Resiliency in the Modern Society: The Japan Earthquake Lesson

By: Joe Mazzarella, SVP and Chief Legal Officer, Mutualink, Inc.
March 17, 2011

As Japan urgently struggles to combat the predations of a massive earthquake and tsunami, the forces of chaos have offered up another sober warning that societies are fragile. The everyday certainty and reliability experienced by citizens and leaders of modernized nations obscures the inherent vulnerabilities attendant to complex economies and societies functioning in a deeply interconnected and interdependent manner. The paradox that the Japan earthquake lays bare is that the very thing that creates a highly efficient and successful economy may well be the same thing that exposes us to catastrophic ruin.

As the world has witnessed, Japan is suffering enormous devastation from a series of compounding events spawned from an initial large scale natural disaster. These secondary and tertiary events have cascaded like a series of invisible dominos spanning outwards in many directions from a single push of a finger. Japan’s emergency response and support infrastructure is being stressed beyond its capability to respond to all needs. From debris fields blocking search and rescue teams, heavy equipment and relief supplies being cut off from communities, to stranded people, trains and impassable roads, limited electricity from rolling blackouts, radiation clouds and evacuations, gas rationing, empty food shelves, insufficient numbers of body bags and decaying corpses due to a lack of refrigeration, and snow and cold freezing adding to the plight of millions of displaced people, the effects of mother nature’s wrath seems to know no bounds. As this is being written, the specter of a mass evacuation of Tokyo is not beyond the realm of the thinkable should Japan’s nuclear emergencies continue to worsen and become unchecked. The impact of evacuating 18 million people and the ensuing panic it will ignite, couple with overwhelming devastation from the earthquake could result in major collapses in critical sectors of their civil society.

Fortunately, Japan has an intangible advantage that may very well be the key to their short and medium term survival, the inherently cooperative, caring and self-restrained nature of the Japanese society. It is the culturally engrained resilience of the average Japanese citizen that will provide a vast network of local human support infrastructure that will enable them to prevail. The simple act of sharing a bottle of drinking water with a neighbor, sharing heat or shelter and food, instead of hoarding resources and closing out those in need may be essential difference between mass suffering occasioned by death and illnesses and great discomfort but survival. And, the reports of this type of behavior are not few or far between.

On the other side of the equation, one can readily observe how the more sophisticated and complex societies become the more fragile they are in terms of their exposure to large scale disasters. As societies become more modernized, economic sectors becomes more specialized along verticals and more concentrated, becoming ever more efficient in production and streamlined in the delivery of services and products. Economies of scale are achieved through great volumes, and this has the practical effect of driving consolidation, cost reduction and lower prices and higher profit margins. Communications and digital information networks drive financial transactions and exchanges set prices and delivery of critical commodities. Electrical and hydrocarbon based energy systems power our communications and information networks as well as our factories, transportation, and nearly every appliance in our households. Food production sources are no longer local, and they crucially depend on transportation and refrigeration. Water and sewage treatment systems depend on power. Medical systems depend on specialized medications and equipment manufactured by a small number of facilities and delivered by transportation systems. Shipping requires fuel and functioning transportation systems and ports, and payment settlement systems. This litany of interlocking dependencies could be continued virtually ad infinitum with increasing granularity, but let the above suffice for sake of argument.

Where the old watch maker may have made his own parts or bought materials from locally produced resources, the new global watch company assembles much, makes little and consumes even less locally, preferring to depend and upon vast supply chains, special parts makers, and sophisticated just in time transportation networks to receive goods and ship them back out to the market. And so it is for a thousand, thousand other niches which make up our vast and complex economy. The same holds true for the individual, where once most households were highly self-sustaining entities, virtually nothing is produced in the household. We are dependent on the delivery of food, electricity, water, and heat to our homes. Whereas at one time nearly all food was produced and sold locally yet a pair of French silk stockings was a rare imported extravagance, today it is just the opposite. One would be more likely to find French made stockings in a grocery store than to find locally produced berries. Modern households are fragile and are deeply dependent on far reaching, often global, supply chains to perform.

Simply put, a vast web of highly dependent connections produces the marvel that is our increasingly productive, specialized and hyper-efficient world. But when one thread frays and breaks, as in the case of a large scale power outage, the fabric can quickly unravel especially when pulled upon and stressed even by the smallest of forces.

Perhaps one of the most astute initiatives of the Department of Homeland Security in regards to emergency preparedness is focusing on strengthening the resilience of communities. The introduction and promotion of this concept is essential to our security. Yet, its true implications may far exceed its intended import. It is one thing to have an all hazards coordinated public safety and emergency response structure that can scale and work with a unified purpose in times of disaster, but it is quite another to achieve a resilient society. In the first instance, much work is being done to plan for and be able to respond and recover from disasters through a better coordinated public emergency response agency structure and this will pay dividends. In the latter case, true community level resilience simply may be at odds with the forces of economic globalization.

Resilience in terms of key infrastructure and critical resources requires more than redundancy. It requires diverse modalities with functional redundancies. By these terms, I mean using many different methods and ways to achieve the same or substantially same functions. On both accounts, global economic forces drive in the opposite direction.

First, at a pure redundancy level, redundancy means necessarily having more of the same thing. By definition, this means having excess capacity. This is squarely at odds with competitive global economic forces that drive the cost of production down by eliminating excess or idle capacity. In the most efficient and productive market ideal, the productive capacity of an asset should be producing at full capacity up to the last marginal profit dollar. At anything less, it is not being used to its highest economic value. So, creating more idle capacity is at odds with market forces even if it is beneficial from a disaster perspective. Worse yet, productive capacity is often dislocated from local areas and moved to more cost efficient places, often in other parts of the world. But, the problem extends even beyond global market forces. In the case of large scale systems that present significant investments such as electrical transport grids, regulated monopolies replicate the same conditions of singular reliance without redundancy. In the United States, our electrical transport system is vulnerable to mass outages because of its spoke and hub topology and lack of real redundancy in transport. It is unlikely that rate payers will be willing to pay the cost for an abstraction called redundancy. So, in most cases the practical reality is most are unwilling to pay more to ensure resilience against a remote event whether it is indirectly through buying behavior or in the form of a direct cost.

