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1
The National Perspective and Lessons Learned
Tennessee Bankers Association Disaster
Response/Contingency Planning Committee Barrett
Training Center, Nashville
Don Rhodes American Bankers Association
Jim Devlin Office of the Comptroller of the
Currency
2

Figuring out how the pieces fit together
090929
3
Florida Department of Health
WHAT KIND OF PROBLEMS CAN REGULAR HAND WASHING PREVENT? INFLUENZA (THE FLU) THE COMMON COLD STREP THROAT INTESTINAL DISORDERS, INCLUDING EVERYONES FAVORITE, DIARRHEA PNEUMONIA FOUL ODORS IN BUSINESS MEETINGS BLANK STARES FROM STUNNED CO-WORKERS DISTURBED FROWNS FROM CLIENTS
Every time you use the restroom Before meals After meals After handling garbage After handling any food After touching a pet After changing a diaper After blowing your nose (which we hope you did into a tissue) WHATS THE BEST WAY TO WASH MY HANDS? Use soap and warm water, and scrub every nook and cranny you can, rubbing your hands together for at least 15 seconds. Get in between your fingers, cover the entire palm, and wash all the way down to the wrist on both sides. Some people sing the song Happy Birthday to themselves to be sure they dont quit early. And try to avoid using your newly clean hands to touch the faucet or door knob. Use a paper towel if available. Many a "Fifth Guy" may have preceded you.  
http//www.5thguy.com/handwashing.htm
3
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4
National Perspective and Lessons Learned
  • Objective
  • Where We Are, How We Got There Where Were
    Going
  • Lessons Learned from 2007 Pandemic Flu Exercise
  • Lessons Learned from the Global H1N1 Response
  • Go To Information
  • Action Takeaways

090929
5
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6
World Health Organization Pandemic Influenza Facts
  • Avian influenza refers to influenza viruses that
    primarily affect birds. An influenza pandemic
    occurs when a new subtype emerges that infects
    humans and is spread efficiently from human to
    human.

Pandemic influenza is different from avian
influenza
  • Pandemic occurs when a new influenza virus
    subtype emerges and spreads as easily as normal
    influenza pandemic influenza has occurred three
    times in the last century.

Influenza pandemics are recurring events
  • Health experts have been monitoring a new and
    extremely severe avian influenza virus the H5N1
    strain for eight years should H5N1 evolve to a
    form as contagious as normal influenza, a
    pandemic could begin.

The world may be on the brink of another pandemic
All countries will be affected
  • Countries might delay arrival of the virus but
    cannot stop it given the speed and volume of
    international air travel today, the virus could
    spread more rapidly now than in previous
    pandemics.

Medical supplies will be inadequate
  • Developing a new vaccine will take several months
    and not be Supplies of vaccines will not be
    available ate the start of a pandemic because and
    for many months thereafter.
  • High rates of illness and worker absenteeism will
    contribute to social and economic disruption.
    Rates of absenteeism will depend on the severity
    of the pandemic.

Economic and social disruption will be great
Source Ten things you need to know about
pandemic influenza, The World Health
Organization, October 14, 2005,
http//www.who.int/csr/disease/influenza/pandemic1
0things/en/index.html
7
WHO Pandemic Influenza Facts (continued)
  • The reported symptoms have ranged from typical
    influenza-like symptoms (e.g. fever, cough, sore
    throat, and muscle aches) to eye infections
    (conjunctivitis), acute respiratory distress,
    viral pneumonia and other severe,
    life-threatening complications.

Avian Flu Symptoms
Typical Incubation Period
  • The typical incubation period (interval between
    infection and onset of symptoms) for influenza is
    approximately 2 days.

Medical Care
  • Of those who become ill with influenza, 50 will
    seek outpatient medical care.
  • In an affected community, a pandemic outbreak (or
    wave) will last about 6 to 8 weeks.

Pandemic Waves
  • Multiple waves of illness could occur with each
    wave lasting 2-3 months. Historically, the
    largest waves have occurred in the fall and
    winter, but the seasonality of a pandemic cannot
    be predicted with certainty.

Antivirals
  • Research suggests that two antiviral medicines,
    oseltamavir (Tamiflu) and zanamavir (Relenza),
    may be useful treatments for H5N1 avian influenza.

Source Ten things you need to know about
pandemic influenza, The World Health
Organization, October 14, 2005,
http//www.who.int/csr/disease/influenza/pandemic1
0things/en/index.html
8
Likely Severity of a Modern Pandemic Influenza
20th Century Pandemic Deaths 20th Century Pandemic Deaths
1918-1919 1918-1919
US 675,000
Worldwide 50,000,000
1957-1958 1957-1958
U.S. 70,000
Worldwide 1-2,000,000
1968-1969 1968-1969
U.S. 34,000
Worldwide 700,000
  • Three human influenza pandemics occurred in the
    20th century
  • 30 of the world population infected
  • Death in 0.2 - 2 of those infected
  • The world has changed since previous flu
    pandemics
  • The world is now more densely populated
  • A larger proportion of the population is elderly
    or has compromised immune systems
  • There are greater interconnections among
    countries and continentsfaster air travel and
    just-in-time inventory systems
  • Experts predict that a modern pandemic could lead
    to the deaths of 200,000 to 2 million people in
    the United States alone
  • The Congressional Budget Office estimates that
    U.S. GDP will decline 1-4.25 in a pandemic, but
    snap back once the pandemic ends as consumers
    increase spending and business increases
    production to meet pent-up demand

