10-11-07-FEMA-NRF-comment-ltr
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10-11-07-FEMA-NRF-comment-ltr

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AAP Headquarters October 11, 2007 141 Northwest Point Blvd Elk Grove Village, IL 60007-1098 Phone: 847/434-4000 The Honorable R. David Paulison Fax: 847/434-8000 E-mail: kidsdocs@aap.org Administrator www.aap.org Federal Emergency Management Agency Reply to 500 C Street, S.W. Department of Federal Affairs Washington, D.C. 20472 Homer Building, Suite 400 N 601 13th St NW Washington, DC 20005 Dear Mr. Paulison: Phone: 202/347-8600 Fax: 202/393-6137 E-mail: kids1st@aap.org The American Academy of Pediatrics, a non-profit professional organization of 60,000 primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical Executive Committee specialists dedicated to the health, safety, and well-being of infants, children, adolescents, President Jay E. Berkelhamer, MD, FAAP and young adults, appreciates this opportunity to comment on the National Response President-Elect Framework (NRF), as published by the Federal Emergency Management Agency (FEMA) Renée R. Jenkins, MD, FAAP in the Federal Register on September 11, 2007. Executive Director/CEO Errol R. Alden, MD, FAAP The Academy recognizes that the NRF has been rewritten to provide a broad conceptual Board of Directors framework within which the response to emergencies will be conducted. We are deeply District I concerned, however, that the NRF appears to minimize the federal role in disaster response Edward N. Bailey, MD, FAAP Salem, MA and fails to take into ...

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AAP Headquarters
141 Northwest Point Blvd
Elk Grove Village, IL 60007-1098
Phone: 847/434-4000
Fax: 847/434-8000
E-mail: kidsdocs@aap.org
www.aap.org
Reply to
Department of Federal Affairs
Homer Building, Suite 400 N
601 13th St NW
Washington, DC 20005
Phone: 202/347-8600
Fax: 202/393-6137
E-mail: kids1st@aap.org
Executive Committee
President
Jay E. Berkelhamer, MD, FAAP
President-Elect
Renée R. Jenkins, MD, FAAP
Executive Director/CEO
Errol R. Alden, MD, FAAP
Board of Directors
District I
Edward N. Bailey, MD, FAAP
Salem, MA
District II
Henry A. Schaeffer, MD, FAAP
Brooklyn, NY
District III
Sandra Gibson Hassink, MD, FAAP
Wilmington, DE
District IV
David T. Tayloe, Jr, MD, FAAP
Goldsboro, NC
District V
Ellen Buerk, MD, MEd, FAAP
Oxford, OH
District VI
Michael V. Severson, MD, FAAP
Brainerd, MN
District VII
Gary Q. Peck, MD, FAAP
New Orleans, LA
District VIII
Mary P. Brown, MD, FAAP
Bend, OR
District IX
Myles B. Abbott, MD, FAAP
Berkeley, CA
District X
John S. Curran, MD, FAAP
Tampa, FL
Immediate Past President
Eileen M. Ouellette, MD, JD, FAAP
October 11, 2007
The Honorable R. David Paulison
Administrator
Federal Emergency Management Agency
500 C Street, S.W.
Washington, D.C. 20472
Dear Mr. Paulison:
The American Academy of Pediatrics, a non-profit professional organization of 60,000
primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical
specialists dedicated to the health, safety, and well-being of infants, children, adolescents,
and young adults, appreciates this opportunity to comment on the National Response
Framework (NRF), as published by the Federal Emergency Management Agency (FEMA)
in the
Federal Register
on September 11, 2007.
The Academy recognizes that the NRF has been rewritten to provide a broad conceptual
framework within which the response to emergencies will be conducted.
We are deeply
concerned, however, that the NRF appears to minimize the federal role in disaster response
and fails to take into account the responsibility at all levels of government to protect the
most vulnerable citizens, mostly notably our children.
The Federal Government Must Be an Active Partner in Disaster Response
The NRF states repeatedly that States are the primary responders to any disaster, and that
the federal government will intervene only in the most dire circumstances.
The NRF
appears to position the federal government as a disinterested bystander that will only be
activated in rare situations.
i
Children are among those most likely to suffer if the federal government stands by idly
while a State struggles through disaster response.
During Hurricane Katrina, the delays in
activating federal resources were a crucial factor in the suffering that followed.
Families
were not evacuated appropriately, children were separated from their parents or caregivers
unnecessarily, often for extended periods of time, and our youngest citizens faced danger,
hunger, and privation unnecessarily.
Many children are still struggling with post-traumatic
stress and other mental health conditions directly related to these separations and lack of
appropriate treatment. The NRF should ensure that the federal government is poised for
response and engages in a proactive dialogue with States, especially to ensure that child
health needs are identified and addressed at every stage of a disaster.
The Federal Government Must Be Prepared to Take the Lead in Multi-State Disasters
Disasters do not recognize state lines.
