jurisdiction: US

text: b'July 23, 2008\n\nJO ANN FEINDT\nVICE PRESIDENT, GREAT LAKES AREA OPERATIONS\n\nALEXANDER E. LAZAROFF\nCHIEF POSTAL INSPECTOR\n\nSUBJECT: Audit Report \xe2\x80\x93 Postal Service Continuity of Operations\n for the Great Lakes Area (Report Number SA-AR-08-009)\n\nThis report presents the results of our audit of the Postal Service Continuity of\nOperations (COOP) for the Great Lakes Area (Project Number 08YG013SA000). Our\nobjective was to determine whether the Postal Service has a viable COOP capability to\nensure the performance of its essential functions during any emergency that may\ndisrupt normal operations. We conducted this self-initiated audit because emergency\npreparedness (EP) is a critical area for the Postal Service. Click here to go to Appendix\nA for additional information about this audit.\n\nConclusion\n\nWe determined management in the Great Lakes Area could enhance their COOP\ncapability to ensure they can effectively and efficiently continue essential functions\nduring emergencies that may disrupt normal operations. Based on our audit and the\nPostal Service\xe2\x80\x99s response to prior emergencies, we believe they have the capability to\ncontinue mail operations in an emergency. However, the Postal Service has not\nimplemented sufficient internal controls, and as a result, responsible officials are not\nfully prepared to effectively and efficiently continue essential functions during\nemergencies that require COOP activation. This could expose employees, mail, critical\nassets, and revenue to increased risk. Click here to go to Appendix B for our detailed\nanalysis of this topic.\n\nCompletion of Continuity of Operations Plans\n\nWe reviewed a sample of COOP plans1 for the Great Lakes Area and determined that\nresponsible area officials did not always establish and maintain area, district, and facility\nCOOP plans in accordance with federal and Postal Service guidance. In addition,\npersonnel with COOP-related responsibilities did not always update and maintain\nCOOP plans in the Postal Alert Notification System (PANS) to facilitate EP and\nresponse activities. For example:\n\n1\n The audit team requested COOP plans from 21 sites and received 19 COOP plans for review: one area plan, four\ndistrict plans, and 14 facility plans. Two facilities did not have a COOP plan.\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\xe2\x80\xa2 COOP plans were not always completed or updated annually, as required.\n\n\xe2\x80\xa2 The COOP plans we reviewed did not contain all pertinent information, such as\n essential functions, staffing needs, offload plans, and current contact information.\n\nThis occurred because Postal Service management did not establish sufficient internal\ncontrols and requirements to ensure COOP plans addressed federal and Postal Service\nguidance. Specifically, management did not ensure responsible personnel updated the\ncontact information of key COOP personnel annually or as needed, and did not\nestablish:\n\n\xe2\x80\xa2 Requirements for mandatory training for COOP personnel, including PANS training,\n to ensure COOP plans were properly completed and maintained.\n\n\xe2\x80\xa2 An internal review and approval process to ensure COOP plans were properly\n completed, updated annually, and maintained in PANS, as required.\n\n\xe2\x80\xa2 Guidance to identify and prioritize essential functions.\n\n\xe2\x80\xa2 An emergency management coordinating committee (EMCC)2 at the area level to\n provide oversight to districts and facilities, as required.\n\nWe recommend the Chief Postal Inspector establish requirements for personnel\nresponsible for continuity of operations to:\n\n1. Update contact information of key continuity of operations personnel at least\n semiannually, or more often as changes occur.3\n\n2. Complete continuity of operations training, including Postal Alert and Notification\n System training.\n\n3. Identify and prioritize essential functions.\n\nManagement\xe2\x80\x99s Comments\n\nManagement agreed with our findings and recommendations 1 through 3, and stated\nthey are currently developing a Continuity Management Instruction (MI). The MI will\ntranslate the new federal requirements as described in the Homeland Security\nPresidential Directive (HSPD) 20 and Federal Continuity Directives (FCD) 1 and 2 into\nPostal Service policy that will be implemented at all levels within the agency. In\naddition, a continuity handbook and emergency plan templates for installations will be\n\n2\n Postal Service Administrative Support Manual (ASM), September 27, 2007: The ASM requires an EMCC to be\nestablished in each area to assist inspectors in charge and district managers in developing emergency plans.\n3\n Although the Postal Service requires contact information to be updated annually, we are recommending that the\nPostal Inspection Service update this information at least semiannually because frequent changes may occur.