Secondly, pure redundancy (or more of the same) is not sufficient in terms of establishing true levels of resiliency. As was demonstrated in the Japan nuclear reactor failures, redundant cooling systems constructed the same way may reduce probability of failure but all are vulnerable to the same type of failure. So, if the causation event spans each system space (i.e., it is sufficiently large to span all redundant systems), the probability of failure is not lower as predicted, it is the same as having one. An analogy can be drawn to airplane hydraulic systems. Three redundant hydraulic lines running through the same harness is not redundant if a turbine blade from an engine breaches the plane and severs all three lines. Again, in the global economy, forces are at work that are driving towards commoditization and pushing against multi-modal diversity. Across virtually all industries the same or similar parts (and underlying designs) are often used by the same vendors. Lower prices attained through scale and volume drive homogenization at the component level and this even dictate similar outcomes at systems levels. Unique approaches in mechanical, operational and even software design are driven out of the system for routine but critical functions.

So what is to be done? Certainly, the substitution of free market mechanisms with old style managed economies is unwise and proven to be a failure over the long term. But what is new is that global market forces are operating in ways that are asymmetric to sovereign interests. Once robust and competitive production assets are removed from the fabric of a nation (whether it is energy resources or raw and processed materials production, food production, core manufacturing capabilities, technological know-how), the overall resilience of that nation becomes dependent upon cooperative forces beyond its borders. Nations become subject to global supply chains and the competing interests and decisions of foreign entities and agnostic market forces. The ability to direct policies that create a robust and healthy production capability across vital domestic infrastructure segments is beyond the grasp. The ability to persuade or direct re-tooling, increased production, or the redirection or concentration of goods and supplies in response to a crisis for the good of the country is lost. Looking at the United States, a strong case can be made that it has become substantially more vulnerable over the past 30 years as its competitive industrial production and infrastructure has been dismantled and shipped overseas. Many of our critical resources, raw materials and finished materials are produced in foreign markets, and little domestic capability remains. While at advent of connected global markets have increased the diversity and supply of goods and services at lower prices under stable conditions, we may well have placed the core of our safety and security during major crisis into the hands of others in that exchange.

We must begin to investigate and understand the vulnerabilities that are being created by complex interdependencies through economic globalization. There is a compelling case to be made that consolidation and elimination of domestic industries create additional vulnerabilities to large scale disasters and hamper recovery. It further can be said, the very nature of advancing economic realities are that all sectors are interdependent with others in one way or another. Resiliency requires investment in diversified redundant capabilities with back-up capacity in key sectors of our economy. Also, restoring and protecting competitive production capabilities across key sectors within domestic markets is vital to a resilient fabric. Perhaps the forces of globalization are so strong that it is impossible to restore local and regional resilience by reestablishing domestic competitive infrastructure. But knowing this fact compels us to seriously understand and evaluate the systems and delicate dependencies that are critical to allowing basic services to continue to function in times of large scale disaster and provide a path for recovery. It may be that basic policies at local, state and federal levels must serve to foster effective surrogate diversified redundancies so that we can achieve a counterbalance to the fragile environment we have constructed.

Finally, returning to Japan, perhaps when all else fails the last line of resiliency lies in the citizenry itself. Creating a culture of individual preparedness and fostering mutual care among neighbors during times of crisis might very well be the invisible thread that holds us together.

***

Our sincere prayers and condolences go out to our friends in Japan

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New Commando Style Terror Plot Predicted in Mumbai Security Briefing

In December, 2008, I wrote an after action Mumbai Attacks Security Briefing in which I advised that the public safety agencies and high risk/high impact targets should be prepared for coordinated multi-site urban terror assaults (commando style attacks) that are modeled after the Mumbai terror attacks. Specifically, I suggested that the operational signature of the Mumbai attacks provided important information that can assist officials in preparing for and responding to potentially similar events in the future. The recently reported terror plot which appears to have been foiled should serve as a stark reminder to our public safety and emergency response agencies that the specter of a large scale coordinated terrorist attack focused on multiple soft targets remains a major concern.

Few details regarding the uncovered plot have been disclosed but some key information has been released, including the fact that the terror plot involved numerous operatives across Europe, attacks were to be coordinated and targets where possibly focused on hotels, malls and stadiums. This information suggests a fit with the Mumbai attacks. The significance of the Mumbai attacks should not be lost in that it represented a continuing departure from the historically favored terror targets of air and rail transportation, and a move towards commando style coordinated attacks. The Mumbai attacks were immensely “successful” from a terrorist perspective, causing large scale carnage and disruption across a major metropolitan region and “success” breeds emulation.

The Mumbai attacks should be seen as part of a natural progression and continuing adaptation of tactics that are moving towards exploiting soft targets using commando like operations. Predecessor events pointed to this new type of threat. These include the savage Beslan School attack in Russia on September 1, 2004, where Chechen terrorists took more than 1,100 people hostage and 334 hostages (including 186 school children) were massacred when they detonated explosives inside the school building. The Beslan attack was preceded by a similar large scale soft target attack on the Moscow Theater on October 22, 2002. The Moscow Theater attack involved over 40 Chechen terrorists taking 850 people hostage. After a two day standoff, Russian security forces conducted a raid and 170 people died. In addition to large scale attacks on soft targets involving many operatives, terrorists have shown an increased attraction towards attacking hotels. Attacks include hotels in Bali, Egypt, and Israel. The Somali terror affiliate of Al Qaeda, Al Shabab, claimed responsibility for a recent August 24, 2010 military commando style attack on the Muna Hotel in Somalia where parliamentarians were meeting, resulting in the death of 31 people.

In retrospect, it comes as little surprise that the Mumbai attacks represented an adaptation and progression of tactics which emulated components of previous attacks. The focal point of the Mumbai attacks was the Taj Hotel, in keeping with predecessor hotel bombing attacks. Borrowing from its Chechen counterparts, the Mumbai terrorists employed a commando style bloody hostage taking assault, and in keeping with Al Queda’s coordinated attack signature adapted further by undertaking coordinated attacks across 10 locations striking key response infrastructure.

There is little reason to doubt that similar plans were underway in this most recent terror plot. In terms of the future, it would seem likely that a domestic terrorist attack will be a coordinated and distributed commando style attack aimed at soft targets and possibly first responders and support response infrastructure. The likely targets appear to be schools, hotels, stadiums and high capacity facilities. Among these targets, hotels remain the most likely target because they are uniquely open to transient traffic, they house large numbers of people, and the ability to surreptitiously smuggle weapons and explosives in luggage as guest is relatively easy. Further, the rooms at the hotel become ideal operational bases from which operatives can meet, prepare and deploy to designated targets. Further, removing and transporting weapons is easy because the can be transported in innocuous looking luggage. Finally, operatives can check-in to rooms at varying intervals to appear unrelated to other conspirators and can request rooms at strategic locations where they can wire explosives and incendiary devices.

