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Report Number: 2016-136

Abbreviations

School Violence Prevention
School Districts, County Offices of Education, and the State Must Do More to Ensure That School Safety Plans Help Protect Students and Staff During Emergencies

Introduction

Background

The California Constitution guarantees California children the right to attend public schools that are safe, secure, and peaceful. The educational institutions of California, such as the California Department of Education (CDE), public school districts (districts), county offices of education (county offices), and the schools themselves are responsible for creating safe and secure learning environments. To keep children safe, schools must be prepared to respond to a range of challenges, including natural disasters, such as earthquakes. Further, some schools have procedures for dealing with man-made hazards, such as bomb threats and chemical spills and behavior issues, such as bullying. Recent events have highlighted the challenges schools face preparing for and responding to incidents of school violence, including active shootings.

School-Based Violence and Active Shooter Incidents Are on the Rise

The results of a statewide survey of districts and county offices conducted as part of this audit suggest that the frequency of active shooter threats and incidents in and around California schools is increasing.1 We surveyed 983 districts and county offices regarding active shooter threats and incidents at their schools and received 348 completed responses—a response rate of 35 percent. The survey responses indicate that the number of active shooter threats and incidents has increased since academic year 2012–13, as shown in Table 1.

Table 1
California Districts and County Offices Reported Increased Active Shooter Threats and Incidents Over the Last Five Academic Years
REPORTED BY FISCAL YEAR
Districts 2012–13 2013–14 2014–15 2015–16 2016–17
THREATS 9 9 15 29 27
INCIDENTS 2 1 0 3 3
County Offices
THREATS 11 11 16 17 11
INCIDENTS 1 0 0 3 1
Totals 23 21 31 52 42

Sources: A survey by the California State Auditor sent to 983 districts and county offices conducted from March to April 2017, with 348 entities responding, and unaudited data from Los Angeles Unified School District's iSTAR database.

Note 1: We conducted the survey before the end of the school year. Thus, data are as of April 2017 and do not reflect the full school year.

Note 2: For the purposes of this survey, we defined an active shooter incident as an event in which one or more individuals were actively engaged in harming or attempting to harm people on or near school grounds. We defined an active shooter threat as a real or perceived threat that an active shooter incident will occur.

Further, two studies undertaken by the Federal Bureau of Investigation (FBI) showed that active shooter incidents are becoming more frequent in the United States. As shown in Figure 1, the frequency of active shootings increased from 2000 through 2015. In addition, the FBI's examination of 200 active shootings in the United States from 2000 to 2015 found that kindergarten through grade 12 (K–12) facilities and institutions of higher education were the second most common location of active shootings, both in the United States and in California, as shown in Figure 2. Of the 200 active shootings in the United States during that time period, 45 took place in K–12 facilities and institutions of higher education. In California, there were 22 active shootings from 2000 through 2015, six of which occurred at K–12 facilities or institutions of higher education. Of the 45 active shootings in K–12 facilities or institutions of higher education in the United States that the FBI documented, 18 (40 percent) took place during the first half of the study's time period (2000–2007), while 27 (60 percent) took place during the second half (2008–2015). Of the six such shootings in California, two (33 percent) took place during the first half of the study's time period and four (67 percent) took place during the second half. These results are consistent with the trends seen in our survey data and, taken together, suggest that active shootings in schools nationwide and in California are on the rise.

Figure 1
Frequency of Active Shooter Incidents in the United States Has Increased Over Time

Figure 1, is a bar graph based on FBI data showing that active shooter incidents in the United States have increased over time.

Source: California State Auditor's analysis of data from the FBI's Study of Active Shooter Incidents in the United States, 2000–2015.

School Safety Plans Are a Key Component of School Safety

Comprehensive school safety plans (safety plans) are a key component of school safety and are required by state law. Safety plans are a collection of procedures for schools to use in the event of an emergency, as well as policies to promote a safe learning environment, including procedures for notifying teachers of potentially dangerous students. In 1985 the Legislature enacted the Interagency School Safety Demonstration Act of 1985 (school safety act) to address school safety concerns. State law specifies that each district and county office is responsible for the overall development of all safety plans for its schools that operate kindergarten or any grades 1 through 12, inclusive.2 The Legislature enacted the school safety act to support the development, through a systematic planning process, of safety plans that include strategies aimed at the prevention of crime and violence on school campuses. The school safety act lists specific requirements that the safety plans must contain as well as optional components schools may include at their discretion.

For example, required items include policies and procedures for the following:

Figure 2
K–12 Schools and Institutes of Higher Education Are the Second Most Common Location for Active Shooting Incidents

Figure 2 is a doughnut graph detailing the number of national and California specific active shootings from 2000–2015 and location that they took place in.

Source: California State Auditor's analysis of data from the FBI's Study of Active Shooter Incidents in the United States, 2000–2015.

