. Laferriere concluded by suggesting that successful contingency planning lies in sustaining relationships and open lines of communication with all those involved.

National Response Network

Dr. Gustavo Soberano of USDA APHIS Animal Care explained that any research facility with regulated species must abide by the Rule and develop plans to address frequently occurring small- and large-scale emergencies like heating, ventilation, and air conditioning (HVAC) failures and power outages. He outlined four components required by the Rule including: (1) identifying likely emergencies; (2) defining critical tasks according to a title or position, not by an individual’s name; (3) establishing a clear chain of command; and (4) detailing response and recovery efforts. He suggested that the Rule be viewed as a planning tool rather than a burden and noted that facilities are not expected to create a separate plan if their existing contingency plan addresses all four components required by the Rule. Establishing a clear chain of command; providing regular training for all staff, including new employees within 30 days of being hired; and maintaining a dynamic plan that evolves with the organization are important pieces of an effective response. Although not required, Soberano also suggested adopting good management practices, including using the ICS and partnering with local emergency management teams.

Facility Engineering Staff

Tom Lentz of the Johns Hopkins Health System focused on how his institution’s physical plant personnel assist with contingency planning by prioritizing proactive measures that prevent emergencies. When an emergency does occur, resources are deployed and procedures are followed to resolve the issue. He highlighted the importance of developing internal expertise, robust preventive maintenance programs, and layered redundancies for critical systems. Lentz outlined strategies to mitigate risks associated with areas of concern like installing fan arrays in HVAC air handling units, minimizing opportunities for pest intrusions through building maintenance and sanitation, installing generators and backup sources for electrical power, and maintaining redundant water purification systems. Lentz also acknowledged the challenges of maintaining critical services during natural disasters, especially at isolated facilities in remote locations. He noted that ensuring access to adequate supplies, backup generators, and readily available transportation plans are essential. Physical plant workers are valuable partners in the contingency planning process and can help to identify external threats like regional infrastructure breakdowns that disrupt campus operations even when internal safeguards are in place. Lentz encouraged researchers to consult with physical plant staff, particularly when making renovations or installing new equipment that could influence the contingency planning process.

Roles and Responsibilities Panel Discussion

Panelists engaged in discussion about strategies for successfully implementing ICS in different institutions. Laferriere highlighted ICS’s importance in ensuring effective communication during emergencies and the value of AARs for maintaining an action list to address any gaps that arise when the contingency plan is acti-

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vated. Lentz added that the ICS structure requires everyone to have a clear grasp of their specific responsibilities, preventing overreach and minimizing disruptions. Multiple speakers shared ways to obtain ICS training, including online sources, in-person training through local agencies, and in-house training programs. Ebert noted that his organization had an established emergency management program and was minimally affected by the Rule’s implementation. However, other panelists’ experiences were more variable depending on their organization’s size and available resources. Harb suggested that smaller programs with limited expertise might need to collaborate with local consultants or partner with larger institutions and local, state, and regional emergency preparedness staff and offices that have more resources and resident expertise to adequately prepare for emergencies.

TRAINING FOR SUCCESS

Dr. Edward (Ted) Kennedy of the Administration for Strategic Preparedness and Response in the U.S. Department of Health and Human Services provided an overview of how to build an effective contingency planning training program. He suggested that contingency plans should exceed basic requirements whenever possible and noted that staff should receive training on broader emergency response concepts—like ICS and the National Incident Management System—to ensure optimal coordination with external authorities during emergencies. He also suggested that facilities should work with local colleagues to leverage and customize existing plans rather than starting from scratch. Planning efforts could involve identifying risks, establishing triggers for plan activation, and clearly defining responsibilities. He also noted the importance of keeping accurate exercise and AAR records to inform the planning process.