Hotels that are most a risk would appear to be larger hotel facilities which are located in metropolitan areas with more diverse populations that include Middle Eastern and African immigrant populations, so that terrorists can more easily blend in to the population. Thus, hotels in localities that serve as gateways for international air traffic like Atlanta, Chicago, Dallas, Detroit, Los Angeles, Miami, New York, San Francisco and Washington DC, would seem to be more at risk than others. Among these, smaller cities would seem to carry a possibly higher t risk because they have less resources and security assets at their immediate disposal to combat an attack. This would make Atlanta, Dallas, Detroit, Miami and San Francisco possibly more attractive potential targets. This pragmatic consideration, however, may be offset by the desire to attack a more significant and symbolic city.

Among types of hotels, skyscraper style hotels would seem to be more at risk than those that are more campus oriented and have more distributed entrances and exits, because it is easier to control the entire hotel facility with many floors by controlling a ground floor with limited entrance and exits. Additionally, traditional American associated brand hotels would seem to be more likely targets because of their symbolic value.

In addition to hotels, large elementary and middle schools in metropolitan areas appear to be potential targets of concern. Generally, these facilities are not well protected against sudden commando style raids. Attacking grade school level facilities also offers terrorists distinct advantages, including a hostage population that will be unable to resist in early stages of an operation, and adults who will be over taxed in attending to children. Further, great political pressure will be placed on officials to avoid any action on the part of public safety and security forces, yet it will command and tie down considerable resources due to the nature of the event. Attacking this target in concert with others will place tremendous stress on available response resources, thus giving terrorists more opportunity to inflict large scale carnage and damage at secondary targets.

As a final note, from a historical perspective it appears that early and aggressive action on the part of security forces would appear to be appropriate. The longer that time passes, the more terrorists are able to entrench, wire explosives and prepare for an assault. In most instances of radical Islamic terrorist attacks, the record indicates it is unlikely there will be a peaceful conclusion and that negotiation merely affords terrorists time to prepare for final acts of mayhem and martyrdom.

Strong emphasis should be placed on building regional terror response teams capable of responding with military like force and special operations capabilities. Response time to the scene should be gauged in minutes, not hours or days. The sooner responding forces can insert into a scene the more they can take advantage of a chaotic and unstable environment. In order to effectively deploy these types of capabilities, tools that provide real time situational awareness are key. These tools include ensuring that advanced interoperable communications and information sharing are in place. This includes enabling communications between hostages and field level responders, sharing video and communicating across multiple responding agencies.

While we all are relieved that a serious terror plot may have been stopped, we all know this is not the last in a determined effort by increasingly worldwide fanatical terror networks to strike a devastating blow against the West.

Pandemic Preparedness & Crisis Management in the Media Age

This is a reprint of a feature Article published with EMSResponder.com in March 2010. All rights are reserved to EMS Magazine and the author, respectively.

By: Joe Mazzarella. Chief Legal Counsel, Mutualink, Inc.

Date: March 26, 2010

The initial stages of the HINI flu virus raised much alarm due to the real fear that it could turn into a major health disaster. Although widespread, it has fortunately proven to have limited lethality thus far. Nonetheless, the H1N1 pandemic stressed and continues to place heavy demands on our public health response systems, and it demonstrates that we need to remain vigilant and ready to act, because the next pandemic is surely around the corner, and its severity and impact could be much worse. The Spanish Flu pandemic of 1918 killed an estimated 20 to 50 Million people worldwide may seem anachronistic because modernity offers us advanced medical care, the modern environment offers new challenges in disease transmission through a a highly mobile world where a single infected individual in Hong Kong can infect hundreds in New York in less than 24 hours. Much like a category 5 hurricane that looms offshore ready to potentially strike, public health and civil emergency preparedness organizations need to be prepared for the potentially catastrophic effects of a major pandemic that is highly contagious and lethal. In any large scale pandemic with significant lethality, there is a low, but nonetheless real risk that basic social systems may unravel through a series of cascading and interdependent events. While the health care system remains ground zero in any pandemic outbreak, other sectors of society that provide essential services can be significantly impacted or disrupted in major outbreak. Major civil strife can be triggered when a critical mass of individuals no longer trust that the basic support mechanisms of civil society will protect them and they begin to change behavior and challenge public order because it is in their best interest to do so. Public information officers are front in center in preempting these events before they reach an unmanageable and self reinforcing state. While public officials struggled to communicate with large portions of the population in 1918, the opposite problem exists today. Ironically, the virulent and uncontrollable virus which could be the catalyst for major disorder is not the actual virus itself, but our modern viral communications environment. The Internet and a 24x7 news media culture enable sensationalism, misinformation and distortions to be quickly and uncontrollably and indiscriminately spread far and wide. Social media sites, blogs, email, and text messaging are power mediums that allow individuals to quickly disseminate and propagate information, opinions, and speculations. With the increasing presence of mobile cameras coupled with web enabled publishing and viewing forums, inflammatory content can be captures and instantly broadcasted throughout cyberspace. The opportunity to instill fear, insight panic and instigate hostility has never been greater for so many with such little consequence for so few, whether they are willful or sadly in error. Additionally, due to the legacy of Hurricane Katrina, today’s citizenry is conditioned to embrace messages that affirm a view of the government which is dispassionately incompetent in handling large scale emergencies. Consequently, the pervasive modern digital media environment has made communications ground zero for public information officers and liaison officers. Improved communications and sophisticated dissemination strategies must be used to effectively combat and counteract disinformation, and ensure vital public information reaches its audience. At the core of the of this effort, emergency response planners and officials must pro-actively manage and disseminate information, enlist and collaborate with key community representatives and groups, and anticipate and seek to mitigate inaccurate information before its emerges with irreversible momentum. The recommendations listed below are not exhaustive (fn 1), but serve to demonstrate the many issues and dynamics that come into play when a major pandemic or mass health crisis strikes. Pandemic planning must be comprehensive and take an expanded view of the social dynamics and impacts that occur at both the community and individual level when engaging in disaster communications. The audience, substance, truthfulness, timing, consistency, frequency and method of delivery are all important factors in successfully achieving an effective and sustained communications initiative. It might be that a few well placed words could be the difference between devolution into chaos or a quieting refuge that safely weathers the storm.