090929
Source Implementation Plan Briefing Book,
Homeland Security Council, May 2006,
http//www.whitehouse.gov/homeland/nspi_implementa
tion_briefing.pdf A Potential Influenza
Pandemic Possible Macroeconomic Effects and
Policy Issues, Congressional Budget Office,
updated May 22, 2006, https//cbo.gov A
Potential Influenza Pandemic An Update on
Possible Macroeconomic Effects and Policy
Issues, Congressional Budget Office, revised
July 27, 2006
9
Annual Impact of Regular Influenza
  • gt 36,000 deaths annually
  • gt 225,000 excess hospitalizations nationwide
  • Highest rates of hospitalization among young
    children and persons gt65 years of age
  • 90 of these deaths among persons gt65yrs
  • Annual vaccination is critical!



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10
Annual vs. Pandemic Flu
  • Pandemic
  • 3 times/century
  • 1918 50-100 million deaths
  • At risk population may enlarge (1918)
  • Vaccination not available at outset
  • Novel strain (shift)
  • Annual
  • Every winter
  • 500k-1 million deaths
  • Deaths in at risk
  • populations
  • Vaccination available
  • and effective
  • Variant strain (drift)

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11
Influenza A Virus
090929
12
Emergence of New Human Influenza Subtypes
Two Methods
Not Significant Happens Every Year
090929
13
Emergence of New Human Influenza Subtypes
Possible Pandemic Source
090929
14
INFLUENZA VIRUS CROSS INFECTIONS
Animal -to-Animal
Bird -to-Bird
Bird-to-Animal
Pigs -to-People
People -to-Pigs
Bird-to-People
Person-to-Person
15
Confirmed Human Cases of H5N1 Reported to the WHO
as of 31 August 2009
Cumulative fatality rate 262 deaths / 440
reported cases  59.5 2009 fatality rate 12
deaths / 45 reported cases  26
Country   2003 2003 2004 2004 2005 2005 2006 2006 2007 2007 2008 2008 2009 2009 Total Total
Country   cases deaths cases deaths cases deaths cases deaths cases deaths cases deaths cases deaths cases deaths
China 1 1 0 0 8 5 13 8 5 3 4 4 7 4 38 25
Egypt 0 0 0 0 0 0 18 10 25 9 8 4 34 4 85 27
Indonesia  0 0 0 0 20 13 55 45 42 37 24 20 0 0 141 115
Viet Nam 3 3 29 20 61 19 0 0 8 5 6 5 4 4 111 56
All Others 0 0 17 12 9 6 29 16 8 5 2 0 0 0 65 39
Total 4 4 46 32 98 43 115 79 88 59 44 33 45 12 440 262
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16
US Pandemic Preparedness Plans

www.pandemicflu.gov
090929
17
US Pandemic Preparedness Plans
  • Surveillance
  • Diagnostics
  • Healthcare Planning
  • Infection Control
  • Clinical Guidelines
  • Vaccine Distribution and Use
  • Antiviral Drug Distribution and Use
  • Community Disease Control and Prevention
  • Surveillance
  • Managing Travel-Related Risk of Disease Xmission
  • Public Health Communication
  • Workforce Support Psychosocial Considerations
    and Information Needs

www.pandemicflu.gov
090929
18
Planning Checklistswww.pandemicflu.gov
090929
19
Regulatory Guidance
http//www.ffiec.gov/ffiecinfobase/index.html
  • FDIC, FRB, NCUA, OCC, OTS
  • FFIEC IT Examination Handbook - 12 Booklets in
    Series
  • Guidance and Examination Procedures
  • Audit
  • Business Continuity Planning
  • Development and Acquisition
  • E-Banking
  • Fed Line
  • Information Security
  • Management
  • Operations
  • Outsourcing Technology Services
  • Retail Payment Systems
  • Supervision of TSPs
  • Wholesale Payment Systems


090929
20
Regulatory Guidance
  • Pandemic Planning - BCP Booklet, Appendix D
  • Identical to FFIEC December 2007 Guidance
  • Five critical elements that each plan should
    address
  • Preventive program
  • Documented response strategy
  • Comprehensive framework to continue critical
    operations
  • Testing program
  • Oversight program

090929
21
Regulatory Guidance
  • Pandemic Planning - BCP Booklet, Appendix D
  • Differences Between Traditional BCP and Pandemic
    Planning
  • Scale, duration, absenteeism
  • Board and Senior Management Responsibilities
  • Incorporating Pandemic Planning into the BIA
  • Risk Assessment / Risk Management
  • Coordination with Outside Parties
  • Identification of Triggering Events
  • Employee Protection Strategies
  • Mitigating Controls
  • Remote Access
  • Risk Monitoring and Testing

