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Report Number: 2016-136


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



Our audit concerning K–12 schools' readiness to respond to emergencies, especially active shooter threats and incidents in and around school sites, revealed the following:

Results in Brief

Recent active shooter incidents in and around school sites have underscored the importance of procedures for responding to such events. Our review of data obtained from the Federal Bureau of Investigation found that active shooter incidents became more common between 2000 and 2015, and that kindergarten through grade 12 facilities and institutions of higher education have been the second most common location for those shootings to occur, both nationally and within California. Further, our survey of public school districts (districts) and county offices of education (county offices) in California suggests that the number of active shooter threats and incidents in and around the State's schools has increased since academic year 2012–13. However, state law does not require schools to include procedures for responding to active shooter events in their comprehensive school safety plans (safety plans), a collection of procedures schools use in the event of emergencies and to promote a safe learning environment.

State law could improve safety plans by requiring that they include procedures for responding to violent incidents, such as active shooters. Although not required to do so by state law, some districts and county offices have embraced practices for responding to violent incidents similar to practices advocated by the U.S. Department of Homeland Security and other state and federal agencies. For example, many of the safety plans we reviewed included a procedure known as a lockdown, a process whereby students and staff shelter in the nearest building or classroom and secure all interior doors. However, 14 percent of our statewide survey respondents indicated that they do not require that safety plans include a lockdown procedure or other procedures that specifically address active shooter incidents. We believe requiring these procedures in all safety plans, and bolstering those requirements with training and periodic drills, could help save lives in the event of a violent incident.

We examined 29 safety plans from three districts and three county offices for the presence of 20 key policies and procedures state law requires and found that plans from four of the six districts and county offices were missing some of the policies and procedures to keep students and staff safe. Specifically, safety plans we reviewed from the Kern, Placer, and San Bernardino county offices, as well as from the San Bernardino City Unified School District (San Bernardino City Unified), omitted important elements for fostering a safe learning environment. For example, 14 of the 16 safety plans we reviewed for schools at these four entities lacked procedures to notify teachers of dangerous pupils in their classes. Further, safety plans we reviewed from these four entities lacked some procedures for responding to emergencies. The omission of these elements from safety plans increases the risk that the schools will be unprepared to respond to emergencies, or that the schools will fail to foster an environment where students can safely learn. Moreover, San Bernardino City Unified told us that a number of its schools may be operating wholly without safety plans.

In addition, we found that some districts and county offices have not provided schools with sufficient oversight, which could lead to inadequate emergency responses that are based on insufficient or absent safety plans. State law requires all districts and county offices to review safety plans by March 1 each year. However, our evaluation found that the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified failed to properly monitor their schools to ensure that they submitted safety plans and that the plans contained all the elements state law requires. For example, San Bernardino City Unified has not formally approved a safety plan in the last five years, and during 2017, 15 of 73 schools required to submit safety plans to the district failed to do so. Similarly, the Kern county office had only one safety plan for all of the community schools it oversees, even though state law requires county offices to oversee the development and submission of safety plans by their individual school sites. These districts and county offices are failing to monitor schools appropriately to ensure that they have procedures in place to operate in a safe manner. This lack of oversight may put students and staff at risk, because they may not know how to properly respond to an emergency.

Further, we found that the California Department of Education (CDE) is not providing sufficient guidance to districts or county offices to help them ensure that their schools comply with safety plan requirements. Although CDE has provided some guidance to districts and county offices related to safety plans, given the number of errors we identified in our review and the responses we received to our interview and survey questions, its guidance appears to be insufficient. The Kern county office and San Bernardino City Unified explained that they were unaware of CDE's guidance, either because that guidance had not made it to the correct employee or because CDE sends numerous letters throughout the year. Thus, these letters may have been overlooked. The Kern and San Bernardino county offices noted that their noncompliance stems from a lack of understanding of the state law.