H1N1 Pandemic Flu Public Safety Preparedness and Communications Management Tips

1. Frontline Multi-agency Communication and Information Sharing. Basic, accurate and consistent health information should be shared among all agencies and their personnel. Information includes facts about prevention and precautions, symptoms, treatments, recovery rates, high risk groups, and fatality rates. Agency personnel that interface with the public must project confidence and a general command of the subject matter.

2. Cross Agency Collaboration and Policy Consistency. While agencies may serve different functions, they will intersect and overlap in key areas and interdependent ways. Ensure that each agency’s policies and procedures dovetail with one another in collaborative response scenarios. Agencies that are subject matter experts within their functional domain should take the lead in establishing recommended inter-agency policies coordination, and judgments should not be supplanted by non-expert agencies. For example, disorderly conduct and civil control should be established by law enforcement professionals, while first aid response and emergency medical treatment procedures should be established by medical professionals. Although expert agencies should take the lead, expert agencies need to collaborate and refine procedures to deal with unique concerns or issues that may be raised other agencies in relation to the particular health emergency circumstance.

3. Interoperable Emergency Communications. Key agencies such as public health agencies, hospitals, EMS, Offices of Emergency Management, and police should have effective real time interoperable communications and information sharing systems in place.

4. Engaged Public Information Management. Proactive and engaged public information out reach is necessary to educate the citizenry and also preempt and combat misinformation and distortions. Engaged public information management includes:

a. Educating and Preparing Public Leadership. Ensure the timely dissemination of official positions and policies among chief executives and other public officials that may interact with the media or public. Information should be updated frequently and address evolving issues and circumstances. Officials empowered with information will pre-empt speculative, conflicting or speculative commentary which may raise uncertainty among the public.

b. Deal Straight with the Public.

i. Truth and Accuracy. Provide truthful, accurate and complete information. Withholding, minimizing or slanting information will be quickly exposed and undermine public confidence and fuel anxiety.

ii. Use Plain Language. Use plain language, data driven facts, be explanatory and avoid jargon. If medical terms or jargon must be used, explain it.

iii. Explain Your Policies and What People Can Expect. Explain your health emergency policies, activities and policies, and the rationale for them in advance. By explaining your rationale in advance it will diffuse misconceptions and potential claims of bias, arbitrariness or insensitivity. Also, describing what people can expect when interfacing with the public health system will help alleviate anxiety.

c. Modernize Your Communications Strategy

i. Communicate Routinely and Frequently. Merely establishing a web site, even if it is chock full of information and updated often, is still a passive form of communication. It requires individuals to consciously seek out and choose to visit on a repeated basis. Officials should use multi-channel strategies to disseminate information that leverage and reinforce one another, including methods that push information to subscribers. Routinely providing updates is an important strategy to maintain the public’s attention and establish an ongoing conversation.

ii. Proactively Engage Traditional Media. Make access easy for traditional news media by updating journalists and reporters on a frequent basis, and making sure key representatives are available to speak with them. A public media relations officer should be designated as a single point of contact to disseminate news briefing information and assist journalists in establishing contact with various representatives. Requests that are received by operational officials should be directed back to the central point of contact to eliminate confusion, eliminate overlap and distractions, and improve resource and time efficiencies.

iii. Proactively Use New Media Venues. Use real time notification technologies and new social media venues to quickly disseminate important information. Email, SMS, MMS, and RSS subscription based alerting should be routinely employed to push out informational alerts with embedded HTML links to informational landing pages with more information. Using share enabling and viral bookmarking and tagging tools should also be employed like Digg, Del.icio.us, Furl, and Reddit, StumbleUpon. Social media venues like Twitter, FaceBook, and MySpace should also be employed.

iv. Disinformation Management. Another important strategy that can pay dividends is actively monitoring popular internet gathering places and communities for information and rumors that are erroneous or distorted, and taking steps to disseminate corrective or clarifying information. Simple methods such as using Google Alerts with custom key words can help bring new information to your attention. Similarly, establishing a Twitter Account and following parties with relevant topical or subject matter interests can also provide an automated way to check the pulse of public concerns in near real time. Formally designating a member of your public information office to undertake these efforts is recommended.

d. Establish Advisory Communications with Frontline Clinical Health Points. Establish known and repeatable methods of communication for information updates and advisories for all frontline health care professionals, such general practitioners, pediatricians, visiting nurses and emergency room personnel. Advisory information should extend to best practices for waiting room management and segregation, updates on symptoms, treatments, public health reporting, monitoring, testing and hospitalization. As noted previously, employing email alert blasts and other push oriented information delivery methods should be used.

e. Establish Outreach and Communications with Key Groups:

i. Critical Infrastructure and Key Business Assets. Officials should establish key sector outreach representatives to interact with large business, critical infrastructure entities and other important community assets. (fn 2) Pandemic planning documents should be made available to assist business leaders and facilities operators in handling an outbreak and ensuring continuity of operations. Additionally, functional capacity and operational impact reporting should be considered so that public emergency management officials can monitor potential interruption or degradation of key services due to workforce impacts. Areas of monitoring include utilities, particularly field technicians and facilities repair personnel, municipal and regional transportation operators and personnel, such as bus drivers and train operators, law enforcement and fire personnel, acute and primary care facilities. Additionally, specific communications channels should be opened for all mass gathering facilities such as stadiums, theaters, malls and similar venues.

ii. Historically Underserved Populations. Officials should actively engage community leaders, including churches, educators, and neighborhood advocacy groups, to explain policies and procedures, shares information and resources, and provide an official liaison contact to mitigate any problems with access and delivery.

iii. Aged, Handicapped and other Vulnerable Populations. Officials should actively engage group homes and retirement communities to explain policies and procedures, shares information and resources, and provide an official liaison contact to address elderly issues. Special emphasis should also be placed on establishing methods of communication for the blind and hearing impaired.

iv. Schools and Universities. Officials should actively engage with schools and universities (fn 3), both private and public, to regarding recommended prevention, response policies and procedures, monitoring and reporting. Grade schools should also be used as a vehicle to disseminate information back into community households. The state, regional and local education officials should be continually collaborating with public health officials, means for advisory communication and updates should be established and an official liaison contact should be provided.

v. Immigrant and Multilingual Populations. As our society has become increasing diverse and mobile, officials should be aware that there are many non-English speaking residents and visitors, and all critical materials and instructions should be accessible in all major languages represented within the community. Appropriate emergency staffing and response should also include multi-lingual speakers and translators.