090929
22
H1N1 Virus
090929
23
WHO / USG Levels at Outbreak
No or Limited Human Cases
Increased and Sustained Transmission in General
Population
Low Risk of Human Cases
Increased Human to Human
Significant Human to Human
Inter-Pandemic Period
Pandemic Period
Pandemic Alert Period
1
5
6
2
3
4
UN WHO Periods Phases (Virus Focus)
1
2
3
4
5
6
0
Federal Government Response Stages (Geographical
Focus)
Human overseas
Animal overseas
Human North America
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24
Mid-Outbreak WHO Phase Change
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25
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26
Periods, Phases, Stages, and Intervals
090929
27
Gartner-like Magic Quadrant?
S E V E R I T Y
       
     
     
       
     
     
     
       
GEOGRAPHIC SPREAD
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WHO Conceptual Guidance
090929
29
Laboratory Confirmed Cases of H1N1 Reported to
WHO as of 30 August 2009
Cumulative fatality rate 2,837 deaths / 254,206
reported cases  1.11 Cumulative fatality rate
from prior reports 1.04... 0.98 0.82
Region Cumulative total Cumulative total
Region as of 30 Aug 2009 as of 30 Aug 2009
  Cases Deaths
WHO Regional Office for Africa (AFRO) 3872 11
WHO Regional Office for the Americas (AMRO) 116046 2234
WHO Regional Office for the Eastern Mediterranean (EMRO) 5031 21
WHO Regional Office for Europe (EURO) Over 46000 At least 104
WHO Regional Office for South-East Asia (SEARO) 19362 188
WHO Regional Office for the Western Pacific (WPRO) 63895 279
Total Over 254206 At least 2837
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30
H5N1 (Bird Flu) versus H1N1 (Swine Flu) (WHO
data as of 30 August 2009)
H5N1 (Bird Flu) H1N1 (Swine Flu)
Time Period 6 YEARS (Feb 2003 August 2009) 24 WEEKS (18 March 30 August 2009)
Confirmed Human Cases 440 254, 206
Human Case Mortality 262 (60) 2,837 (1 )
Number of Countries 15 Most
31
Reported Cases Tip of the Iceberg (DCHSEMA)
REPORTED INFLUENZA
Sensitivity of test
Specimen tested for influenza
Specimen collected
Sought care for illness
TOTAL NUMBER INFECTED WITH INFLUENZA
090929
32
Recent H1N1 Federal Guidance
  • DHS National Framework for 2009-H1N1 Influenza
    Preparedness and Response
  • Surveillance - Mitigation Measures Vaccination
    - Communication and Education
  • Updated Guidance for Businesses and Employers for
    the Fall Flu Season (Aug 09)
  • Offer businesses and employers a range of options
    for responding to 2009 H1N1 influenza, depending
    on how severe the flu may be in their
    communities.
  • Preparing for the Flu A Communication Toolkit
    for Businesses and Employers
  • Provides information and communication resources
    to help businesses and employers implement
    recommendations from CDCs Guidance for
    Businesses and Employers.
  • Preparedness Guide for Small Business Announced
    (Sep 09)
  • Department of Homeland Security Secretary Janet
    Napolitano joined Small Business Administration
    (SBA) Administrator Karen Mills and Centers for
    Disease Control and Prevention Influenza Division
    Deputy Director Daniel Jernigan to announce a
    preparedness guide to assist small businesses in
    planning for the H1N1 flu.

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33
Teens and Young Adults Disproportionately
Affected (DCHSEMA)
While this pattern falls more heavily on the
young, working parents must stay home to care for
sick children
Seasonal 2007-08
2009 H1N1 (April - Jun)
April 12-June 30
N3,930
N312
Emerging Infections Program
33
090929
34
Even Mild Flu Can Result in Extended Absenteeism
(DCHSEMA)
Notional cycle of infection within a family
demonstrates potential for missed work and lost
productivity
week 1
week 2
week 3
Can be infected 1 day before symptoms
Must have no fever for 24 hours to return to
school
child infected
No fever for 24 hours to return to work
Children contagious up to 10 days after being
infected
parent infected
parent stays home
No fever for 24 hours to return to work
adults contagious up to 5-7 days after being
infected
parent infected
parent stays home
34
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35
DC HSEMA Pandemic Response States
District agencies will employ three levels of
response.Response level changes will be based on
pandemic severity and outbreak phase
Pre-pandemic Steady State Agency should
maintain the pandemic readiness of its plans and
capabilities
Preparedness
Imminent Arrival of Effects on Agency from
Pandemic Agency should initiate crisis measures
in anticipation of imminent arrival of pandemic
challenges
Alert
Pandemic Stress on Agency The Agency is
experiencing the full effects of a pandemic.
Agency should maintain sustainable crisis
measures. Crisis measures in this case are those
steps adopted to keep the Agency functioning
under periods of high demand and high operational
stress
Crisis Management
090929
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National Perspective and Lessons Learned
  • Objective
  • Where We Are, How We Got There Where Were
    Going
  • Lessons Learned from 2007 Pandemic Flu Exercise
  • Lessons Learned from the Global H1N1 Response
  • Go To Information
  • Action Takeaways