State law does not require charter schools to have safety plans, but charter school petitions must include procedures the charter school will follow to ensure the health and safety of pupils and staff. CDE guidance states that safety is central to the daily operation of a school, and that school safety starts with the development of a comprehensive school safety plan. Schools with comprehensive safety plans that include all the required elements may provide a safer environment for students and staff and make them better prepared to respond effectively in the event of an emergency.

Districts and county offices are legally responsible for ensuring that the schools they supervise develop adequate safety plans in a specific manner. As shown in Figure 3, at each school the school site council (council)—comprising at a minimum the school's principal or the principal's designee, a teacher, a parent of a child who attends the school, and a school employee who is not a teacher—develops the school's safety plan.3 State law also requires the council to consult with a representative from a law enforcement agency when writing and developing the safety plan. After adopting a safety plan, each school must submit its plan to its respective district or county office for approval. Districts and county offices must approve their schools' safety plans by March 1 each year. Although each school develops its own safety plan, the school safety act makes clear that the districts and county offices are responsible for the overall development of safety plans for all the schools they supervise. State law requires districts and county offices to notify CDE by October 15 each year of any schools that have not developed a safety plan and requires CDE to fine districts and county offices up to $2,000 for willful failure to report those schools without a safety plan.

Figure 3
State Law Requires Public Schools to Follow a Multistep Process to Develop a Safety Plan

Figure 3 depicts the process schools are required to follow to comply with state law during the creation of their safety plans.

Source: Education Code.

* The council may also delegate the responsibility of developing a safety plan to a school safety planning committee (committee) generally composed of the same members. Districts with fewer than 2,501 average daily attendance are considered small districts and only need to develop a districtwide safety plan that is applicable to each school site.

State law does not require that safety plans include procedures for responding to active shooters in and around school sites. However, schools have discretion to include a variety of optional items related to school violence in their safety plans. For example, schools may coordinate with local law enforcement officials to develop tactical response plans to respond to criminal incidents that may result in death or serious bodily injury at the school site. Some schools' safety plans include procedures for responding to active shooters, such as locking down all classrooms to prevent unauthorized entry. The Sandy Hook Advisory Commission, a group established after the active shooting at Sandy Hook Elementary in Connecticut in 2012, recommended that schools implement specific procedures for responding to violent events. For example, it recommended the implementation of perimeter lockout procedures to lock all exterior doors and gates, as well as interior lockdown procedures during which all the interior doors throughout the school site are locked while students and teachers shelter in their classrooms as a means of preventing or delaying an intruder from entering these areas.

During the 2015–16 Regular Session, Assembly Bill 58 (AB 58) proposed changes to state law that would have required schools to incorporate procedures for responding to active shooters into their safety plans. AB 58 would also have increased oversight on districts and county offices by requiring superintendents to provide written notification to CDE certifying that each school within their jurisdiction had complied with the requirement to adopt a safety plan. Analysis of the bill indicated potentially significant reimbursable costs to districts and county offices for these activities. An analysis prepared for the Senate Appropriations Committee found that if the Commission on State Mandates determined AB 58 to be a mandate, it could create pressure to increase state funding for the K–12 Mandate Block Grant to reflect its inclusion. Although the Assembly approved AB 58, the Senate Appropriations Committee referred it to the suspense file, where no further action was taken.

Scope and Methodology

The Joint Legislative Audit Committee (Audit Committee) directed the California State Auditor to perform an audit to examine K–12 schools' readiness to prevent, identify, and respond to school-based violence, particularly active shooter threats and incidents in and around school campuses. Table 2 outlines the Audit Committee's objectives and our methods for addressing them.