5. Monitoring and Preempting Escalation. Officials should be vigilant in monitoring trends in behavior, particularly any rise in occurrence of acts of public disorder and the circumstances under which and places where they are occurring. As discussed, potential flash points are emergency rooms, inoculation centers and dispensaries, among others. Threats and incidents that have any reasonable nexus to the pandemic should be reported into a central repository for analysis and establishing prevention and mitigation strategies. For example, if significant potential for disturbances are occurring at hospitals, then deploying uniformed law enforcement personnel at these locations may temper behavior, but also help contain any disturbance. Implementing real time interoperable communications between security personnel and law enforcement and establishing video monitoring at key locations with real time video sharing with law enforcement is also be a good strategy for force multiplication, situation awareness, and reducing response times.

6. Legal Services Collaboration. Pandemics impact not only the sick, but also their families and care givers. Many people do not have the basic legal documents in place to effectively manage and care for incapacitated family members and friends, such as healthcare proxies to make medical decisions and durable powers of attorney to handle financial affairs. Even worse, the restrictions imposed by medical privacy laws, such as HIPPA, in many cases denies care givers, family members and friends access to important information about their loved one’s medical condition and even works to block information from being given regarding the admission status of a patient at health care facilities. It is essential that individuals be properly advised regarding the need to establish HIPPA privacy waivers for their friend and relatives. Moreover, many have not attended to fundamental matters regarding estate management, particularly if they are younger individuals. In the event of a major pandemic, officials should be working with state and local Bar Associations and other legal profession organizations to build a network of available support advocates for patients and families. The recommendations listed above are not exhaustive (fn 4), but serve to demonstrate the many issues and dynamics that come into play when a major pandemic or mass health crisis strikes. Pandemic planning must be comprehensive and take an expanded view of the social dynamics and impacts that occur at both the community and individual level. In the age of real time electronic and social media, there are opportunities to improve effective communication and planning, but there is also a potential downside. These powerful technologies can act as a major catalyst for panic and social disorder, and emergency response planners and officials must pro-actively manage and disseminate information, enlist and collaborate with key community representatives and groups, and anticipate and seek to mitigate behavioral risks before they emerge and gain irreversible momentum.

Footnotes:

[1] There are a significant number of resources available from international, federal and state agencies covering a broad array of planning issues. The following informational guide is directed specifically at information officers: Effective Media Communication during Public Health Emergencies, WHO Handbook (2005). Ref. at: http://www.who.int/csr/resources/publications/WHO%20MEDIA%20HANDBOOK.pdf. The U.S. Centers for Disease Control and Prevention (CDC) has also created an online instructional course for public information officers called “Crisis and Emergency Risk Communication Training “. It is located at: http://emergency.cdc.gov/cerc/CERConline/index.html.

[2] For a comprehensive resource guide, please see Pandemic Influenza, Preparedness, Response and recovery, Guide for Critical Infrastructure and Key Resources, Department of Homeland Security (2006). Ref.: http://www.pandemicflu.gov/plan/pdf/cikrpandemicinfluenzaguide.pdf.

[3] See, CDC Guidance for State and Local Public Health Officials and School Administrators for School (K-12) Responses to Influenza during the 2009-2010 School Year at http://pandemicflu.gov/professional/school/schoolguidance.html. For universities, see, CDC Guidance for Responses to Influenza for Institutions of Higher Education during the 2009-2010 Academic Year at http://pandemicflu.gov/professional/school/higheredguidance.html.

[4] There are a significant number of resources available from international, federal and state agencies covering a broad array of planning issues. The following informational guide is directed specifically at information officers: Effective Media Communication during Public Health Emergencies, WHO Handbook (2005). Ref. at: http://www.who.int/csr/resources/publications/WHO%20MEDIA%20HANDBOOK.pdf. The U.S. Centers for Disease Control and Prevention (CDC) has also created an online instructional course for public information officers called “Crisis and Emergency Risk Communication Training “. It is located at: http://emergency.cdc.gov/cerc/CERConline/index.html.

Navigating HIPAA and FERPA in an Interoperable Emergency Communications World

By: Joe Mazzarella, Chief Legal Counsel

The current United States homeland security and national emergency response policy as reflected in the National Response Framework (NRF), National Emergency Communications Plan (“NECP”) and National Incident Management System (NIMS) is correctly focused on implementing a scalable and cohesive “all hazards and all disciplines” emergency planning and incident response capability across all levels of government. The implementation of this policy is facilitated through a seamless interoperable communications continuum and information environment. Through this environment public safety agencies and other critical or key community assets can collaborate and coordinate in real time during incidents to achieve force and resource multiplication, greater situational awareness and enhanced response. In this world first responder agencies are linked with important community assets including schools, hospitals, utilities and other key private entities. The implementation of such a cohesively linked emergency communications sharing environment (which is nothing short of essential to improving overall national emergency preparedness and response capabilities to deal with an increasing array of natural and manmade incidents) must also coexist within a framework of privacy laws such as the Health Insurance and Portability and Accountability Act (HIPAA) and the Family Education Rights and Privacy Act (“FERPA”).

HIPAA is designed to protect medical privacy of individuals and limit the unnecessary sharing and disclosure of personal medical information through or by covered groups that routinely house, access and transmit health information, such as hospitals, medical facilities and medical clearinghouse and billing services. Yet, hospitals and medical facilities play vital roles in emergency incident response and crisis recovery efforts. FERPA, like its HIPAA counterpart, also is a privacy law which is directed at protecting privacy of students and their educational records. Notably, student educational records often contain important family and health information. Like hospitals, schools (albeit for different reasons) are also at the center of emergency planning and response initiatives. It is well recognized that school populations are high priority, vulnerable community assets and close coordination and communication between schools and public safety agencies is essential to improving overall emergency readiness. In both cases, we see two key participants in the overall homeland security and emergency response landscape that have unique information privacy laws that may limit the disclosure and sharing of important information in the event of a crisis.

Fortunately, however, this is not the case. Simply put, neither HIPAA nor FERPA interfere with or hamper emergency response efforts. In fact, in each case, they are narrowly drawn in this area and provide ample room to enable both public and private emergency response entities, including “covered entities”, to communicate and share necessary information to carry out emergency response and crisis management functions.

