The following testimony was submitted to the Federal Commission on School Safety by Kenneth Trump, President of National School Safety and Security Services on August 28, 2018.  The Commission acknowledged receipt the following afternoon.

To the Federal Commission on School Safety:

Commissioners, my name is Kenneth Trump and I am the President of National School Safety and Security Services, a Cleveland-based national firm specializing in school security, emergency preparedness, litigation consulting, and related safety consulting and training. My work in school safety as an officer, investigator, and youth gang unit supervisor for the Cleveland City Schools’ safety division, and as a suburban Cleveland school security director and assistant gang task force director. As a national consultant, I have served more than 30 years in the school safety profession working with school and public safety officials from all 50 states and internationally. As a litigation consultant and expert witness, I have conducted forensic analysis on school active shooter cases (including serving as the defense expert on the Sandy Hook school shooting case), school rape and other sexual assaults, school-involved suicides, child abduction from school, and other safety matters. I am currently a doctoral student at The Johns Hopkins University School of Education in the Entrepreneurial Leadership in Education specialization where my research focuses on school administrator crisis leadership and parent communication issues. I have earned Master of Public Administration and Bachelor of Arts in Social Service (Criminal Justice concentration) degrees from Cleveland State University, and completed more than 2,500 hours of specialized training on school safety and security, emergency preparedness planning, gang and drug issues, terrorism and emergency management, and related school and youth public safety topics. I am the author, co-author, and/or editor of three books, five book chapters, and more than 450 articles on school safety and emergency preparedness issues. I have served as a four-time invited Congressional witness testifying on school safety and emergency preparedness issues, and have testified on the role of the federal government in bullying at a hearing of the U.S. Commission on Civil Rights. I have also testified on school security and emergency preparedness to the Connecticut Governor’s Sandy Hook Advisory Commission, Oklahoma School Security Commission, New Jersey School Security Task Force, National Lieutenant Governors Association, Council of State Governments, Education Commission of the States, and other public policy agencies.

Given this foundation of education, training, and experience, I am providing the following testimony to your Commission for the record as you consider your final recommendations:

Far too many school officials are taking a skewed approach to school safety with “target-hardening." —- security hardware and products — to appeal to parents’ emotional security needs to see a visible, tangible change that they can equate to “improved security” at their child’s school. Parents want something visible and tangible that school administrators can point to and say, “See, we have improved security.” The reality is that many of the more meaningful school safety strategies are actually invisible (see the best practices below).

Some security product and hardware vendors have items that may be a good fit for a K-12 school district’s safety needs, while many — if not most — do not.  The devil is in the details of implementation when it comes to the plethora of gadgets, bells, and whistles on the market.  There far too many opportunistic product and hardware vendors trying to fit their square pegs in a round hole where they just do not fit. The first and best line of defense is a well-trained, highly-alert staff and student body where the people side of school safety takes the lead over hardware and products. Any security technology and hardware is only as effective as the weakest human link behind these physical security measures. Fortifying your school with so-called “single point of entry." sounds emotionally appealing, but it may not necessarily be effective if a person can still gain access through commonly open door doors at custodial delivery docks, food service/cafeteria entrances, and physical education doors. A secured vestibule is a helpful tool for visitor management, but it can also be useless when there is a skewed approach focused on physical security that is imbalanced in its attention to people and procedural components of a comprehensive and balanced school safety program.

I conduct forensic analysis as an expert witness on high-profile school active shooter cases, rapes and other sexual assaults, child abduction, and other school safety cases. While the facts and merits of each case will vary, the common thread is that the majority involve allegations of failures of people, procedures, and systems — not failures of security products and hardware.  Visible, tangible signs of school safety may make parents and others feel emotionally safer, but they may not actually make students and staff truly safer.  “Security theater." by creating a façade of safer schools in the form of visible, tangible pieces of hardware and security products may be more of an emotional security blanket if the focus is overly consumed and focused upon target hardening.

Likewise, quick-fixes and politically-driven “solutions." are equally ineffective.  Bulletproof backpacks, ballistic whiteboards, metal detectors, teaching children and educators to throw iPads and pencil cases at heavily armed gunmen, arming teachers and non-law enforcement laypersons, and other measures are high-risk, high-liability propositions.  Arming teachers and using federal funds for educators to buy guns presents exceptionally high-risks that could easily be avoided by investing in trained, certified, and commissioned police officers commonly known as School Resource Officers (seehttp://www.schoolsecurity.org/trends/arming-teachers-and-school-staff/). Teaching children to attack gunman, such as is encouraged by Homeland Security departments and the federally-marketed “Run, Hide, Fight." or the privately promoted ALICE Training and similar “options-based." active shooter training, fails to take into consideration age and developmental, special needs, and other child-oriented factors (see http://www.schoolsecurity.org/trends/alice-training/).

