DIRECTOR'S ORDER #50C: Public Risk Management Program

Approved:

Effective Date:

Sunset Date:

This is the third in a series of three Director's Orders which focus on
employee and visitor safety and risk management. The other two are [50A
(Workers Compensation Case
Management](http://www.nps.gov/refdesk/DOrders/DOrder50A.html), and [50B
(Occupational Safety and
Health)](http://www.nps.gov/refdesk/DOrders/DOrder50B.html). In
addition, other Director's Orders with implications for employee and
visitor safety, health, and risk management are cross-referenced
throughout this Director's Order. This Director's Order and its
accompanying reference manual (RM-50C) supersede NPS-50 and any other
guidance documents that may offer conflicting information.

**1. BACKGROUND AND OBJECTIVE**

The National Park Service (NPS) has a continuing concern about the
health and safety of its employees and others who spend time in the
parks--whether as visitors, volunteers, contractors, concession
employees, or in any other capacity. Those who participate in work or
recreational activities in the parks are always, to some extent, exposed
to the risk of accident, injury or illness. In recognizing this, the NPS
is committed to reducing these risks and their associated pain,
suffering, and financial expense.

Historically, public safety has been addressed primarily at the
operating unit level and generally in response to mishaps. This
Director's Order sets a new direction with emphasis on prevention of
visitor-related mishaps while ensuring appropriate response
capabilities.

The objective of the NPS public risk management program is to establish
and implement a continuously improving and measurable process that
minimizes the occurrence of visitor injury, illness and property loss
and achieves maximum effectiveness in communicating risk to the public,
without negative impacts to park resources

**2. GUIDING POLICIES AND PRINCIPLES**

Within units of the National Park System, the NPS and its commercial
operators, special use permittees, cooperators, and contractors will
meet or exceed all applicable laws relating to public safety, health,
and the environment. Where conflicts arise between codes and standards,
the more stringent requirement(s) will be used.

Section [**8.2.5.1 of Management
Policies**](http://www.nps.gov/refdesk/mp/chapter8.htm) provides
policies and principles to guide the National Park Service's public risk
management program. According to those policies and principles, the
saving of human life takes precedence over all other management actions.
While recognizing that competing concerns often restrict the Service's
ability to eliminate hazards, the Service will strive to protect human
life and provide for an injury-free visit, doing so within the
constraints of the 1916 Organic Act and available resources. The Act
requires the National Park Service to provide for the public enjoyment
of the parks while conserving the scenery and natural and historic
objects and wildlife therein "in such manner and by such means as will
leave them unimpaired for the enjoyment of future generations" (16
U.S.C. 1).

The Service recognizes that the park resources it must protect are not
only a visitor attraction, they may also be potentially hazardous. In
addition, the recreational activities of some visitors may be of an
especially high-risk, high-adventure type, which pose a significant
personal risk to participants, and which the Service cannot totally
control. Park visitors must assume a substantial degree of risk and
responsibility for their own safety when visiting areas that are managed
and maintained as natural, cultural, or recreational environments.

The means by which public safety concerns are to be met is left to the
discretion of superintendents and other decision-makers at the park
level. Examples include decisions about whether to install warning signs
or artificial lighting; distribute weather warnings or advisories;
initiate search and rescue operations, or render emergency aid;
eliminate potentially dangerous animals; close roads and trails, or
install guardrails and fences; and grant or deny backcountry or climbing
permits."

Some forms of safeguards typically found in other public venues may not
be appropriate or practicable in a park setting. For example, a campsite
might present any number of "hazards" that could be mitigated by
artificial lighting, paving, fences, guardrails, water purification
systems, etc., but the park's decision to provide the opportunity for a
backcountry experience may mean that none of these mitigation measures
are taken.

3\. AUTHORITY

The authority to issue this Director's Order and its associated
Reference Manual is contained in 16 U.S.C. 1 through 4 (the National
Park Service Organic Act) and the delegations of authority contained in
Part 245 of the Department of Interior Manual.

4\. OPERATIONAL POLICIES AND PROCEDURES

A.  **Incident Prevention.** The NPS will strive to minimize the number
    and severity of visitor incidents. Through risk assessments, park
    areas will develop appropriate mitigation strategies, which may
    include elements of communication, education, facility design, and
    facility maintenance. (Refer to RM-50C.)

B.  **Communication and Education.** The NPS will emphasize providing
    information and advice to assist park users in selecting and
    planning activities which match their levels of physical fitness,
    technical ability, provisioning and equipment. The goal of education
    is to encourage visitors to develop the judgment, skills and
    experience required to participate in activities safely. (Reference
    Director's Order #6.)

C.  **Facility Design and Maintenance.** The NPS will strive to locate,
    design, build, operate and maintain facilities so as to minimize
    natural and man-made hazards. All visitor facilities will be
    inspected on a regular basis to identify and mitigate unsafe
    conditions. If it is not possible to correct an unsafe condition,
    the NPS will take reasonable action to protect the public from that
    condition. (Reference Director's Order #80.)