Within the context of interoperable communications systems the operative function and effect is to enable many diverse parties to communicate and share information across boundaries. In the minds of some, this aspect of multiparty participation raises the concern whether participants within a communications group may not be privy to private or protected information and disclosure within this context raises the potential for inadvertent violation of these laws. This question naturally leads to the next. Do these laws require authorization levels to be established to ensure only certain participants join in group communications where certain types of protected information are to be shared? Further, must the type and scope of information that may be shared or disclosed be tailored based upon the identity of the parties that are participating in joint communication session? Thankfully, the reality is that these questions and concerns are implicitly handled in emergency contexts, assuming covered entities under HIPAA employ standard operating policies that they already have in place and good faith reasonable judgment is used by all in light of the circumstances at hand. As a general proposition, neither privacy law restrains or prevents the flow of important information where it will protect the health, welfare, or safety of the subject individual whose privacy is being protected or those in logical and circumstantial proximity to the individual.

HIPAA. HIPAA, along with imposing uniform data coding practices, generally prohibits the unauthorized electronic disclosure of a patient’s protected health information (PHI). This prohibition is comprised of two main thrusts, one aimed at transactional privacy, and the other at ensuring data security. The rules in this area are manifold and complex. However, HIPPA is limited only to “covered entities” and there are safe harbor exceptions for various circumstances where the public interest outweighs individual privacy.

Generally speaking, covered entities are hospitals, medical facilities, health providers, and medical billing entities. HIPAA does not apply to public safety responders and agencies, including EMS (however private ambulances and those owned by, or affiliated with, a covered entity are subject to the law). Non-health care related entities and schools (except in limited cases of on-site school health clinics) are not covered. Moreover, entities that may store medical information as part of their overall function, such as independent living centers, social agencies, public health care agencies, transit organizations, and non-governmental organizations like the Red Cross, are not covered entities. Thus, most participants within any community-wide or pervasive interoperable communications environment are not subject to HIPAA. Yet, as noted, health and medical entities do play a major role within the emergency response environment and are covered by HIPAA.

Covered Entities. Given that many covered entities would participate within an interoperable emergency response communication system, an issue that does arise is how covered entities can participate without running afoul of HIPAA. The most likely circumstance where concerns would arise is in the case of emergencies or incidents where responding or participating parties may be requesting medical or health status information on one or more individuals from a covered entity (such as a hospital or medical provider). However, HIPAA makes provision for the disclosure of necessary information in emergencies.

HIPAA Safe Harbors for Emergencies.

Disclosure During Emergencies. The Department of Health and Human Services (“HHS”), the agency responsible for the administration and enforcement of HIPAA, has reaffirmed its position that HIPAA does not prevent the disclosure of medical information in the case of severe emergencies in order to enable necessary medical treatment and related logistical matters. The applicability of HIPAA became a significant issue during Katrina, and HHS acted swiftly and with clarity to provide guidance that HIPAA does not compromise emergency response and relief efforts. Specifically, HHS has articulated the following guidelines:

Treatment Information. Patient medical information may be shared in times of serious emergency

· with other medical providers (hospitals, clinics, etc.) to aid in the delivery of treatment,

- to enable patient referral and linking with available treatment centers, and

· to coordinate care with emergency relief workers.

Notification. Patient information may be shared as is necessary to enable family members, guardians and others charged with the care of an individual to be identified, located and notified of that patient’s condition and whereabouts. However, to the extent verbal permission can be obtained from the patient, it should be obtained.

Imminent Danger. Providers can share patient information with anyone where it is necessary to prevent or lessen a serious and imminent threat to the health and safety of a person or the public -- consistent with applicable law and the provider’s standards of ethical conduct.

See, Department of Health and Human Services-Office of Human Rights, Hurricane Katrina Bulletin: HIPAA Privacy and Disclosure During Emergency Situations, Sep. 2, 2005, and Hurricane Katrina Bulletin 2: Compliance Guidance and Enforcement Statement, Sept. 9, 2005

Hospitals and health care providers, however, should take note that emergencies do not relieve covered entities from establishing appropriate agreements in advance with respect to its business associates (i.e., agents) that house, store, maintain or administer information on its behalf. The HSS makes it clear that business associates and covered entities, must have a business associate agreement in place to ensure general compliance with HIPAA privacy requirements. Within these agreements provision and consideration can be made for information sharing in cases of emergency. HHS has published a sample business associate’s contract that may be used and adapted to meet the relationship that may exist between the covered entity and its business associate. See 45 CFR 164.504(e)(2)(ii)(D). The sample contract can be found on the internet at:

http://www.hhs.gov/ocr/privacy/hipaa/understanding/special/emergency/enforcementstatement.pdf.

Accordingly, as part of any hospital’s or other health care provider’s emergency preparedness efforts, appropriate due diligence should be undertaken to identify whether any third party agents hold or provide information that may be required to be disseminated or shared during a crisis, and make sure a business associate’s agreement is in place to avoid a possible disruption or delay in furnishing key information during an emergency.

FERPA Safe Harbor for Emergencies

While HIPAA governs protected health care information, it does not cover health care information that is part of a student’s educational records. Health care information that is stored and maintained by schools (with the exception of on-site health clinics which process and seek insurance payments), although medical in nature, is considered part of a student’s “educational records” under FERPA rather than HIPAA. See, Department of Health and Human Services and U.S. Department of Education, Joint Guidance on the Application of the Family Educational Rights and Privacy Act (FERPA) And the Health Insurance Portability and Accountability Act of 1996 (HIPAA) To Student Health Records, Nov., 2008. Consequently, one must look to FERPA in regards to disclosure of student information in times of emergency.

Again, like HIPAA, under FERPA the disclosure of information within educational records to appropriate third parties is permitted without any consent in connection with an emergency. The information that is permitted to be disclosed however must be necessary to protect the health or safety of the student or other individuals. See 34 CFR §§ 99.31(a)(10) and 99.36.

See, also, http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/hipaaferpajointguide.pdf.

Conclusion. Overall, neither HIPAA nor FERPA offer any serious obstacles to the implementation of cohesive, real time interoperable communications and information sharing systems for emergency preparedness and response and can coexist quite well with the broad goals of pervasive interoperable communications collaboration envisioned within homeland security and emergency preparedness realms. Express safe harbor provisions are made to accommodate the reasonable disclosure and sharing of information among entities that are participating within the context of an emergency incident. In each case, the protection of the health and safety of individuals under the exigent circumstances of an emergency is the operable standard by which agencies and participants may collaborate.