The NRF provides only limited information as to
how the federal government will act in the event of another catastrophic event that impacts
more than one state simultaneously.
The NRF gives little guidance as to how critical needs
will be prioritized and competition for resources resolved.
The Academy is particularly concerned as to how this ambiguity will impact the ability to serve
children and their families.
Hurricane Katrina illustrated with painful clarity the fact that the
resources available to different states had a major impact on the care they were able to deliver to
victims.
The Academy recommends adding more detail either to the NRF or its annexes to
describe to States and others how these situations will be handled.
The Federal Government Should Provide National Standards in Disaster Response
The federal government has a deep and abiding interest in the rapid, appropriate response to any
disaster.
While States are certainly sensitive to the particular needs of their population, the NRF
seems to ignore the broad commonalities among many disaster events.
The federal government
has a key role to play in providing standardized guidance and resources to States in responding to
disasters.
It is both inefficient and ineffective to expect each State to re-invent a disaster
response plan.
The federal government should play an active part in providing States with
models, standards, and tools, as well as the resources to implement them effectively.
In particular, the federal government should develop and disseminate such models and standards
for ensuring the health, safety and wellbeing of children during disasters.
Disaster planning
across all levels of government currently suffers from a profound lack of attention to children’s
issues.
ii,iii
Children have unique needs in the areas of health care, mental health, medication,
supervision, shelter, equipment, supplies, and more.
The Academy recommends the
development of specific materials to assist all relevant entities in planning to meet children’s
needs.
Children Are Not Just a “Special Needs” Population
The Academy appreciates the tremendous challenge in developing a definition for “special
needs” populations.
It is the Academy’s position, however, that it is inappropriate for our
nation’s 73 million children to be classified as “special needs” along with other disparate groups
such as the elderly, the transportation-disadvantaged, and low English proficiency individuals.
Children are a diverse population – they are of various ages, sizes, and developmental levels;
some have chronic or other special health care needs; many belong to cultural or ethnic
minorities; and above all, they are wholly dependent upon the caregiving of the adults around
them.
If they are not considered specifically and directly, their needs will not be anticipated or
addressed.
Specific Attention Must Be Paid to Children’s Needs
The Academy urges that pediatricians and other pediatric experts be involved in the review of
the NRF and all other disaster preparedness, response and recovery plans, documents, and
materials.
iv
As specialists in children’s health, pediatricians are equipped to identify both
children’s needs and solutions for addressing them.
If the NRF attains a level where it can
ensure that children’s needs are met during a disaster, it is highly likely that the framework will
also be appropriate to meet all Americans’ needs.
In conclusion, it remains discouraging that pets and service animals receive considerably more
direct attention in the National Response Framework than our nation’s 73 million children.
v
The
words “child,” “children,” or “pediatric” do not appear even once in the 78 pages of the NRF.
The Academy urges the agency in the strongest possible terms to revisit this document with an
eye to ensuring that our most vulnerable citizens – our children – are appropriately considered
and their needs are addressed.
We stand ready to provide any expertise or other assistance that
might be useful in this endeavor.
Once again, the American Academy of Pediatrics appreciates this opportunity to offer comments
on the National Response Framework.
We look forward to working together toward our mutual
goal of protecting our nation’s children during disasters.
Sincerely,
/s/
Jay E. Berkelhamer, MD, FAAP
President
JB:cp
i
E.g.: “Depending on the size, scope and magnitude of an incident, communities, States and, in some cases the
Federal Government will be called to action.” (p. 31); “
States provide the vast majority of the external assistance
to communities.
” (p. 37); “When an incident overwhelms State and mutual aid resources, the Governor may request
Federal assistance.” (p. 38); “When it is clear that State or tribal capabilities will be exceeded or exhausted, the
Governor can request Federal assistance,” (p. 38); “Before making a declaration request, the Governor must activate
the State’s emergency plan and ensure that all appropriate State and local actions have been taken, including…” (p.
39).
ii
Institute of Medicine.
Emergency Care for Children: Growing Pains. July 14, 2006.
See
Chapter 6, “Improving
Emergency Preparedness and Response for Children Involved in Disasters.”
iii
Shirm S, Liggin R, Dick R, Graham J.
Prehospital Preparedness for Pediatric Mass-Casualty Events.
Pediatrics
,
2006 xxx pp. e756-e761.
iv
Markenson D, Reynolds S, Committee on Pediatric Emergency Medicine and Task Force on Terrorism.
The
Pediatrician and Disaster Preparedness.
Pediatrics
, 2006 117: e340-e362.
v
E.g.: “[Families should] develop family emergency plans that include care for pets and companion animals”; (p. 4);
“[planning should] ensure that local emergency preparedness plans take into account the needs of individuals with
special needs or those with companion or service animals prior to, during and after an incident.” (p. 14); Response
activities include “Implementing evacuation plans that include provisions for special needs populations and service
animals” (p. 36); Department of Agriculture has lead responsibility for “Safety and wellbeing of pets” (p. 57).