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37
Federal Financial Services Sector
PUBLIC SECTOR
PRIVATE SECTOR
US Treasury Deputy Assistant Secretary,
CIP, FBIIC CHAIR
SECTOR COORDINATOR
Financial and Banking Information Infrastructure
Committee (FBIIC) US Treasury Department Commodit
y Futures Trading Commission Conference of State
Bank Supervisors Farm Credit Administration Federa
l Deposit Insurance Corporation Federal Housing
Finance Board Federal Reserve Board of
Governors Homeland Security Council National
Association of Insurance Commissioners National
Association of Credit Union Supervisors National
Credit Union Administration North American
Securities Administrators Association New York
Federal Reserve Bank Office of the Comptroller of
the Currency Office of Federal Housing Enterprise
Oversight Office of Thrift Supervision Securities
and Exchange Commission Securities Investor
Protection Corporation
Financial Services Sector Coordinating Council
for CIP/HLS, LLC (FSSCC) Credit Union National
Association Financial Services Trade Associations
Institutes Depository Trust Clearing
Corporation New York Stock Exchange ChicagoFIRST T
he Clearinghouse FS/ISAC Securities Industry
Automation Corporation The Options Clearing
Corporation VISA USA Fannie Mae NASDAQ AMEX
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Federal Financial Services SectorRegional
Coalitions
  • Filling the Gap
  • Local/Regional Partnerships to increase the
    resilience of financial services in the event of
    a regional disaster in collaboration with the
    city, state, and federal agencies.

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2700 Participants
January 30, 2008
Lessons Learned from the FBIIC/FSSCC Pandemic Flu
Exercise of 2007
http//www.fspanfluexercise.com/
081211
40
Telecommuting
  • While many organizations included telecommuting
    as part of their plans for social distancing,
    relatively few employees telecommuted during the
    exercise.
  • At the height of the pandemic, one-third of large
    organizations reported that 26-50 percent of
    their employees telecommuted
  • One-third of medium and nearly two-thirds of
    small organizations reported that less than 10
    percent of their available employees
    telecommuted.

41
Human Resources Management Personal Protective
Equipment (PPE)
42
Key themes raised
  • ATM operations
  • Branch operations
  • Providing relief to customers
  • Mutual aid arrangements
  • Regulatory relief

43
ATM Operations
  • Analyzed factors associated with maintaining
    operation of complex ATM networks
  • ATM operators manage their complex networks in
    various ways most ATM networks are dependant
    upon third-party service providers to
  • Replenish cash
  • Remediate physical machine problems
  • Maintain connectivity
  • Banking participants responses confirmed the
    subsectors recognized reliance on third-party
    service providers

44
Branch Operations
  • High absenteeism rates and changes in work
    assignments that result from facility closings
    will pose challenges to banks abilities to meet
    their customers needs
  • Responses indicated an understanding of the need
    to adjust their facilities availability and
    operational procedures
  • To address handling face-to-face encounters with
    customers during the height of the pandemic,
    respondents noted that they would
  • Reduce operating hours
  • Provide only drive through services

45
Branch Closings
46
Providing Relief to Customers
  • Participants were asked what type of relief they
    anticipate providing customers during a pandemic
  • During weeks 3 12 of a simulated 12 week
    pandemic wave saw a substantial percentage of
    participants of all sizes providing relief in one
    or more categories of consumer debt or mortgage
    loans
  • A significant percentage of respondents reported
    that an increase in customer late payments was
    expected to have a material impact on funding
    liquidity
  • Addressed by using lines of credits
  • A fair percentage of respondents had no plans to
    address these funding liquidity needs

47
Regulatory Relief
  • The exercise provided helpful input into the
    types of regulatory relief that banking
    participants might seek at various stages of a
    pandemic
  • Extension or waiver of regulatory reporting
    requirements, Bank Secrecy Act / anti-money
    laundering and USA PATRIOT Act requirements
  • Postponement of examination and audits
  • Extension of time to comply with consumer-related
    regulations
  • Relaxation of branch closure / relocation notice
    requirements
  • Easing of reserve and liquidity requirements and
    relief from prompt corrective action and capital
    rules
  • Relief from Sarbanes-Oxley (SOX) internal
    controls requirements
  • Relaxation of internal policies and procedures

48
Considerations and Next Steps
  • Requests for relief point to
  • Potential value in the private sector opening a
    dialogue with the supervisory community to
    discuss identified concerns with regard to
    regulations
  • Regulated institutions, through their trade
    associations, formulating possible alternative
    mechanisms that would provide appropriate
    assurances to supervisors while allowing for
    flexibility to regulated institutions
  • Next Steps
  • Assess adequacy of third-party providers plans
  • Review plans for reducing face-to-face
    encounters, modifying operating hours and
    redeploying staff to provide customer service
  • Assess cross-training plans including existing
    delegation and back-up assignments to ensure
    their effectiveness

