This is in response to the subject Draft Office of Inspector General (OIG) Report, issued August l5, 2006. In its report, the OIG made two recommendations.

We appreciate that the OIG noted that the FDIC's Emergency Response Plan (ERP) provides a framework from which comprehensive ERP's have been established for Washington as well as in the regions. However, to ensure that our plans provide for the safety and protection of the Corporation's employees, we recognize that they should be updated with current information. This response outlines our planned corrective actions for each of the recommendations cited in the OIG's Report.

MANAGEMENT DECISION

Finding: Increase Active Senior Management Involvement and Support

Condition: Although the ERPs reviewed address most of the recommended emergency response elements contained in federal agency criteria for emergency response planning, the FDIC could do more regarding the importance of the ERP through increased communication to employees and additional guidance.

Recommendation 1: That the Director, Division of Administration (DOA) work with senior FDIC executives to establish a strategy for ensuring their public support for and involvement in ERP.

Management Response 1: DOA concurs with this recommendation.

Corrective Action: As noted in the 01G's Report, FDIC senior management has taken steps to increase awareness and preparedness among FDIC staff by establishing comprehensive policy and plans, Strategic Planning initiatives, table top exercises and Quarterly Status Reports for the Emergency Preparedness Program. Further, FDIC senior managers have consistently participated in the ERP Situation Room exercises as well as in discussions during Operating Committee meetings. Going forward, we will continue to stress to all senior managers the importance of this program and ask them to include emergency preparedness in their discussions at various division and office staff meetings as a way to increase awareness. The DOA, Corporate Services Branch, Security Management Section (SMS) will complete this task by October 30, 2006.

Recommendation 2: That the Director, DOA revise the ERP policy and individual ERP's, where appropriate, to address the following issues discussed in this report:

• Documenting management review and approval;
• Updating ERPs on a regular basis;
• Ensuring floor marshal/Warden assignments are kept current and Floor Marshals/Wardens attend periodic training;
• Communicating ERP information to employees;
• Implementing an annual, mandatory ERP computer based training course;
• Conducting evacuation drills to include a process for evaluating the drill and obtaining employee feedback.
• Developing instructions for conducting shelter-in-place drills and for the location, distribution, and maintenance of food, water, and other emergency supplies.
• Establishing procedures for handling serious injury or illness and informing employees of procedures for obtaining medical supplies and first aid.
• Ensuring FDIC's ERPs address coordination between the child-care facility and the FDIC before, during, and after an emergency.
• Developing additional instructions for assisting persons with varying disabilities as is included in the HQ ERP.

Management Response 2: DOA concurs with this recommendation.

Corrective Action:
Documenting management review and approval: The SMS recently updated the Headquarters (HQs) Emergency Response Plan (ERP). The updated ERP will be routed through FDIC senior management for review and approval. To provide a more complete record of the review and approval by FDIC senior managers, the SMS will attach and maintain the FDIC Routing and Clearance Sheet, FDIC Form 1211/40. The FDIC Routing and Clearance Sheet will remain a part of the official record for authorizing the updated ERP. The updated ERP should be complete by October 15, 2006.

Updating ERPs on a regular basis: The SMS decided to defer updating the HQs ERP until after the Corporation's realignment of staff and the construction of the Virginia Square Phase II facility. The SMS has updated the ERP. The ERP is currently being prepared for final FDIC senior management review and approval. The DOA SMS will continue to review the ERP on an annual basis and make any changes as needed. The ERP should be complete by October 15, 2006.

Ensuring floor marshal/Warden assignments are kept current and Floor Marshals/Wardens attend periodic training: Given the many changes to FDIC staffing levels over the course of the past year, as well as the relocation of employees to the new Virginia Square Phase II facility, maintaining a more current and accurate list of Floor Marshals has been difficult. Now that this activity is complete, the SMS updated the list of Floor Marshals. Going forward, the SMS will continue to ensure that there are adequate numbers of Floor Marshals to assist employees in emergency situations. To this end, the SMS recently solicited volunteers to serve as Floor Marshals during employee emergency preparedness training as well as sent an email to all employees for volunteers. In addition, the SMS has worked with each division and office to fill specific needs by floor. These efforts have yielded a 25% increase in overall participation in the Floor Marshal program. Attached is an updated list of all current Floor Marshals.

To ensure Floor Marshals attend periodic training, the SMS will conduct its Floor Marshal training on a semi-annual basis. Currently, the SMS is working with the Arlington County Fire Department to provide the most current life safety information to all Floor Marshals. The SMS will offer this training by December 31, 2006.

The OIG noted in its Report that the New York Regional Office (NYRO) ERP did not include procedures for maintaining its Floor Warden Program. The NYRO agrees with the OIG's statement and will work to enhance their Plan by specifying procedures for maintaining its Floor Warden Program. In addition, the NYRO will increase the frequency of conducting emergency response briefings/meetings with Floor Wardens, Deputy Wardens, Searchers, and Buddies to at least three times annually. The NYRO will incorporate these changes into their ERP by September 30, 2006.