Kennedy emphasized a practical approach to emergency preparedness training, highlighting the importance of hands-on skill development and quick access to critical information through phone apps and ID badges. These information sources can help remind staff of their specific roles and responsibilities during an emergency and assist in identifying employees who are incapacitated during an emergency. He discussed the pros and cons of online learning, acknowledging that it has become the norm and is quite effective for information gathering but often falls short if the goal is to develop tactile skills, provide real-time feedback, or tackle high-level and sensitive issues like ethical considerations and leadership development. Kennedy encouraged facilities to expand their training opportunities by partnering with local emergency services, public health departments, and volunteer organizations like the state’s Medical Reserve Corps, reiterating that staff need to also plan for their family’s preparedness to avoid distractions while they are deployed. He emphasized that emergency preparedness is a collaborative effort, and success depends on responses being in place before an emergency occurs. Kennedy concluded by encouraging adopting creative training approaches to engage trainees and motivate them to participate, such as the CDC’s zombie apocalypse campaign (CDC, n.d.).

RESOURCES AND PLANNING FOR THE FUTURE

Dr. Jason Villano, of the Johns Hopkins University School of Medicine and a planning committee member, moderated a final session that explored various topics presented during the workshop. Key concerns raised by the panelists centered on challenges with training, internal and external response coordination, time management, and identification of relevant stakeholders. Kennedy reiterated that training should be directly related to the contingency plan and its specific tasks. DiVincenti commented on the requirement for new employees to be trained within 30 days of their hiring, explaining that the duration seems reasonable to ensure that employees have the basic information they need to start their duties. DiVincenti also clarified that the type and level of training could be tailored to the position, with more in-depth instruction for those in leadership roles. Colby added that facility-specific plans should be considered within the context of the overarching institutional plan and any applicable regional or state plans.

Panelists confirmed that the level of difficulty in implementing the Rule’s requirements varies between organizations. Russell-Lodrigue mentioned that many institutions already have contingency plans in place and Rule requirements would benefit by building on these existing frameworks. She also noted that her institution had funding to implement the institution-level contingency plan and support for crisis management and communi-

cations staff. Those institution-specific options may be available at other institutions. Russell-Lodrigue also recommended seeking external funding sources, like grants, if additional resources are needed to support contingency plan development. Several participants welcomed opportunities to share plans and templates, but Russell-Lodrigue and Kennedy cautioned that facilities with sensitive research or security concerns might be averse to openly sharing this information. Finally, Harper alluded to the importance of relationships and partnerships in contingency planning by repeating “you can’t fight a wildfire all by yourself.”

Example actions to improve institutional compliance with the Rule, based on key points raised during the workshop, are available in the supplemental materials.⁴

REFERENCES

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COMMITTEE MEMBERS Susan B. Harper (Chair), National Institutes of Health; Lesley A. Colby (Vice-Chair), University of Washington; Kari Fiala, Charles River Laboratories; Margaret S. Landi, Independent Consultant; Jason Villano, Johns Hopkins University School of Medicine; Temeri Wilder, Office of Laboratory Animal Welfare, National Institutes of Health; Wanda Wilson Egbe, U.S. Department of Health and Human Services.

SPONSOR This workshop was supported by the U.S. Department of Agriculture Animal & Plant Health Inspection Service.

STAFF Nia Johnson, Responsible Staff Officer; Kavita Berger, Board Director; Robin Schoen, Board Director; Mitchell Hebner, Research Associate; Jessica De Mouy, Research Associate; Mariah Waul, Senior Program Assistant.

DISCLAIMER This Proceedings of a Workshop—in Brief was prepared by Megan Snair and Nia Johnson as a factual summary of what occurred at the workshop. The statements made are those of the rapporteurs or individual workshop participants and do not necessarily represent the views of all workshop participants; the planning committee; or the National Academies of Sciences, Engineering, and Medicine.

REVIEWERS To ensure that it meets institutional standards for quality and objectivity, this Proceedings of a Workshop—in Brief was reviewed by CDR Temeri Wilder, Dr. Joseph Thulin, and Dr. Edward (Ted) Kennedy.

SUGGESTED CITATION National Academies of Sciences, Engineering, and Medicine. 2024. Contingency Planning and Training of Personnel Rule: One Year of Implementation: Proceedings of a Workshop—in Brief. Washington, DC: The National Academies Press. https://doi.org/10.17226/27738.

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