49
Assets
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50
General Finding Continuity of Operation
It appears that while there will be significant
impacts to the financial services sector, the
sector overall will continue to cope and operate.
081211
51
Exercise Framework for the Banking Subsector
  • Banking participants were confronted with
    situations designed to directly affect their
    organization
  • Customer social-distancing behaviors
  • Online Banking trends
  • Call Center demands
  • Functionality of Automated Teller Machines
  • Issues focused on
  • exploring the dependencies on other critical
    infrastructures
  • enhancing the understanding of systemic risks
    facing the subsector
  • exploring types of regulatory relief

081211
52
Considerations and Next Steps
  • Requests for relief point to
  • Potential value in the private sector opening a
    dialogue with the supervisory community to
    discuss identified concerns with regard to
    regulations
  • Regulated institutions, through their trade
    associations, formulating possible alternative
    mechanisms that would provide appropriate
    assurances to supervisors while allowing for
    flexibility to regulated institutions
  • Next Steps
  • Assess adequacy of third-party providers plans
  • Review plans for reducing face-to-face
    encounters, modifying operating hours and
    redeploying staff to provide customer service
  • Assess cross-training plans including existing
    delegation and back-up assignments to ensure
    their effectiveness

081211
53
FFIEC / ABA - Roundtable on Pandemic Planning
  • Held at FDIC Seidman Center on January 30, 2008
  • Panels Presented
  • Lessons Learned from the FBIIC/FSSCC Pandemic Flu
    Exercise
  • Impact of a Pandemic on Telecommunications and
    the Internet
  • Human Resources Planning
  • Testing Pandemic Plans
  • Regulatory Relief Expectations - Industry
  • Regulatory Relief Expectations FFIEC
  • Materials available at
  • http//www.aba.com/Solutions/2008RoundtableonPa
    ndemicPlanning.htm

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54
Follow-Up - Roundtable on Pandemic Planning
  • Focused on Banking Sector Regulatory Relief
  • Initial Meeting - March 26, 2008
  • Regulatory Relief vs. Regulatory Clarity
  • Public Sector Regulatory Relief Abilities
  • Private Sector Regulatory Relief Expectations
  • Agreement on Action / Follow-Up Items
  • Discussion of FFIEC Agency Pandemic Plans
  • Development of Prioritized list of Anticipated
    Regulatory Relief needs
  • Consideration of the Issuance of an FFIEC
    document based on existing OTS and FFIEC documents

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Pandemic Preparedness PlanningSystemic Banking
Organizations
1. Governance Oversight 2. Preventative
Program 3. Documented Strategy 4. Comprehensive
Framework 5. Testing Program 6. Training
Awareness
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  • Conclusions
  • Strengths
  • Observations for consideration
  • Key Performance Indicators
  • Governance Oversight
  • Preventative Program
  • Documented Strategy
  • Comprehensive Framework
  • Testing Program
  • Training Awareness

KPI range of 7.7 to 9.3
KPI range of 8.6 to 9.4
KPI range of 7.6 to 8.8
KPI range of 8.1 to 9.8
KPI range of 6.8 to 10
KPI range of 6.7 to 10
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57
  • Firms recognized and continue to enhance crisis
    management communication and notification systems
  • Firms have embraced multi-dimensional frameworks
    to support sustainable Crisis Management
  • Firms are requiring business units and shared
    services to identify secondary and tertiary
    vendors whenever possible

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  • Firms are training business line management to
    understand absenteeism policies so as to better
    serve employees needs during a pandemic event
  • Firms are designating and cross training primary
    and secondary personnel for key leadership and
    critical functional positions
  • Firms are relying on combinations of recovery
    sites and internal networks to ensure
    availability of people and technology
  • Firms are maintaining inventories of key staff
    and skill sets

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59
  • Firms have folded pandemic preparedness testing
    scenarios into their BCP testing programs (Crisis
    management testing also has incorporated pandemic
    scenarios)
  • Firms better understand the value and usefulness
    of aligning their plans with federal, state and
    local agencies
  • Firms are integrating support systems (industry
    forums, communication networks, vendor workshops)
    and shared best practices into their programs

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National Perspective and Lessons Learned
  • Objective
  • Where We Are, How We Got There Where Were
    Going
  • Lessons Learned from 2007 Pandemic Flu Exercise
  • Lessons Learned from the Global H1N1 Response
  • Go To Information
  • Action Takeaways

090929
61
Video
62
H1N1 Lessons Learned in Spring 09
  • 'Worried well' overload gives taste of pandemic
    scenario
  • The Flu Had Everyone Worried That Could Be a
    Good Thing
  • Even if the swine flu outbreak doesn't get more
    serious, this Springs events have been a
    worthwhile exercise to test preparedness 
  • Vaccine makers catching up
  • H1N1 Influenza Vaccine Available November 2009 
  • Avian flu research has swine flu outbreak
    applications

62
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63
H1N1 Lessons Learned
  • 1. What is the general anxiety level of the
    sector?
  • 2. What gaps is the sector perceiving?
  • 3. What information needs are currently existing
    that are not being filled?
  • 4. What activities are the institutions in the
    sector currently engaged in?
  • 5. Operational, Economic Impacts?

