May 10, 2004

MEMORANDUM

To: Commissioners

From: Team 8

Subj: Recommendation on National Preparedness Standards

Issue. Staff Statement No. 15 at the upcoming hearing includes preliminary findings that
may lead the Commission to support the adoption of the National Fire Protection
Association Standard (NFPA) 1600 as a voluntary national standard for developing a
private sector preparedness and continuity of business plan. This course of action has
been recommended to the Commission by the American National Standards Institute
(ANSI). Following the Commission's November hearing on emergency preparedness,
ANSI developed a recommendation for the Commission's consideration at the Chair and
Vice Chair's request.

At next week's hearing, Secretary Ridge will testify on the topic of preparedness, and we
have asked him to comment specifically on this recommendation. DHS staff has been
apprised of this issue throughout the process and attended the meetings during which the
recommendation was developed. DHS has not yet taken a position.

The issue is whether or not the Commission wishes to formally adopt this
recommendation prior to the hearing and announce it at the hearing's conclusion.

Pros:
• It would lift the end of a difficult hearing with a positive, proactive statement to
concretely help preparedness in the future.
• The recommendation is for the adoption of a voluntary high-level standard, one that is
currently being used by the public sector through DHS to rate state and local
government preparedness. It is already in use and thus not controversial, and is high-
level enough not to cause private sector companies who have plans in place to do
additional work, and was supported by a wide-range of private sector companies.
• The issuance of this recommendation relates well to the hearing content and would
flow naturally from the proceedings.
• Holding off on the recommendation until the end of July may lose the impetus and
get lost in the other recommendations that are more wide-ranging and policy driven
whereas this one is directly related to safety.

Cons:
• Commissioners may decide to wait on all recommendations until the final report.
• There may not be enough time to thoroughly vet these recommendations by
Commissioners and get follow-on support from all interested parties.
• DHS support is not yet guaranteed even though they have been briefed and brought
along in this process
• The story of the day could be the fire/police issues and this recommendation could get
lost in the press coverage of more "controversial" issues that fall out from the
hearing.
History of the Commission's Work with ANSI on National Preparedness Standards

As part of the Commission's investigation, Commission staff interviewed many

companies located in the World Trade Center and learned about the evacuation,
communication, and continuity of business issues they faced that day. These issues were
further examined at the Commission's Fifth Public Hearing at Drew University.
Following this hearing, the Chair and Vice Chair asked the American National Standards
Institute (ANSI) to convene their Homeland Security Standards Panel (HSSP) to develop
recommendations for the Commission's consideration.

The HSSP Panel met from January to April of this year to discuss and develop a
recommendation to the Commission. Commission staff attended these meetings, along
with DHS and GAO representatives, and staff coordinated with these agencies to ensure
that they were involved in the process and ready to assist in the implementation of these
voluntary standards should they be recommended by the Commission.

More than 100 professionals from the standards and conformity assessment community
gathered for the second plenary meeting of the American National Standards Institute
Homeland Security Standards Panel (ANSI-HSSP) on April 29-30, 2004. On April 29,
the Vice Chair attended the reception hosted by ANSI to receive a recommendation on
private sector emergency preparedness and business continuity. Presented by ANSI
president and CEO Dr. Mark W. Hurwitz, the Institute recommended a voluntary national
preparedness standard based on criteria developed by the National Fire Protection
Association (NFPA).

Recommendation. "In response to the January 23, 2004 letter from the 9-11 Commission
Chairman Kean and Vice Chairman Hamilton, the American National Standards Institute
(ANSI) convened safety, security and business continuity experts from a wide range of
industries and associations, as well as from federal, state and local government
stakeholders, to consider the need for standards for private sector emergency
preparedness and business continuity. These parties, brought together under the auspices
of ANSI's Homeland Security Standards Panel (ANSI-HSSP), have concluded that a
high-level, voluntary standard applicable to all businesses regardless of industry, size, or
location, is needed to establish a common framework for emergency preparedness. On
behalf of these experts and stakeholders:

ANSI proposes that the National Commission on Terrorist Attacks Upon the
United States include in its recommendations to Congress and the President of the
United States, the position that the high-level, voluntary American National
Standard on Disaster/Emergency Management and Business Continuity Programs
(NFPA 1600) be accepted as the common framework for private-sector national
preparedness (hereinafter known as the National Preparedness Standard). This
document was developed by the National Fire Protection Association (NFPA)
using due process and consensus-based procedures approved by ANSI.

The National Preparedness Standard establishes a common set of criteria and

terminology for private-sector disaster management, emergency management, and
business continuity programs for a variety of hazards. Recognizing that any truly viable
standard is open to continuous improvement, the parties also developed several
recommendations for further enhancements to the standard. These comments have
already been submitted to the NFPA disaster management technical committee.

A national implementation strategy is necessary to support the use of this standard.

ANSI recommends that the Commission request the U.S. Department of Homeland
Security (DHS), and other federal agencies as appropriate, to undertake this initiative, hi
addition, ANSI will continue to collaborate with the Working Group on Private Sector
Preparedness (PSP-WG) to develop incentives for private-sector implementation of this
voluntary standard and to market, promote and educate the public about its existence.
The Institute also stands ready to take additional steps that may be deemed appropriate in
furtherance of this initiative."

The participants in the panel workshops which developed this recommendation were the
following:

Experts from the following organizations participated in the process:

3M
Alliance for Telecommunications Industry Solutions (ATIS)
American Electric Power (AEP)
American Management Services
AS IS International
Association for Cooperative Operations Research and Development (ACORD)
Attainium Corporation
Bank of New York
Battelle
Bechtel Nevada
Booz Allen Hamilton
Canadian Standards Association (CSA)
Chiron Corporation
The Conference Board
Congressman Christopher Shays' (R-CT) Office
Deere & Company
DMJM Technology
DRI International (DRII)
EAI Corporation
Emergency Corps
Emergency Management Accreditation Program (EMAP)
Federal Emergency Management Agency (FEMA)
Goldman Sachs
Greater New York Safety Council
Homeland Security Industries Association (HSIA)
IBM
Insurance Services Office (ISO)
Lucent Technologies
Marsh USA Inc.
Micro-News Network
Microsoft Corporation
Midwest Research Institute (MRI)
National Biometric Security Project (NBSP)
National Fire Protection Association (NFPA)
New York City Police Department (NYPD), Counter Terrorism Bureau
New York City Transit (NYCT)
North American Electric Reliability Council (NERC)
Raytheon Company
SBC Communications
Skyscraper Safety Campaign
Telecommunications Industry Association (TIA)
U.S. Department of Homeland Security (DHS)
U.S. General Accounting Office (GAO)
U.S. Postal Service (USPS)
Willis
Working Group on Private Sector Preparedness (PSP-WG)