In addition, CDE and the California Department of Justice (DOJ) failed to maintain the activities of the school–law enforcement partnership (partnership). Established by state law, this partnership requires CDE and DOJ to provide safety plan training and guidance to districts and county offices, including holding regional conferences and conducting assessments. Even though only two of the partnership's activities were contingent upon appropriations from the Legislature, CDE and DOJ staff stated that they ceased conducting these functions due to budget cuts. Because neither entity actively participates in the partnership, none of these important activities have taken place in recent years.

Moreover, CDE has never conducted any oversight activities, such as audits, to ensure that districts and county offices are appropriately approving safety plans that their schools submit. State law requires county offices and districts to notify CDE annually of schools that have failed to comply with safety plan requirements. However, CDE stated that it has not received one notification of noncompliance since the Legislature implemented the requirement in 1997. If CDE had conducted a survey or audit similar to the work we performed for this report, it would have found that districts' and county offices' schools were failing to submit safety plans. Until the State takes steps to increase oversight of districts' and county offices' compliance with state laws related to safety plans, it will not know whether these entities need to do more to safeguard students and staff at California's schools.

We also found that some districts and county offices have processes in place to help ensure that schools include the required elements in their safety plans and submit the plans to them for approval. For example, our review of safety plans at Rocklin Unified School District found that its safety plans largely complied with state law. Other districts and county offices could benefit from the best practices we identified, such as distributing emergency procedure templates to all schools in the district and using a document‑tracking system to verify that all safety plan submissions and approvals occur in a timely manner.

Selected Recommendations

To ensure that students and staff are prepared to respond to violent incidents on or near school sites, the Legislature should require that safety plans include procedures, such as lockdowns, recommended by federal and state agencies.

To ensure that districts and county offices are complying with state law each year, the Legislature should require CDE to conduct an annual statewide survey to determine whether schools have submitted plans, and to verify that the plans have been reviewed and approved by their respective district or county office. The Legislature should also require CDE to issue an annual report detailing the survey's results.

To ensure that districts and county offices properly review and approve safety plans as required, CDE should provide additional guidance regarding district and county office responsibilities under state law.

To ensure that districts, county offices, and schools receive guidance on a variety of safety issues, CDE and DOJ should resume their partnership activities, as required by state law.

To ensure that their schools' safety plans comply with state law and are submitted and approved on or before March 1 each year, the Kern, Placer, and San Bernardino county offices, and San Bernardino City Unified should implement procedures to monitor and approve their schools' safety plans. The procedures should include the use of electronic document-tracking services and safety plan templates.

Agency Comments

CDE disagreed with our recommendation to provide additional guidance to districts and county offices regarding building disaster plans, but stated it would update and correct its safety plan compliance checklist and initiate meetings in 2017 with the DOJ to explore the possibility of resuming the partnership's activities. DOJ also stated that it will work with CDE to identify the resources needed to resume the partnership's activities.

The Kern, Placer, and San Bernardino county offices and San Bernardino City Unified disagreed with some of our findings, particularly related to the elements missing from their respective safety plans. In addition, the Kern county office considered its community schools to fall within the small schools exception in state law, and thus claimed it was not required to review and approve safety plans for each of its school sites. Related to its court schools, the Kern county office stated that because its court schools were under the primary supervision of the county's probation department, the court schools' safety plans did not need to include all policies and procedures required by state law. Similar to Kern county's assertion, the San Bernardino county office believed that its schools fell within the small school district exception in state law. The Placer county office believed that some procedures we identified as missing in its schools' safety plans were available elsewhere. San Bernardino City Unified believed it had accomplished the results envisioned under the safety plan legislation by focusing on training and drills. Despite their disagreements with certain audit findings, the Kern, Placer, and San Bernardino county offices and San Bernardino City Unified all agreed to improve their review and approval processes concerning safety plans. The Rocklin and Taft districts did not provide a response to the audit.

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