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H1N1 Lessons Learned
The Outbreak was followed by Multiple
Lessons-Learned Activities in the United States
and Around the World and Common Themes Emerged
General Conclusions The swine flu outbreak
presented a unique opportunity for the industry
and the Government and to test their pandemic
plans and preparations both internally and
externally. Most organizations believe that the
Pandemic Plans and policies they have in place
are accurate and that they took the right course
of action to deal with the outbreak from the
onset. Most did not need to fully execute the
plans but used them as reference tools to deal
with the H1N1 outbreak.
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H1N1 Lessons Learned
Some of the more common steps taken Limit or
eliminate travel to Mexico - employees asked to
delay business travel. If the employee could
not delay the trip, the company asked them to
work from home (if possible) for 7-10 days
(incubation period of the virus). Employees
that took personal trips we asked to do the same.
Parents of sick children were asked to stay
home for the day. FIs with offices in Mexico
went to half staff.
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H1N1 Lessons Learned
Some of the more common steps taken Set up
preventative measures to deal with symptomatic
employees in the office nurses on site
isolation areas for symptomatic employees.
symptomatic employees were asked to go to the
hospital or to their personal doctor employees
could not return to work until a doctor released
him/he with a note. Organizations were proactive
in their efforts to limit the spread of the virus
internally handed out sanitizing wipes and/or
personal hand sanitizer automatic hand sanitizer
dispensers were put into public areas Cleaning
of office space and retail locations was
revamped some increased the number and quality
of cleanings workspaces of symptomatic employees
were immediately cleaned mask were
pre-distributed at some organizations.
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H1N1 Lessons Learned
Some of the more significant specific learnings
identified Main lesson identified - the need for
flexibility to provide a range of options rather
than prescriptive measures tied to a particular
phase. Outbreak spotlighted how crisis managers
often need to work with possibly inaccurate
information Also, made it clear that health
resources are not limitless. The outbreak
provided an insight into how long a containment
strategy can be maintained Finally, feedback led
to the realization of how much staff relies on
employers as a credible source of info, and the
need for employers to supply that information.
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H1N1 Lessons Learned
Concerns / Issues for follow-up Need for more
consistent trending information based on
mortality, rate of occurrence, specific geography
involved Need for information about prior
government use of quarantines and the effect on
the targeted area business. Better
understanding of the impact on supply
replenishment - especially liquid fuels. Need to
review timeliness and pro-activeness of
communications One key concern emerged need for
a better understanding of the ability of key
suppliers and outsource operators to continue to
meet SLAs
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Pandemic Flu Lessons From the FrontlinesJune
2009
  • Sick leave and policies for limiting mass
    gathering were problematic
  • Sick individuals went to work and sent sick kids
    to school because they lacked sick
    leave/childcare and feared losing their jobs
  • School closings have major ramifications for
    students, parents, and employers
  • Providing clear, straightforward information was
    essential for allaying fears and building trust
  • Employ existing channels
  • Clear and concise messages are most effective
  • Response plans must be adaptable and
    science-driven
  • New strains can emerge more quickly and less
    severe than anticipated

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Pandemic Flu Preparedness LESSONS FROM THE
FRONTLINES
1. Investments in pandemic planning and
stockpiling antiviral medications paid off 2.
Public health departments did not have enough
resources to carry out plans 3. Response plans
must be adaptable and science-driven 4.
Providing clear, straightforward information to
the public was essential for allaying fears and
building trust 5. School closings have major
ramifications for students, parents, and
employers 6. Sick leave and policies for
limiting mass gatherings were also
problematic 7. Even with a mild outbreak, the
health care delivery system was overwhelmed 8.
Communication between the public health system
and health providers was not well coordinated 9.
WHO pandemic alert phases caused confusion
and 10. International coordination was more
complicated than expected.
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PANDEMIC INFLUENZA IS THERE A CORPORATE DUTY TO
PREPARE?
  • This article considers whether in the wake of an
    influenza pandemic companies may be exposed to
    claims of legal liability for failing to provide
    employees with access to antiviral medications,
    as the Department of Health and Human Services
    (HHS) now encourages businesses to do.
  • It concludes by considering whether claims may be
    brought on the theory that corporate leadership
    is under a duty to prepare for a pandemic by
    considering whether to provide access to
    antiviral protection for employees.

