What Should Be Included in an Emergency Response Plan Gap Analysis for Multifamily Properties?

Emergency response plans are an essential part of multifamily property management. When troubles present themselves (and they invariably will), the emergency response plan is the guide that can turn chaos into calm and deliberate action. The property management team that knows the plan and has practiced the plan is miles ahead of the team that isn’t sure what to do next. And in an emergency situation, every moment spent trying to decide how to proceed slows the response and potentially multiplies the loss.

FIRM Incident Response clients don’t just have a plan; they use the plan. They don’t refer to a dusty document, though, or use a cookie-cutter set of instructions. FIRM begins with an emergency response plan gap analysis to uncover any missing pieces and to confirm that the plan is actionable and solid.

Whether you are a multifamily property owner, property manager, or risk management professional, the following list of the types of considerations FIRM environmental health experts consider when examining emergency response plans will help you feel more confident about the strategy you currently have in place.

Emergency Response Gap Analysis: General Considerations

A gap analysis helps you identify the areas of risk within your company that need to be addressed or adjusted in order to lower that risk. Conducting an emergency response gap analysis is the quickest path to shoring up your emergency response capabilities. And the surest path to clarity is to contract with a nationally-based company that employs industrial hygiene specialists (like FIRM) to help you manage and reduce risk.

Consistency with a defined process is the key to emergency response management across multiple properties. The closer you can align your portfolio to a common set of procedures, the more likely you are to avoid confusion and keep everyone on track.

Special Considerations for Emergency Response Gap Analyses

While the emergency response gap analysis will necessarily be wide in scope (but specific in actions) there are certain topics that are either of primary interest, are often missed, or both.

Here are some of those topics:

Check your emergency restoration response policy:  Are your expectations of vendor capability realistic and based on industry standards? Are your chosen vendors capable of responding to emergencies 24/7? Emergencies don’t often occur at optimum times. They can threaten your property at any time, day or night. Without a solid relationship with licensed vendors who know and follow all applicable laws and regulations, you may see your short-term emergency turn into a longer-term disaster.

Codify your plan for relocation during an emergency incident and check your subrogation (chargeback) policies: It is important to create and communicate a defined process for any type of tenant interaction, but especially so when it comes to tenant relocation. A predefined policy demonstrates consistency and shows tenants you are following the plan, not punishing or protecting one tenant over another. Consistency is also essential in your chargeback policy. All tenants should receive the same considerations and obligations.

List and file your hazardous building materials surveys and clearances: Your gap analysis should review your current policy covering hazardous building materials. You should confirm that your policy is meeting the requirements of local, state, and federal regulations. If you discover that you have no records of asbestos surveys, for instance, it may be time to get one completed before the next emergency. Hazardous building materials are highly regulated, and the laws can differ from one state to another. An up-to-date survey can save you time and money in the long run — especially during an emergency response.

Decide what to do about mold: Mold is a tough subject. Some states regulate mold extensively, while others are not so stringent. Make sure the company you hire to perform your emergency response gap analysis is intricately familiar with the laws affecting your property.

It is important that owners with a national portfolio make sure they are following each of the various state regulations. Some states require initial assessments to be performed by a licensed industrial health provider before any restoration work can begin.

Your emergency response plan should spell out when you will perform initial assessments, even if the state doesn’t require that level of response. Below is an example of the mold assessment timing criteria chosen by a current FIRM client. If one of these is evident, an assessment is performed:

• More than three units are impacted by the issue
• More than 100 square feet of suspected visible mold is present
• The resident has mentioned legal action
• The resident is complaining of health issues

Mold clearance assessments: Clearing the area for re-occupancy after the situation is resolved is required in some states. For states that don’t have this requirement, you should set a policy that tells you when to perform a clearance. Again, this is a case where consistency proves you are treating every tenant the same. It can relieve you of the appearance of prejudice. You are following your emergency response policy, not selectively clearing one unit, but not another.Here is the policy one FIRM client adopted:

• If there is 30 square feet or greater of continuous suspected mold growth, then the company will dispatch for a clearance assessment which will include moisture mapping, visual inspection, and air sampling.

Drug assessments and clearances: Methamphetamine and fentanyl use is a growing concern throughout the United States. The number of contaminated areas FIRM teams inspect is increasing steadily. Methamphetamine and fentanyl are particularly dangerous because they will remain on walls and surfaces for years. During the manufacturing of these drugs, the residue will seep into the drywall. Anyone exposed can become sick from contact or simply from being in the room.

During the emergency response gap analysis, you should consider how many drug cases have been discovered on the property, then use that information to develop a reasonable policy for drug presence testing and clean-up protocols.

Importance of the Emergency Response Plan Gap Analysis

You can manage your multifamily property and portfolio, but you can’t control it. Unplanned and unforeseen incidents are bound to happen. From water pipes bursting at three in the morning to floods, wildfires, and windstorms — your property is one event away from the next emergency.

Smart owners and property managers don’t wait for a catastrophe to occur; they plan for it, they familiarize staff and tenants with the plan, and they practice the plan in advance. Imagine the relief you’ll feel when your emergency response plan is analyzed for gaps, is tested, and is proven effective. Then imagine what it would be like if your onsite staff only needed to pick up the phone at any hour and on any day, call one number to alert the FIRM manager of the situation, then get back to the normal schedule knowing FIRM is there to advise your maintenance team and dispatch pre-vetted vendors immediately.

If you aren’t sure whether your plan is ready to implement and strong enough to work when needed, call FIRM. We can help: (888) 910-0994.