    Where facilities or resources have inherent risks that are not
    mitigated through facility design or other physical means, and where
    access to those resources is important in order to achieve the park
    area's mission, communication and education will be used to assist
    visitors in choosing and engaging in use of those facilities or
    resources safely.

D.  **Public Health.** [Director's Order
    #83](http://www.nps.gov/refdesk/DOrders/DOrder83.html) establishes
    NPS policy with respect to all public health activities within areas
    of NPS jurisdiction, regardless of whether those activities are
    carried out by NPS or other Federal employees, or by other
    organizations, including the US Public Health Service (PHS). Public
    health includes illnesses associated with drinking water,
    wastewater, food safety, animal vectors, animal reservoir, hazardous
    wastes, indoor air pollution, institutional sanitation, radiation
    safety, medical wastes, solid wastes, air pollution, and other
    related area of environmental health.

E.  **Incident Response.** The National Park Service will develop and
    maintain a program of emergency preparedness and response. The
    purposes of the emergency service programs will be to maximize
    visitor and employee safety and to protect resources and property.
    ([Reference Director's Order and RM
    51](http://www.nps.gov/refdesk/DOrders/DOrder51-rev.html).)

F.  **Incident Review.** After an incident, a review of the response and
    the incident should be conducted. Findings and recommendations of
    this review should be used to modify the park's risk management
    program, where applicable, and may also be used for developing
    training bulletins to be shared with other park areas. (Reference RM
    50B.)

G.  **Law Enforcement.** Law enforcement plays a significant role in
    prevention of accidents and illnesses, by requiring compliance with
    laws and regulations put in place for the protection of the visitor
    and the resource, and by engaging in opportunities to educate the
    public on the reasons for those rules. ([Reference Director's Order
    #9.)](http://www.nps.gov/refdesk/DOrders/DOrder9.html)

H.  **Structural Fire Prevention.** Fire prevention and suppression is
    the primary consideration in all facilities. Structural fires will
    be suppressed to prevent the loss of human life and to limit
    property damage. ([Reference Director's Order
    #58](http://www.nps.gov/refdesk/DOrders/DOrder58.html).)

I.  **Wildland Fire.** The wildland fire program is designed, and will
    be managed to meet, resource management objectives for the various
    areas of the parks and to ensure that firefighter and public safety
    are not compromised. ([Reference Director's Order
    #18](http://www.nps.gov/refdesk/DOrders/DOrder18.html).)

    5\. RESPONSIBILITIES

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A.  **Visitors.** The NPS expects that park users will exhibit a degree
    of self-reliance and responsibility for their own safety,
    commensurate with the degree of difficulty of activities they
    undertake. Park users are expected to:

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1.  Understand that there are inherent risks and potential consequences
    associated with visiting NPS sites.

2.  Heed the information and advice provided through various NPS public
    risk management programs and observe/comply with applicable laws and
    regulations.

3.  Seek out further information and advice from the park staff when
    they are uncertain about their level of preparedness or the nature
    of hazards and risks inherent in the activities they are planning.

4.  Be properly provisioned and equipped and have levels of knowledge,
    skill, and physical fitness required for the activities that they
    choose to undertake.

5.  Cope with adverse conditions one might reasonably expect to
    encounter, and consider the extent of their self-rescue capability
    in planning and conducting these activities.

6.  Assume a high degree of responsibility for their own actions,
    safety, and survival as well as for those within their care.

    **B. Director**.

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1.  Establishes Service-wide Public Risk Management policies and goals,
    and a system of accountability for accomplishment of those policies
    and goals.

2.  Issues Director's Orders to meet the Public Risk Management needs of
    the Service.

    C. Associate Director, Park Operations and Education

    1\. Is delegated the authority and responsibility to carry out the
    elements of this Director's Order.

    2\. Serves as the "Designated Agency Safety and Health Official"
    (DASHO) for the National Park Service. Represents the NPS on issues
    concerning occupational and public safety management at DASHO
    meetings.

    3\. Exercises the authority of the Director to develop and manage
    the Service's Public Risk Management program that results in the
    achievement of this policy.

    4\. Issues a Risk management program Reference Manual (RM-50C) to
    provide detailed information on specific implementation requirements
    and strategies for a public risk management program in the National
    Park Service.

    5\. Appoints and directly supervises the NPS Risk Management Program
    Manager (meeting OPM Standard GS-018/803). Provides adequate
    resources for the effective implementation and administration of the
    program.

    6\. Authorizes a Public Risk Management Council (a sub-council to
    the Risk Management Advisory Council) for the purpose of providing
    advice and assistance to the NPS Risk Management Council, NPS Risk
    Management Program Office and to the Service's Designated Agency
    Safety and Health Official (DASHO) on policy, programs, and concerns
    that are national in scope.

    7\. Authorizes an evaluation of regional public risk management
    programs at least every three years.