\n\n\n\n 2\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\ndeveloped based on the policy requirements detailed in the MI. The handbook and\ntemplates will require contact information for key continuity operations personnel be\nupdated at least semi-annually, and when changes occur. The handbook will also\ndocument the supporting tasks for the Postal Service mission essential function, which\nis to deliver the mail. Management stated the MI, handbook, and emergency plan\ntemplates for operations facilities will be completed by December 31, 2008. The\ntemplates for non-operational facilities will be completed by June 2009.\n\nManagement further stated they agreed that the report recommendations will enhance\nthe Great Lakes Area COOP capability and will ensure they can effectively and\nefficiently continue essential functions during emergencies that may disrupt operations.\nHowever, they do not believe the report adequately reflects the tireless efforts of Postal\nService employees and the difficult challenges the Postal Service faced to amend its\npriorities and philosophy related to homeland security since September 11, 2001.\nManagement\xe2\x80\x99s comments, in their entirety, are included in Appendix E.\n\nIn supplemental correspondence provided by Postal Inspection Service and Postal\nService management, management agreed to establish requirements for personnel\nresponsible for COOP to complete COOP and PANS training by the end of fiscal year\n(FY) 2009.\n\nEvaluation of Management\xe2\x80\x99s Comments\n\nThe U.S. Postal Service Office of Inspector General (OIG) considers management\xe2\x80\x99s\ncomments responsive to the recommendations, and the corrective actions should\nresolve the issues identified in the findings.\n\nWe recognize in the report that based on our audit and the Postal Service\xe2\x80\x99s response to\nprior emergencies, we believe they have the capability to continue mail operations in an\nemergency. However, our recommendations, when implemented, should help to\nimprove the Postal Service\xe2\x80\x99s ability to effectively and efficiently continue essential\nfunctions during emergencies and decrease the risk to employees, mail, critical assets,\nand revenues.\n\nWe recommend the Vice President, Great Lakes Area Operations, in consultation with\nthe Chief Postal Inspector:\n\n4. Establish a formal review process to ensure continuity of operations plans are\n completed, updated annually, and maintained in the Postal Alert and Notification\n System, as required.\n\n5. Establish an area emergency management coordinating committee to provide\n oversight and assistance to district and facility Emergency Management Teams in\n establishing, implementing, and reviewing emergency management plans.\nManagement\xe2\x80\x99s Comments\n\n\n\n\n 3\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nManagement agreed with our findings and recommendations 4 and 5, and stated they\nhave developed objectives, goals, and performance measures to ensure the\ncompleteness of Integrated Emergency Management Plans (IEMP) at districts and\ninstallations. National Preparedness templates will be issued by June 2009.\n\nManagement also stated the Postal Inspection Service will incorporate requirements for\nthe EMCC into the new Continuity MI and will work with the area offices to establish the\nEMCCs. They further stated the Great Lakes Area had established their EMCC.\nHowever, in supplemental correspondence provided by Great Lakes Area management,\nmanagement stated they met in March 2008 to discuss their approach for the EMCC,\nbut they had not held any formal meetings. They stated they were waiting for\nheadquarters management to establish the requirement and that they would comply\nwithin 90 days after the requirement has been established.\n\nEvaluation of Management\xe2\x80\x99s Comments\n\nThe OIG considers management\xe2\x80\x99s comments responsive to the recommendations, and\nthe corrective actions should resolve the issues identified in the findings.\n\nAlternate Facilities\n\nIdentification\n\nResponsible Great Lakes Area personnel did not always identify appropriate alternate\nfacilities to ensure they could effectively continue operations. This occurred because\nmanagement did not establish specific guidance for identifying alternate facilities, such\nas the number of alternate facilities that should be identified, and criteria for location,\nmail volume, and mail capacity.\n\nWe recommend the Chief Postal Inspector:\n\n6. Establish specific guidance for identifying and selecting alternate facilities, to\n include, at a minimum, the number of alternate facilities that should be identified,\n and criteria regarding location, mail volume, and mail capacity.\n\nManagement\xe2\x80\x99s Comments\n\nManagement agreed with the finding and recommendation, and stated the new\nContinuity MI and handbook will establish guidance for identifying alternate facilities,\nincluding criteria regarding location, function, mail volume, and mail capacity. The MI\nand handbook will be issued by December 31, 2008. Management further stated that\nthe Postal Service\xe2\x80\x99s alternate facility selections are constrained by the facility function\nand geographic location and FCD 1 requires the identification of one alternate facility.