As is the case with any subjective standard regarding what circumstances constitute an “emergency” and “necessary” information, good faith and reasonable judgments must prevail. In this regard, for entities that are covered under HIPAA and in the case of student educational records, establishing clear guidelines and policies that assist in evaluating a request for information within the context of any emergency is important. Integrating these policies into an emergency preparedness and response plan may help to support any subsequent challenge to the necessity and propriety of any disclosure by showing they were undertaken based on a well reasoned policy and on a good faith belief that the disclosure was appropriate and necessary. Perhaps even more importantly, in times of emergency the effective mitigation of harm and a successful aid response may turn on the speed with which critical information is shared with responding parties. Delays in responding to information requests caused by uncertainty or time consuming ad hoc legal or unplanned administrative reviews could adversely impact a timely emergency response effort.

Overall, while participants should be vigilant and make proper efforts to prepare for emergencies and integrate sound and lawful information sharing policies into their plans, it should be fundamentally recognized that neither FERPA nor HIPAA should serve as any obstacle to hospitals and schools participating in an interoperable emergency communications platform with other critical community participants. In fact, based upon the prevailing emergency preparedness and homeland security recommendations and policies, the failure to reasonably do so may be viewed as unreasonable in light of generally accepted standards of good security and emergency preparedness practices to the extent participation is available within your community.

Special Note. This article is provided for general information purposes only and does not constitute legal advice upon which a reader may rely. Interested parties are encouraged to consult with their legal advisers. FERPA and HIPAA are not the only privacy laws which may be applicable to you. Many states also have privacy laws which may apply to you.

Twitter® for Public Safety & Emergency Management

By Joseph Mazzarella, Chief Legal Counsel
April 28, 2009

In the world of public safety, obtaining and communicating important information in real time can save lives. In this regard, new communications tools are continually be deployed to improve emergency preparedness and response capabilities within a collaborative “all hazards, all disciplines’” paradigm that implicitly requires coordinated planning and response among responders, supporting agencies and other critical assets. These communications improvements range from employing mass alerting and reverse 9-1-1 solutions to advanced multi-agency communications interoperability solutions that link together an array of disparate systems and equipment. While the emergency management sector forges ahead with innovation, the world at large is also blazing new paths and ways of communicating through internet and mobile data driven social networking utilities. Despite the natural temptation to dismiss them as pedestrian at best and frivolous at worst, these social networks may offer something of value to the public safety and emergency management sector. After all, literally millions of users cannot be all that wrong. One of the fastest growing social networking utilities among them, and the focus of this article, is Twitter®, which may offer emergency management and public safety organizations with another potentially powerful and effective communications utility to add to their communications tool chest.

Twitter® is a deceptively simple, yet powerful social networking based communications tool. As described on its web site, “Twitter is a service for friends, family and co-workers to communicate and stay connected through the exchange of quick, frequent answers to one simple question: What are you doing?” See, http://www.twitter.com. With Twitter®, people can follow one another and receive messages from their network of friends in real time. What makes Twitter powerful is it that it links people together around a topic, cause or person, and it provides an easy way to quickly disseminate and share messages among “followers” in the listening group. It is proving to be a popular and particularly attractive communications medium because it intersects with the “always on and available” status created by data enabled consumer mobile devices. Availability or presence is not limited to whether a user logs on to his or her computer anymore. You are always within range of your friend’s “tweet” (Twitter parlance for a message) courtesy of your Blackberry®, iPhone®, cell phone or other mobile device strapped to your hip.

Before you dismiss its potential utility, consider that Twitter is already being used in certain public safety contexts in both planned and spontaneous ways. This April, the Garden City, Kansas Police Department started using Twitter as a free public messaging tool to send out information on events, missing persons and other community advisories, as did the Franklin, Massachusetts Police Department some 1,000 miles away a few days later. In fact, a recent search of Twitter® reveals over 200 police related Twitter® micro-blogs, the largest being the Boston Police Department with over 2,100 followers. Additionally a number of local and state Offices of Emergency Management have rolled out their own Twitter alert based sites, such as Oregon OEM and University of Medicine and Dentistry of New Jersey’s (UMDNJ) Office of Emergency Management to name a few. Beyond state and local agencies, even federal agencies have jumped on board. The Department of Homeland Security (DHS) has its own Twitter® micro-blog which is used for news and announcements, and another micro-blog at twitter.com/LLIS for its Lessons Learned Information Sharing web site (www.LLIS.gov) which is a community repository of best practices information for state and local homeland security and emergency response personnel. The Center for Disease Control (CDC) Emergency Preparedness and Response site uses Twitter as a mass communications tool and has over 2,000 followers. Similarly, the FDA has employed its own Twitter feed at twitter.com/FDARecalls to alert over 3,000 people of its recall of salmonella-tainted pistachio products. See, “Twitter to the rescue: Agencies apply high-tech tools in crisis response” by Elise Castelli, Federal Times (April 06, 2009). While overall use as measured by followership remains relatively small, most of these initiatives are new and they will likely gain popularity as Twitter® becomes better known as a community alerting and information dissemination point.

While mass outbound public communication is a natural use for Twitter®, it may also serve potentially other equally useful purposes. Twitter® is not a one way conversation utility. Namely, it is a tool for information gathering and quick interactive information updating. Followers can send messages too. In fact, Twitter® was reportedly used in the aid of a Swiss Alps mountain rescue operation. As the Alpine rescue unfolded, members of a snowboarding party were sending “tweets” to friends who were, in turn, passing on information to aid in finding their location and providing updated status details regarding their condition. See, “Mountain rescue played out on Twitter; 1 dead”, Associated Press (March 3, 2009). In one the earliest celebrated cases of “Twitter to the rescue”, it was widely used during the 2007 Southern California wildfires to track and report fire movements in real time and alert people of potential oncoming danger. See, “California Fire Followers Set Twitter Ablaze” by Michael Calore, Wired Blog Network (Oct. 2007).

In this vein of emerging communications and cooperation, it is worth noting one particular Twitter micro-blog that is very interesting – twitter.com/HoustonFireDept. The Houston Fire Department is sending out incidents generated from its CAD system as “tweets” with hypertext linked mapped location information. It is quite easy to imagine extending this type of alert into an interactive web based information gathering portal through which the public can contribute information, and also follow incident updates at an incident defined level.