####### D. Program Manager, Risk Management  {#d.-program-manager-risk-management .unnumbered}

1.  Serves as a professional advisor/consultant to assist the Associate
    Director, Park Operations and Education, and the National Leadership
    Council in their development of Service-wide public risk management
    policy, direction, and goals.

2.  Coordinates periodic program review of public risk management
    programs, at least once every three years. Assists and advises
    regions and centers on the accomplishment of a safety program
    review.

3.  Provides professional public risk management program assistance, and
    manages resources in support of Service-wide policy and programs.

4.  Provides statistics to managers relating to public injuries and
    illnesses.

5.  Represents NPS public safety interests on the Department's Bureau
    Safety Manager's Council.

6.  Maintains a library of resources for public risk management,
    including examples of successful programs.

7.  Maintains this Director's Order and RM-50C to ensure that
    information is current.

8.  Conducts periodic review of regional Public Risk Management
    programs.

####### E. Regional Director {#e.-regional-director .unnumbered}

1.  Implements NPS Public Risk Management policies. Establishes clear
    goals, and develops work plans to facilitate the accomplishment of
    those goals. Holds operating unit managers accountable for
    implementing effective risk management programs.

2.  Designates a Regional Public Risk Management Program Coordinator.

3.  Directs park managers to establish and maintain an active public
    risk management program and to review program effectiveness at a
    minimum of every three years in accordance with program elements in
    this Director's Order and RM-50C.

4.  Recognizes and rewards public safety achievements.

    5\. Requires evaluation of regional Public Risk Management programs,
    at least once every three years.

    F. Regional Public Risk Management Coordinator

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1.  Serves as an advisor/consultant on Public Risk Management issues.

2.  Advises the regional director on the status of park Public Risk
    Management efforts. Evaluates park programs to determine
    progress/status at least once every three years, based on the risk
    management program elements in this Director's Order and RM-50C.

3.  Provides advice and consultation to individual field unit managers
    on mitigation strategies for public safety issues.

4.  Conducts periodic review of each park's Public Risk Management
    programs.

    G. Operating Unit Manager (Superintendent/Center/Unit/Office
    Manager)

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1.  Implements this Director's Order and RM-50C, including the
    development of work plans and implementation strategies.

2.  Exercises broad judgment and discretion to provide a safe and
    enjoyable park visit while achieving the mandate of the NPS Organic
    Act.

3.  Strive to minimize number and severity of visitor incidents.

4.  Develops, implements, and keeps current written, site-specific
    public risk management work plans.

5.  Annually conducts self-audits of public risk management program.
    Where risks are identified, ensures that they are communicated to
    the public using methods that will result in visitors' awareness of
    and knowledge needed to avoid injury, when encountering those risks.

6.  Obtains appropriate public risk management training for all
    personnel.

7.  Investigates all public safety incidents to identify causal factors
    and implement appropriate corrective actions to prevent recurrence.

8.  Establishes a Public Risk Management Program Coordinator to
    facilitate implementation of this Director's Order at the local
    level.

9.  Conducts a Technical Board of Investigation for all visitor
    fatalities using format in RM-50B

10. Requires that all public incidents be recorded using the NPS
    Incident Reporting System.

11. Establishes a system to reward Public Safety achievement.

12. Incorporates Public Risk Management elements in performance
    standards and competencies for employees at all levels of NPS
    individual operating units.

####### H. Operating Unit Public Risk Management Coordinator {#h.-operating-unit-public-risk-management-coordinator .unnumbered}

1.  Serves as a point of contact for Public Risk Management. Assists in
    the implementation of this Director's Order and RM 50-C.

2.  Ensures that an investigation of all serious visitor accidents is
    conducted and is accurately recorded in the NPS Incident Reporting
    System.

3.  Advises the site manager of all serious visitor accidents and
    incidents. May advise the Technical Board of Investigation on their
    responsibilities and authorities for accident investigation. (See
    Reference Manual 50B section on Investigative Responsibilities).

    **I. Tort Claims Officer**

    Notes patterns and assists park in developing ways to prevent future
    tort claims

    **J. Concession Management**

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1.  Ensures that concessioners comply with the requirements of the NPS
    Concession Risk Management Program. Each concessioner is to develop
    its own risk management program, which is reviewed and approved by
    the park superintendent. (Reference Director's Order #48.)

2.  Ensures that concessioners have an appropriate structural fire plan
    to ensure the protection of guests, employees, and assets.

3.  Ensures that concessioners work closely with NPS managers to address
    specific safety issues.

######### K. Every Employee

1.  Is alert to safety issues; notes, reports and mitigates visitor
    safety hazards as they are observed, and as appropriate and within
    their authority.

2.  If an employee who observes a safety hazard is unable to mitigate it
    personally, that employee must take responsibility for reporting the
    safety hazard to someone who can.

    \-\-\-\-\-\-\-\-\--*End of Director's Order\-\-\-\-\-\-\-\-\--*