Communicating ERP information to employees: Although the SMS currently disseminates emergency preparedness information to FDIC employees through the Security website, security alerts, security task force meetings and training sessions, the SMS will ensure that the approved HQ's ERP is added in its entirety to the Security website. Additionally, the SMS will work with DIT to ensure that the Regional Office security hotlinks are properly linked to the respective Regional Office Security website and not to the HQ's wcbsite. SMS will complete this work by December 31, 2006.

Implementing an annual, mandatory ERP computer based training course: As was discussed by SMS staff with the OIG review team, the SMS began an initiative one year ago with the Corporate University to develop an annual ERP computer-based training course. Subsequently, a pilot on-line course has been developed. The pilot will be rolled out to a focus group for feedback with full implementation by March 1, 2007.

Conducting evacuation drills to include a process for evaluating the drill and obtaining employee feedback: The SMS staff conducted and evaluated both evacuation and shelter-in-place drills in HQs. Since 2004, the SMS staff conducted 20 evacuation and 10 shelter-in-place drills, evaluated each, and sought employee feedback. SMS staff will continue this practice and will ensure that at least two evacuation and one shelter-in-place drills occur annually at each FDIC location. SMS will document their procedures for evaluating each drill and for obtaining employee feedback by October 15, 2006.

The OIG noted in its Report that the NYRO conducts three evacuation drills each year, although its ERP does not include a provision requiring a certain number of drills. To address the missing provision, the NYRO will add language to its ERP to indicate that three emergency response drills will be conducted annually. The NYRO will revise its ERP by September 30, 2006.

While the Dallas Regional Office (DRO) is in compliance with the Dallas Fire Code for evacuation drills, the DRO conducted additional training on September 7, 2006 to include procedures for evacuating a high rise building, and the proper procedures for operating a fire extinguisher. This training highlighted the responsibilities for the Floor Wardens and included a presentation by the building engineer describing life safety systems specific to the DRO building. Employees will be provided copies of the Emergency Evacuation Plan and offered the opportunity to provide comment. Additional training forums will be offered later in the year.

Developing instructions for conducting a shelter-in-place (drills) and for the location, distribution, and maintenance of food, water, and other emergency supplies: The SMS will ensure that all ERPs have sufficient instructions/information for conducting shelter-in-place drills to include the location, distribution, and maintenance of emergency supplies by October 15, 2006.

The OIG noted that the NYRO ERP did not provide specific shelter-in-place procedures identifying refuge rooms or procedures for maintaining food and water supplies. The NYRO will enhance the shelter-in-place instructions, including the identification of specific rooms for shelter as well as specify the shelter-in-place supply storage location and maintenance. The NYRO will revise its ERP by September 30, 2006.

The NYRO and the DRO will add language to their respective ERPs informing employees on how they can obtain medical supplies and first aid. A list of CPR trained employees is included in the DRO Emergency Operations Center handbook provided to all emergency responders. These ERPs will be updated by September 30, 2006 and October 15, 2006 respectively.

Ensuring FDIC's ERPs address coordination between the child-care facility and the FDIC before, during, and after an emergency: Although the Child Development Center (CDC) is managed by a separate board of directors, we maintain a close working relationship with their staff and include them in all of our evacuation and shelter-in-place drills. The new CDC contractor has finalized their plan for the F Street center and it is being incorporated into the FDIC ERP. The CDC plan for the new Virginia Square (VASQ) center is being written and, once completed, will be incorporated into the ERP. While we will incorporate those plans into the ERP, for the safety and protection of the children, the VASQ CDC plan will only be available to parents of enrolled children as well as to FDIC executives and emergency response personnel, The F Street center plan will be incorporated into the updated HQ ERP by October 31, 2006.

Developing additional instructions for assisting persons with varying disabilities as is included in the HQ ERP: The SMS staff has always worked closely with FDIC personnel with disabilities. Recently, the SMS sent an email to all personnel asking them to contact the Security staff should they need assistance during an emergency and met separately with these employees to ensure that their needs were met. While the HQs ERP provides specific instructions for those individuals with permanent or temporary disabilities to include guidance and specific procedures for assisting persons with varying disabilities, the HQ emergency website will be updated to include additional instructions. As stated in our response to "Communicating ERP information to employees", the SMS will ensure that the updated ERP is added to the Security website so that the website includes this guidance by October 31, 2006.

In addition, the NYRO will revise its ERP to address more thoroughly the instructions and procedures for assisting persons with disabilities by September 30, 2006.

Also, the DRO will add language to the ERP offering guidance to employees with varying disabilities, allowing them the opportunity to properly plan for evacuation and sheltering-in-place during an emergency situation by October 15, 2006.

If you have any questions regarding this response, FDIC's point of contact for this matter is William Gately. Mr. Gately can be reached at (703) 562-2118.