Authored by J.P. McMenamin and colleagues,
McGuireWoods LLP Food and Drug Law Journal 69-100
(2009). Sourcehttp//www.fdli.org/pubs/Journal20
Online/jour_toc/vol64_1.html
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National Perspective and Lessons Learned
  • Objective
  • Where We Are, How We Got There Where Were
    Going
  • Lessons Learned from 2007 Pandemic Flu Exercise
  • Lessons Learned from the Global H1N1 Response
  • Go To Information
  • Action Takeaways

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Resources
  • Additional tools and guidance documents have been
    developed by the federal government to assist
    employers in their planning. These resources are
    available online at www.flu.gov/plan/workplacepla
    nning/index.html.
  • One-Stopwww.flu.gov
  • 2009 H1N1 Influenza Informationhttp//www.cdc.gov
    /h1n1flu/
  • 2009 H1N1 Influenza Resources for Businesses and
    Employershttp//www.cdc.gov/h1n1flu/business/
  • Worker Safety and Health Guidance for a
    Pandemicwww.osha.gov/dsg/topics/pandemicflu/index
    .html
  • OSHAs Guidance on Preparing Workplaces for an
    Influenza Pandemichttp//www.osha.gov/Publication
    s/influenza_pandemic.html
  • CDC/NIOSH Occupational Health Issues Associated
    with 2009 H1N1 Influenza Virus http//www.cdc.gov/
    niosh/topics/h1n1flu/

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ABA Emergency Preparedness Toolbox
  • Pandemics Have Different Characteristics Than
    Other Disasters
  • Checklist of Issues to Consider
  • Business Continuity
  • Communication and Education
  • Employee Health and Safety
  • Administrative and Legal

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Pandemic Planning in the News
Subject 090913- Pandemic Planning in the News
  • News from the World Health Organization (WHO)
  • H5N1 - Confirmed Human Cases of H5N1 Influenza
    Reported to the WHO as of 31 August 2009
  • Cumulative fatality rate 262 deaths / 440
    reported cases  59.5
  • H1N1 - International Situation Update 65 Weekly
    Update (11 September 2009)
  • Cumulative fatality rate 3,205 deaths / 277,607
    reported cases  1.15 - current report
  • Cumulative fatality rate from prior
    reports 1.11... 1.04... 0.98 0.82 0.71
  • WHO Issues Advice on Measures in School Settings
    - Pandemic (H1N1) 2009 briefing note 10
  • News from DHS / HHS / CDC et al
  • Interim Guidance for State and Local Health
    Departments for Reporting Influenza-Associated
    Hospitalizations and Deaths for the 2009-2010
    Season
  • New System (2009-10 Flu Season) U.S. Influenza
    and Pneumonia-Associated Hospitalizations and
    Deaths 1,380 hospitalizations and 196 deaths
    August 30 September 5, 2009
  • Prior System (2008-09 Flu Season) U.S. 2009
    H1N1 Flu Hospitalizations and Deaths 9,079
    hospitalizations and 593 deaths .. April
    August
  • Statement by Dr. Anthony Fauci, Director,
    National Institute of Allergy and Infections
    Diseases, NIH, Regarding Early Results from
    Clinical Trials of 2009 H1N1 Vaccines in Healthy
    Adults
  • Updated Interim Recommendations for the Use of
    Antiviral Medications in the Treatment and
    Prevention of Influenza for the 2009-2010 Season
  • Statement Agriculture Secretary Regarding Animal
    Health and 2009 Pandemic H1N1 Influenza
  • Other Noteworthy News Items
  • Vaccine Supply May Miss Swine Flu Peak
  • U.S. Urges Getting Regular Flu Shot
  • During the H1N1 pandemic, please allow sick
    workers to stay home Lisa Koonin, Senior Advisor
    of the Influenza Coordination Unit at the CDC
  • Study Most firms are ill-prepared for H1N1 flu
  • Australia Swine flu indemnity crisis averted
  • Roche Sees Few Cases of Tamiflu-Resistant Swine
    Flu

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National Perspective and Lessons Learned
  • Objective
  • Where We Are, How We Got There Where Were
    Going
  • Lessons Learned from 2007 Pandemic Flu Exercise
  • Lessons Learned from the Global H1N1 Response
  • Go To Information
  • Action Takeaways

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Objectives
  1. Reduce transmission among staff
  2. Protecting people at increased risk
  3. Maintaining business operations
  4. Minimizing adverse effects on other entities in
    your supply chain

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Recommendations
  • Understand your normal seasonal absenteeism rates
  • Assess essential business functions
  • All sick should stay home
  • Hand washing, covering coughs sneezes should be
    encouraged
  • Routine cleaning of commonly touched surfaces
  • If severity increases
  • Social distancing
  • Prepare for both scenarios as planning framework
  • Be flexible

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Recommendations
  • Work with State and Local Public Health Partners
  • Intensity may differ according to geographic
    location
  • Local public health officials will issue guidance
  • Keep Sick Workers Home
  • No planning differences between seasonal flu and
    H1N1 flu
  • Staff with flu-like illness should stay home
    not come to work for 24 hrs after fever resolved
  • Some do not develop fever. Will be impossible to
    exclude everyone who gets ill from the workplace.