Table 2
Audit Objectives and the Methods Used to Address Them
Audit Objective Method
1 Review and evaluate the laws, rules, and regulations significant to the audit objectives.
  • Reviewed the laws related to protecting students and staff from violent events at schools.
  • Reviewed and documented the laws related to safety plans.
  • Reviewed laws related to CDE monitoring and guidance requirements.
2 Determine the type and level of guidance CDE has provided to K–12 schools, charter schools, districts, and county offices related to ensuring the safety of students and staff on campus, including guidance related to active shooters or assailants.
  • Identified the guidance the Legislature requires CDE to provide related to the safety of students and staff on campus, including guidance related to active shooters, and obtained evidence of that guidance.
  • Interviewed CDE and California Department of Justice (DOJ) personnel to determine whether they complied with requirements related to the school–law enforcement partnership (partnership).
  • Determined partnership funding for fiscal years 2000–01 through 2015–16.
3 Evaluate and assess how CDE monitors districts' and county offices' compliance with state laws, regulations, and guidelines related to preventing, identifying, and responding to school-based violence or ensuring the safety of students and staff on campus. Reviewed CDE's oversight role related to school safety and determined whether it was complying with those requirements.
4 Determine the number of districts and county offices that have reported school noncompliance with state law regarding the submission of safety plans to CDE. In addition, evaluate CDE's response to such notifications. Determined whether CDE had received reports of noncompliance from districts or county offices and whether our selected districts and county offices reported noncompliance to CDE.
5 To the extent possible, determine the number of active shooter threats or incidents that have occurred in and around K–12 schools statewide.
  • Reviewed information on active shooters obtained from the FBI.
  • Surveyed 983 districts and county offices about school violence, active shooter incidents, and safety plans.
6 For a selection of schools, districts, county offices, and charter schools, including at least one small district and one district located in San Bernardino County, determine the following:
  • Selected San Bernardino City Unified School District (San Bernardino City Unified), Taft Union High School District (Taft), Rocklin Unified School District (Rocklin), and the Kern, Placer, and San Bernardino county offices for review based on a variety of factors, including prior history of active shooter incidents and geography.
a. Whether schools, districts, county offices, and charter schools are complying with laws requiring the development and submission of a comprehensive safety plan.
  • Determined whether a selection of schools at each district and county office had submitted an updated safety plan for 2017 and whether the schools submitted plans by the March 1 deadline.
  • Determined whether each district and county office had approved the plans for a selection of schools by March 1, 2017.
  • For a selection of schools, determined whether the district retained a copy of approved safety plans for the last five years.
  • Determined whether the selected districts and county offices tracked whether schools had submitted updated safety plans each year and assessed the adequacy of the district's safety plan approval process. Districts and county offices are not required to review and approve charter safety plans and charter schools are not required to submit them.
b. The number of active shooter threats or incidents that have occurred in or around the selected school campuses. In addition, determine how the incidents were handled and assess whether the incidents were handled in accordance with the safety plan or other guidance.
  • Interviewed district staff and principals from one charter school and at least one public school from each district, about whether they handled the violent event near them in accordance with their safety plans and whether those plans were adequate to respond to the violent event.
  • Obtained any documentation of other policies and procedures related to active shooter incidents, and implemented by the selected districts and county offices, that might be considered best practices.
c. Whether the safety plan of the selected schools, districts, county offices, and charter schools includes all elements required by law. Assess whether the safety plan includes more elements than required by law and determine the nature and source of any additional elements. Further, determine whether the additional elements are and should be considered best practices.
  • Reviewed a selection of 29 safety plans from three districts, three county offices, and two charter schools to determine whether they contain all of the elements required by state law and whether the safety plans included additional elements related to active shooter incidents or violent events.
  • Reviewed whether the selected plans include additional optional elements, such as provisions related to airplane crashes and civil disobedience.
  • Reviewed additional elements from the selected plans to determine whether they comply with best practices advocated by state and federal agencies.
d. Whether the selected schools, districts, county offices, and charter schools are complying with existing laws and guidelines related to school safety, particularly in the areas that include, but are not limited to, campus violence and active shooter threats and incidents.
  • Determined what guidelines are available from CDE, the FBI, the U.S. Department of Homeland Security (DHS), and other state and federal agencies. State law does not require schools to have procedures for responding to violent incidents, including active shooter incidents.
  • Reviewed a selection of safety plans to determine whether they contained elements related to active shooter incidents or violent events. For those safety plans that included additional elements, determined whether CDE, DHS, and other applicable agencies advocated the elements as best practices.
e. The types and levels of planning, training, and drills the selected schools, districts, county offices, and charter schools employ to respond to active shooter threats and incidents in and around campuses. Determine and evaluate whether the planning, training, and drills are evidence-based or considered best practices.
  • Determined the trainings and drills the FBI, DHS, and other federal entities advocate for responding to active shooter incidents and other violent situations.
  • Interviewed staff from the three county offices to determine what support and assistance they provide to schools.
  • Determined whether the selected districts and county offices require drills and trainings related to active shooter events and if they comply with practices advocated by the FBI.
f. Whether the selected schools, districts, county offices, and charter schools are effectively engaging with other schools or districts, parents, and the community in maintaining safe school environments.
  • Interviewed school and district staff to determine if schools are coordinating with law enforcement before updating their safety plans as required by state law.
  • Determined whether a selection of schools from our selected districts and county offices held public meetings or met with law enforcement before updating their safety plans.
7 Review and assess any other issues that are significant to the audit.We did not identify any additional issues that are significant to the audit.

Sources: California State Auditor's analysis of the Audit Committee's audit request 2016-136, planning documents, and information and documentation identified in the table column titled Method.



Footnotes

1 The FBI defines an active shooter as one or more individuals actively engaged in killing or attempting to kill people in a populated area. Implicit in this definition is that the subjects' criminal actions involve the use of firearms. Go back to text

2 Small districts with 2,501 or fewer students may choose to meet this requirement by developing a districtwide comprehensive safety plan that is applicable to each school site. Go back to text

3 The school may also designate the responsibility for developing and writing its safety plan to a committee. Go back to text



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