Emergency situations involving churches are making headlines more often than many churchgoers would like to believe. As recently as November 16, 2013, tornados touched down in Illinois on a Sunday evening when many were attending church. Churches were targeted in at least 108 incidents of violence in 2011 and over 135 incidents in 2012. In addition, many churches were affected by technological disasters, such as leaks from industrial plants, roadway spills, and power failure.
In June 2013, the Federal Emergency Management Agency (“FEMA”) released a “Guide for Developing High-Quality Emergency Operations Plans for Houses of Worship” (available here). FEMA suggests that churches create and implement a six step “Emergency Operations Plan” to prepare for natural disasters, technological disasters, and active shooter situations. Churches and other houses of worship may use the Guide to take action before, during, and after an incident in order to prevent or mitigate the loss of property and human life.
The Guide focuses specifically on active shooter situations. Church leaders may be discouraged by the time-intensive six step procedure outlined in the Guide, because creating such a plan will likely cost precious time and resources that many churches cannot afford. Even if churches choose not to develop an Emergency Operations Plan, they should contemplate the following considerations in the event that a shooter situation does occur: (1) how to lock down or evacuate personnel and visitors; (2) how to evacuate when primary evacuation routes are unusable; (3) how to select effective shelter-in-place locations; (4) how those in the building and on the ground will be notified that an active shooter incident is underway; and (5) how everyone will know when buildings and the grounds are safe. This information should be shared with first responders, including local law enforcement, firefighters, and emergency medical service personnel.
As far as preventative measures, the Guide identifies common “warning signs” or “behavioral indicators” derived from studies of shootings at workplaces, schools, and places of worship. These behaviors often include: development of a personal grievance; contextually inappropriate and recent acquisitions of multiple weapons; contextually inappropriate and recent escalation in target practice and weapons training; contextually inappropriate and recent interest in explosives; contextually inappropriate and intense interest or fascination with previous shootings or attacks; and a significant real or perceived loss in the weeks or months leading up to the attack. Interestingly, few offenders had previous arrests for violent crimes. Note that these behaviors are of limited use in isolation and should be used to prompt further investigation by church leaders or law enforcement into the individual exhibiting these behaviors.
The Guide also suggests that places of worship consider organizing “Threat Assessment Teams (“TATs”),” which are common in college and university settings. These teams are designed to partner with law enforcement and review troubling or threatening behavior brought to their attention. However, churches should be aware of the legal ramifications of such a team, as noted by the Guide: “TATs should keep in mind . . . the importance of relying on facts (including observed behavior) and avoid unfair labeling or stereotyping of individuals to remain in compliance with civil rights laws, when applicable.”
In conclusion, FEMA’s Guide should spark a conversation among church leaders about whether their churches are prepared to cope with the types of disasters described in this article in the unlikely event that they should occur.
This article is provided for general information and should not be relied upon as legal advice for a specific situation. If you are in need of specific advice or legal representation, please do not hesitate to contact us.
©2014 Bea & VandenBerk
 See Jamie Aten, What’s Your Church’s Plan for an Active Shooter?, Christianity Today (Aug. 21, 2013), http://blog.managingyourchurch.com/2013/08/whats_your_plan.html; Melissa, Steffan, Church Shootings Prompt Pastors to Reevaluate Security, Christianity Today (Nov. 20, 2012), http://www.christianitytoday.com/gleanings/2012/november/church-shootings-prompt-pastors-to-reevaluate-security.html.
 Churches that operate schools as part of their ministry should also consult Guide for Developing High-quality School Emergency Operations Plans for planning considerations created with schools in mind. See http://www.dhs.gov/sites/default/files/publications/REMS%20K-12%20Guide%20508_0.pdf.