\n\n\n\n\n 4\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nEvaluation of Management\xe2\x80\x99s Comments\n\nThe OIG considers management\xe2\x80\x99s comments responsive to the recommendation, and\nthe corrective actions should resolve the issue identified in the finding. Although FCD 1\ndoes not specifically require agencies to identify more than one alternate facility, having\nadditional alternate facilities could help ensure the continuation of essential functions\nduring emergencies, particularly in an operations-driven environment.\n\nTesting and Exercise\n\nResponsible Great Lakes Area personnel did not always conduct testing and exercises\nto ensure alternate facilities could effectively receive and process the primary facilities\xe2\x80\x99\nmail. This occurred because management did not establish sufficient requirements for\npersonnel responsible for COOP at primary and alternate facilities to conduct tests and\nexercises to ensure alternate facilities could effectively process the primary facilities\xe2\x80\x99\nmail.\n\nWe recommend the Chief Postal Inspector:\n\n7. Require personnel responsible for continuity of operations at primary and alternate\n facilities to conduct tests and exercises to ensure alternate facilities can effectively\n process the primary facilities\xe2\x80\x99 mail.\n\nManagement\xe2\x80\x99s Comments\n\nManagement partially agreed with the recommendation and stated that each facility\xe2\x80\x99s\ncontinuity plan will be tailored to measure offload capability to the extent feasible. Full\nscale exercises to test an alternate facility\xe2\x80\x99s capability to handle offload mail volume will\nnot be undertaken due to negative effects on service. The test, training, and exercise\nprogram will be issued by June 2009.\n\nEvaluation of Management\xe2\x80\x99s Comments\n\nThe OIG considers management\xe2\x80\x99s comments responsive to the recommendation, and\nthe corrective actions should resolve the issue identified in the finding. Conducting tests\nand exercises, whether full-scale or smaller, would help ensure the alternate facilities\ncan effectively and efficiently process the primary facilities\xe2\x80\x99 mail.\n\n\n\n\n 5\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nThe OIG considers all recommendations significant, and therefore requires OIG\nconcurrence before closure. Consequently, the OIG requests written confirmation when\ncorrective actions are completed. These recommendations should not be closed in the\nfollow-up tracking system until the OIG provides written confirmation that the\nrecommendations can be closed.\n\nWe appreciate the cooperation and courtesies provided by your staff. If you have any\nquestions or need additional information, please contact Andrea L. Deadwyler, Director,\nInspection Service and Facilities, or me at (703) 248-2100.\n\n\n E-Signed by Darrell E. Benjamin, Jr\n VERIFY authenticity with ApproveIt\nDarrell E. Benjamin, Jr.\nDeputy Assistant Inspector General\n for Support Operations\n\nAttachments\n\ncc: Pat A. Mendonca\n Zane M. Hill\n Jakki M. Krage\n John F. Bolger\n Katherine S. Banks\n\n\n\n\n 6\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n APPENDIX A: ADDITIONAL INFORMATION\n\nBACKGROUND\n\nThe U.S. Postal Service, an independent establishment of the executive branch of the\nU.S. government, operates like a business and generated $74.8 billion in revenue in FY\n2007.4 The Postal Service is responsible for the development of plans for actions\nnecessary to maintain itself as a viable part of the federal government during\nemergencies.\n\nThe Postal Inspection Service is responsible for protecting the mail, Postal Service\nassets, and customers. As the emergency coordinator for the Postal Service, the Chief\nPostal Inspector is responsible for coordinating emergency planning and civil\npreparedness programs and providing training and guidance to responsible EP\npersonnel.\n\nConsolidation of Postal Service Homeland Security Responsibilities. In March 2007, all\nhomeland security responsibilities were consolidated under the Postal Inspection\nService. These responsibilities included EP and aviation security. These groups\nrealigned to form the Office of National Preparedness (ONP) within the Postal\nInspection Service. ONP\xe2\x80\x99s key responsibilities include incident management,\ninfrastructure protection, aviation mail security, public health preparedness, and\nperformance measures.\n\nONP is responsible for developing Postal Service EP policy and guidance, including the\nIntegrated Emergency Management Plan templates. Its mission is to maintain a high\nstate of national preparedness across the Postal Service enterprise through a\ncomprehensive and coordinated approach to planning, integration, and support.