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Recommendations
  • Be prepared if schools dismiss students or child
    care programs
  • Especially if severity increases
  • Plan now to determine how you will operate if
    absenteeism spikes due to sick workers, those who
    stay home to care for ill family members, or to
    care for children at home.
  • Businesses must institute flexible workplace and
    leave policies

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Components of an Influenza Pandemic Plan
  • Identify possible work-related exposure and
    health risks to your employees. OSHA tools to
    determine if your employees are at risk of
    work-related exposures and if so, how to respond.
  • www.osha.gov/dsg/topics/pandemicflu/index.html
  • Review human resources policies
  • Consistent with public health recommendations,
    state, federal workplace laws.
  • Department of Labor/EEOC
  • www.dol.gov
  • www.eeoc.gov
  • Explore whether you can utilize telecommuting
    and/or flexible work hours (staggered
    shifts/reduce operating hours
  • Social distancing steps Drive thru only?

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Components of an Influenza Pandemic Plan
  • Identify essential business functions, essential
    jobs or roles, critical elements within supply
    chain.
  • Suppliers
  • Contracted services (Core processing, online
    banking, mobile banking, check processing, IT)
  • Set up authorities, triggers, procedures to
    activate / terminate response plan, altering
    business operations (consolidating branch
    operations, adjusting staffing)
  • Plan to minimize staff exposure if public health
    calls for social distancing
  • Drive up
  • Burglar barrier equipped branches
  • Relief to Customers?
  • Late payments

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Components of an Influenza Pandemic Plan
  • Recommended Employer responses under current flu
    conditions (similar in severity to Spring/Summer
    09)
  • Sick persons should stay home
  • Sick employees at work should be asked to go home
    (HR implications)
  • If employee becomes ill at work, inform employees
    of possible exposure to flu-like illness, but
    maintain confidentiality as required by Americans
    with Disabilities Act (ADA).
  • http//www.flu.gov/faq/workplace_questions/equal_e
    mployment/index.htmlPrivacyIssues
  • Cover coughs and sneezes
  • Improve hand hygiene
  • Alcohol based hand sanitizers
  • Clean surfaces and items that are likely to have
    frequent hand contact
  • Encourage employees to get vaccinated

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Components of an Influenza Pandemic Plan
  • Take measures to protect employees who are at
    higher risk for complications of influenza
  • Pregnant women
  • Children under 5 yrs of age
  • Those with chronic lung disease (asthma), heart
    disease, diabetes, diseases that suppress the
    immune system and other chronic medical
    conditions
  • Those who are 65 and older
  • Prepare for increased absences due to illness in
    employees and their family members and plan for
    essential business functions to continue.
  • Cross train
  • Prioritize functions and business operations
  • Advise employees before traveling to take certain
    steps
  • Precautions
  • CDC Travel Website http//wwwn.cdc.gov/travel/con
    tent/novel-h1n1-flu.aspx)

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Components of an Influenza Pandemic Plan
  • Under conditions with Increased Severity Compared
    to Spring/Summer 09
  • Consider active screening of employees who report
    to work
  • CDC recommends persons stay at home for at least
    7 days
  • Flexible sick leave policies, consistent with
    public health guidelines
  • Consider social distancing, canceling
    non-essential travel.
  • Prepare for school dismissal or closure of child
    care

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Internal and External Communications
  • Need for internal staff communications
  • Reinforce hygiene and health best practices
  • Need for external customer communications
  • Need to coordinate with local emergency
    organizations and other financial institutions
  • Regional Coalitions (www.rpcfirst.org)
  • NCR First (National Capitol Region, DC, MD, VA)
  • FS-ISAC (www.fsisac.com )

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Other Considerations
  • Antivirals -HHS guidelines
  • Considerations for Antiviral Drug Stockpiling by
    Employers in Preparation for an Influenza
    Pandemic http//www.flu.gov/vaccine/antiviral_empl
    oyers.html
  • See updated interim guidance on the use of
    antiviral agents for treatment and prophylaxis of
    2009 H1N1 influenza infection at
    http//www.cdc.gov/h1n1flu/recommendations.htm.
  • Regulatory Compliance Issues (FFIEC)

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Actions to Take Now
  • Review or establish your plan
  • Conduct a focused discussion or exercise using
    your plan
  • Understand normal seasonal flu absenteeism rate
  • Engage State and Local health departments
  • Allow sick workers to stay home without fear of
    losing their jobs
  • Develop flexible leave policies
  • Share flu plan with employees
  • Share best practices with other businesses in
    your community (especially in your supply chain)
  • Add a widget or button to your Web page or
    employee Web site to access latest info on
    influenza
  • www.cdc.gov/widgets/
  • www.cdc.gov/SocialMedia/Campaigns/H1N1/buttons.htm
    l

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90
Federal Pandemic Planning Efforts For the
Financial Sector
Thank You !
Don Rhodes Director, Risk Management
Policy American Bankers Association (202)
663-7513 DRhodes_at_aba.com
Jim Devlin Special Advisor for Operational
Risk Office of the Comptroller of the Currency
(202) 874-5013 / (202) 359-6590
(cell) Jim.Devlin_at_occ.treas.gov
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