School leaders need to focus on best practices: Creating a climate where students feel comfortable to report weapons, plots, and other safety concerns; Creating threat assessment teams, training, and protocols; Providing students with emotional, behavioral, and mental health supports; reasonably diversifying basic school safety drills (fire, lockdown, weather-related, police-controlled evacuations) without going over-the-top to do more harm and debrief lessons learned from each drill; forming crisis teams, train them, and make sure they meet proactively; assessing security and emergency guidelines at least annually; reasonably improve information sharing and data integration on high-risk students without privacy violations; and engaging students, parents, and school-community partners in communications and planning for school safety.

Suggestions that school safety needs to be placed in the hands of the U.S. Department of Homeland Security at the federal level, or in state Homeland Security departments at the state level, are flawed. The composition of your Commission itself, with the Departments of Education, Health and Human Services, Homeland Security, and Justice leading the Commission, reflects the balance and depth of the issues related to school safety, security, and emergency preparedness.  A federal school safety czar or a Homeland Security department for school safety would be little more than a waste of federal dollars in creating a new bureaucracy that would provide little meaning or true support to local schools. If this was appropriate, the Commission would not be composed of form federal agency heads. The same applies for special interests advocating for new federal standards for School Resource Officer training or physical security measures under the guise of critical infrastructure.  The devil is in the details of implementation, there are far too many risks of “unintended consequences,." and it is highly doubtful that the federal government would ever fund the implementation of such federal mandates/standards. School safety is a state and local issue due to the diversity of school communities and school safety threats, needs, and implementation considerations.

Perhaps the most important thing the federal government could do is to restore the post-Columbine programs that were created in a bi-partisan, apolitical manner to address comprehensive and balanced school safety programming and federal school safety policy.  These include:

1. Restore and expand eliminated federal school safety programs including the Readiness and Emergency Management for Schools (REMS), Secure Our Schools, and Safe Schools, Healthy Students programs.  Focus the REMS program on its original model of prevention, mitigation, response and recovery grants direct to local schools that develop lessons learned and models that can be replicated in our nation’s public, private, charter and other schools.  Make the Secure Our Schools grant moderately funded and to require security equipment expenditures to be a part of a more comprehensive, people-oriented approach of school safety programs. Focus Safe Schools, Healthy Students program on providing student mental health support models to prevent violence, school shootings and other violence.
2. Restore the COPS in Schools program and address legitimate concerns about the school-to-prison pipeline through training and modeling programs in accordance with proven best practice models in school-based policing.
3. Establish new violence and drug prevention programs, training programs for school security, policing and administrative personnel, and related programs that address emerging trends, such as the nation’s heroin epidemic, terrorist lone-wolf security threats, etc.
4. Keep the gun-control and gun-rights debate where it belongs: Separate and distinct from school safety policy, and debated without exploiting it under the guise of school safety.
5. Address civil rights concerns with school discipline, policing and security, bullying and other safety issues, while making these programs and strategies an inclusive part of a broader, comprehensive federal school safety policy and programming strategy.
6. Avoid limited, narrowly focused school safety programs and policies that are skewed heavily to security hardware and equipment, or modeled after homeland security and other practices that are geared for non-child-centered industries and facilities.
7. Engage experts in federal school safety, security and emergency preparedness who are experienced and knowledgeable of preK-12 schools, i.e., experts in preK-12 school security and policing, school psychology, school administration, etc. who understand preK-12 school climate, culture, special needs and school-community relations.
8. Balance funding for research and direct resources to schools. Reasonably fund research to see what works. But also put limited federal school safety funds where they belong: On the front lines to keep students and educators safe TODAY.

In closing, all voices need to be heard. But they also need to be distinguished.  There are advocates, activists, and experts presenting opinions. Advocates suggesting policy changes based upon single-incident facts may not be the best policy options. Likewise, political and social activists deserve to be heard, but single-agenda policy recommendations may not be the best policy options. School safety is a local and state issue, and the best federal intervention now is not a federal school safety czar, a Homeland Security Department takeover, skewed approaches toward physical security, or similar feel-good, knee-jerk approaches. There is existing data, research, and best practices on school safety, security, and emergency preparedness from the past 20+ years. You do not need to reinvent the wheel. You do not need to create a new bureaucracy or unfunded federal standards or mandates. We know what needs to be done. Get the information and resources to local school leaders to do it.

Respectfully

Kenneth S. Trump

Kenneth S. Trump, M.P.A.
President
National School Safety and Security Services