\n\nIntegrated Emergency Management Plan (IEMP). In January 2004, the Postal Service\nestablished the IEMP as the all-hazard, comprehensive plan for the Postal Service to\nmitigate, prepare for, respond to, and recover from any natural or man-made disaster.\nThe IEMP integrates the Emergency Action Plan5 (EAP), the COOP plan, and annexes\nfor specific hazards into one plan. District and facility managers are required to update\nIEMPs at least annually.\n\nContinuity of Operations Plan. The COOP plan is intended to ensure postal facilities\nare prepared to:\n\n \xe2\x80\xa2 Continue essential functions in the event of any emergency that disrupts\n normal operations.\n\n\n\n4\n United States Postal Service Annual Report 2007.\n5\n The EAP provides evacuation-specific tasks and procedures for the facility.\n\n\n\n 7\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n \xe2\x80\xa2 Protect essential equipment, vital records (operating, legal, and financial), and\n assets.\n\n \xe2\x80\xa2 Reduce or mitigate disruptions to operations by minimizing the loss of\n resources and by providing timely and orderly recovery from an emergency\n and the resumption of full service.\n\nThe COOP plan also assists emergency management team (EMT) members in all\nphases of emergency management: mitigation, preparedness, response, and recovery.\nThe Postal Service has developed COOP plan templates for districts and facilities.\nResponsible district and facility personnel should tailor the COOP plan templates to\naddress site-specific requirements and risks.\n\nFederal Preparedness Circular (FPC) 65, Federal Executive Branch Continuity of\nOperations, June 15, 2004. FPC 65 provides guidance to Federal Executive Branch\ndepartments and agencies for developing contingency plans and programs for COOP.\nFPC 65 establishes COOP planning as the means by which federal departments,\nagencies, and their subcomponents ensure their essential functions are performed.\nThis includes plans and procedures that delineate essential functions; specify\nsuccession to office and the emergency delegation of authority; provide for the\nsafekeeping of vital records and databases; identify alternate operating facilities;\nprovide for interoperable communications; and validate the capability through tests,\ntraining, and exercises.6\n\nOBJECTIVE, SCOPE, AND METHODOLOGY\n\nOur objective was to determine whether the Great Lakes Area has a viable COOP\ncapability to ensure the performance of its essential functions during any emergency\nthat may disrupt normal operations.\n\nTo accomplish our objective, we interviewed Postal Service and Postal Inspection\nService officials, including ONP officials; facility heads; and area, district, and facility\npersonnel responsible for COOP plans, to gain an understanding of their roles and\nresponsibilities related to COOP. We reviewed applicable COOP policies and\nprocedures and assessed related internal controls.\n\nWe conducted audit fieldwork at Postal Service Headquarters and various judgmentally\nselected sites in the Great Lakes Area. (See Appendix C for a list of sites reviewed.)\n\n\n\n\n6\n In February 2008, the Department of Homeland Security issued FCD 1, Federal Executive Branch National\nContinuity Program, and FCD 2, Federal Executive Branch Mission Essential Function and Primary Mission Essential\nFunction Identification and Submission Process. These directives supersede FPC-65 and establish continuity\nplanning requirements, including continuity plan templates, to assist departments and agencies in developing internal\ncontinuity processes and procedures. FCDs 1 and 2 are applicable to the Postal Service, and Postal Service\nmanagement has indicated they will comply with the directives.\n\n\n\n 8\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nWe assessed COOP plans for the area, districts, and critical facilities,7 8 to determine\nwhether they addressed Postal Service and federal guidance. In addition, we reviewed\ntraining records from the National Training Database to determine whether key\npersonnel responsible for COOP completed training provided by the Postal Service and\nsuggested by the Federal Emergency Management Agency (FEMA). We also\naccessed data in PANS to determine whether responsible officials updated and\nmaintained current COOP plans in the system. Although we did not conduct extensive\ntests of the accuracy of computer-generated data, we discussed the training records\nand PANS data with applicable personnel and compared the data to other source\ndocuments. As a result, we consider the data sufficiently reliable to support the\nopinions and conclusions in this report.\n\nWe conducted this performance audit from January through June 2008 in accordance\nwith generally accepted government auditing standards and included such tests of\ninternal controls as we considered necessary under the circumstances. Those\nstandards require that we plan and perform the audit to obtain sufficient, appropriate\nevidence to provide a reasonable basis for our findings and conclusions based on our\naudit objective. We believe that the evidence obtained provides a reasonable basis for\nour findings and conclusions based on our audit objective. We discussed our\nobservations and conclusions with management officials on May 9, 2008, and included\ntheir comments where appropriate.