The above examples provide a glimpse into the potential utility that Twitter® may offer in the realm of emergency response and public safety. Imagine what thousands of eyes and typing hands can do to provide important information to public safety agencies during a large distributed, evolving crisis such as a natural disaster. Or, perhaps what a handful of people in the right place and at the right time can offer in the case of a manmade disaster or terrorist attack. In the case of Citizen Corps, 2,342 local councils have formed across that United States. These Corps are local citizen based civic emergency preparedness organizations designed to assist local communities with civilian emergency planning and response. Twitter might play a constructive role in providing quick updates to diverse members. Or, consider how Twitter® or a secure private Twitter-like service might be used for NIMS Incident Command System (ICS) communications functions for providing quick updates from branches, divisions, tactical units or groups. Each of these applications presents potentially useful benefits. Like any good communication tool, it has the ability to act as a force multiplier by increasing information flow and raising real time situational awareness.

As is the case with many new communications tools, functional or pseudo-functional overlap with legacy systems is not uncommon. In the area of crisis information management, for example, there are a variety of web-enabled emergency operations center solutions which purport to offer real time information sharing for emergency management personnel. These solutions range from highly sophisticated environments with extensive integrated data views to rudimentary topic driven message boards, many of which purport to comply with Incident Command System (ICS) and Emergency Support Functions (ESF) standards. However, in reality, ICS and ESF are not technology standards or explicit functional requirements inasmuch as they are organizational and process frameworks with rules meant to rationalize and organize command and control, drive coordinated planning, foster continuing training, prompt exercises, assess results, and make improvements, all within a uniformly understandable and scalable way. In this regard, any system claiming or asserting ICS standards compliance (and by implication “completeness or suitability”) misses the mark in that the very essence of the thing they purport to meet contemplates a dynamic and continuing cycle of evolutionary improvement towards an increasingly better state of active preparedness. Improving, replacing and supplementing legacy communications systems and methods to advance efficient, cohesive, real time coordinated communications and information sharing is a core principle of NIMS and ICS. So, the mere fact the there may exist other modalities of communication in use providing “similar” functions should not necessarily preclude an examination as to how the overall environment can be improved by cohesively integrating or introducing new modes of communication such as micro-blogging capabilities.

Of course, integrating Twitter® or a Twitter-like capability into a public safety or emergency management environment raises unique suitability considerations based upon its use context. These considerations include security and privacy, user identity management and authentication, evidence preservation and chain of custody, and practical possession and control matters. In the context of public alerting, for example, maintaining a permanent record of the alert content, its time of dissemination and the party who sent it are all important. These records must be maintained in a secure and controlled environment to ensure their integrity in the event of subsequent litigation or an investigation. Moreover, as with any alerting mechanism, the actual credentials and permissions of the person authorized to send alerts must be carefully managed. While external threats and breaches from hackers may permit unauthorized users to send out fraudulent alerting messages, unauthorized messaging can also occur from within the agency through lax credentials access and control procedures.

Finally, as with any official public communications outlet, an integrated administrative review and approval workflow component is important to ensure that appropriate quality control standards, legal review requirements, and internal policies are followed, obtained and recorded. In the case where Twitter® might be used to collect information from the public, concerns are present that are similar to those that arise in the context of tip lines and other inbound telephone calls. Chiefly among them is being able to process potentially large volumes of information that may be submitted as well as being able to determine its relevancy, verify or assess its likely accuracy and truthfulness, and assess its actionable value in a timely manner. Finally, in the case of internal communications for crisis or emergency management purposes, a broad array of considerations are at play, including the security, authentication and records management issues previously described along with evidentiary and chain of custody matters associated with communications logs. Finally, the use of third party systems where the agency is not in possession and control of its communications data records also leaves the information vulnerable to legal discovery. If information resides in another party’s possession, the agency may have no or limited opportunity to contest or challenge a demand for disclosure, particularly since the party in possession of the data may have no duty to notify the agency, or worse yet, voluntarily chooses to disclose data without due consideration for the agency’s rights or concerns.

Finally, beyond these particular considerations, there are more rudimentary issues that must be addressed when dealing with public safety communications, namely reliability. As this article was being written, Twitter served up a page at 9:39PM EST on April 19, 2009 stating “Twitter is over capacity. Please Wait and try again”. In the public safety, those aren’t welcome words.

Notwithstanding the above, it is reasonable to expect the use of Twitter® to continue to rapidly grow within the public safety and emergency management space primarily as an adjunct to existing mass alerting modalities. It is further likely that Twitter® can and will be used by innovative agencies as a means to enhance information gathering through public participation - in essence enabling “virtual neighborhood watch” capabilities. However, it is very unlikely Twitter® could be adopted for any internal public safety and emergency management communications use because of the additional security, data integrity assurance, information management and control, and most importantly, reliability needs. Instead, it is more likely that private, in-house “Twitter-like” communications utilities will be created that are more suitable for public safety needs that could augment existing internal communications and information management environments, particularly where resources and assets are geographically diverse. But even within a more robust private framework, the public Twitter® environment still can play an important role as a public interface through integration and the application of appropriate information vetting and verification filters to allow relevant two-way information sharing.

Do these things like Twitter® matter? You bet. For someone, somewhere it just might make all the difference in the world. Here is one of my favorite tweets which came from the Oregon Office of Emergency Management (twitter.com/BailyJN):

“Here's the scenario - You are at work, kids at school. Big earthquake. No phone service or power. Roads closed. Tell me your plan.” 3:46 PM Mar 13th

Post Script: As this article was completed and waiting for general publishing, Microsoft announced a beta release of Vine, a new Twitter-like service for emergency communications. As they say “timing is everything” but then again there is a certain obviousness for the reasons described above. See,
http://www.pcworld.com/article/163974/microsofts_vine_emergency_social_networking.html

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The author is not affiliated with Twitter, and the assessments and characterizations made within the article reflect the author’s opinions and do not constitute any endorsement of Twitter or its suitability or reliability for public safety or any other use. Neither the author nor publisher of this article asserts any claim or rights in or to the trade names or marks of Twitter, Inc., all of which are expressly reserved to Twitter.

You can follow the Author’s updates and commentary on Twitter at “@Interoperable”.