\n\nPRIOR AUDIT COVERAGE\n\nIn the past 3 years, the OIG issued 11 reports regarding Postal Service emergency\npreparedness plans. Eight of the 11 audits related to our review of the Postal Service\xe2\x80\x99s\nresponse to Hurricanes Katrina and Rita. In these reviews, we found that while the\nPostal Service took noteworthy actions in responding to the hurricanes, opportunities\nexisted to enhance emergency preparedness planning and response. Management\ngenerally agreed with our recommendations. Two of the audits related to our review of\nemergency plans in the New York Metro and Western Areas. The reports concluded\nthat Postal Service emergency plans were not always completed in accordance with\nfederal and Postal Service guidance and did not fully address risk vulnerabilities. We\nmade five recommendations to improve the EP program. Management agreed with our\nrecommendations to revise the IEMP, identify facilities that require an IEMP, and\nestablish performance measures. Management partially agreed with our\nrecommendations to establish training requirements for EP personnel and to establish\nan area EMCC.\n\nIn addition, the U. S. Government Accountability Office (GAO) issued four reports on\nfederal emergency preparedness planning. Overall, the reports concluded that\nemergency planning could be improved by providing more effective oversight and\n\n7\n Critical facilities are facilities essential for the delivery of vital services. The Postal Inspection Service provided the\nOIG with a list of facilities they determined critical to the Postal Service.\n8\n We assessed one facility that was not considered critical; however, the facility ranked second in the nation for total\nmail pieces handled.\n\n\n\n 9\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nconducting test, training, and exercises. GAO made numerous recommendations to\nimprove emergency planning.\n\n REPORT TITLE REPORT NUMBER REPORT DATE\n\n OIG Reports\nPostal Service Emergency Preparedness Plans\n SA-AR-08-005 March 21, 2008\nfor the New York Metro Area\nPostal Service Emergency Preparedness Plans\n SA-AR-08-006 March 21, 2008\nfor the Western Area\nPostal Service Emergency Preparedness for\n SA-AR-06-007 August 3, 2006\nHurricanes Katrina and Rita\nHurricane Katrina \xe2\x80\x93 The Effectiveness of the\nPostal Service Transportation and Logistics NL-AR-06-006 June 29, 2006\nNetwork\nPostal Inspection Service Emergency\n SA-AR-06-005 June 5, 2006\nPreparedness for Hurricane Katrina\nPostal Inspection Service\xe2\x80\x99s Procurement\nTransactions Related to Hurricane Katrina\n SA-AR-06-004 May 30, 2006\nResponse, Recovery, and Reconstruction\nEfforts\nReview of Postal Service\xe2\x80\x99s Replacement and\n FA-MA-06-001 May 26, 2006\nRepair of Facilities Affected by Hurricane Katrina\nNational Change of Address \xe2\x80\x93 Emergency\n IS-AR-06-005 March 30, 2006\nPreparedness\nMail Processing Operations in the Wake of\n NO-MA-06-002 March 27,2006\nHurricanes Katrina and Rita\nPostal Service Actions to Safeguard Employees\n HM-AR-06-002 February 15, 2006\nfrom Hurricane Katrina\nPostal Inspection Service Emergency\n SA-AR-05-001 January 5, 2005\nPreparedness\n\n GAO Reports\nThe Federal Workplace: Additional Steps\nNeeded to Take Advantage of Federal Executive\n GAO-07-515 May 2007\nBoards\xe2\x80\x99 Ability to Contribute to Emergency\nOperations\nCatastrophic Disasters: Enhanced Leadership,\nCapabilities, and Accountability Controls Will\nImprove the Effectiveness of the Nation\xe2\x80\x99s GAO-06-618 September 2006\nPreparedness, Response, and Recovery\nSystem\n\n\n\n\n 10\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n REPORT TITLE REPORT NUMBER REPORT DATE\n GAO Reports, continued\nContinuity of Operations: Selected Agencies\nCould Improve Planning for Use of Alternate GAO-06-713 May 2006\nFacilities and Telework during Disruptions\nContinuity of Operations: Agency Plans Have\nImproved, but Better Oversight Could Assist GAO-05-577 April 2005\nAgencies in Preparing for Emergencies\n\n\n\n\n 11\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n APPENDIX B: DETAILED ANALYSIS\n\nCompletion of Continuity of Operations Plans\n\nResponsible Postal Service officials in the Great Lakes Area did not always establish\nand maintain COOP plans for area, districts, and facilities9 in accordance with federal\nand Postal Service guidance. In addition, personnel with COOP responsibilities did not\nalways update and maintain all COOP plans in PANS10 to facilitate emergency\npreparedness and response activities. For example:\n\n1. COOP plans were not always completed or updated annually, as required. (See\n Appendix D.) Specifically:\n\n \xe2\x80\xa2 Two facilities did not have a COOP plan.11 In addition, two facility COOP plans\n were not updated annually.\n\n \xe2\x80\xa2 Thirteen COOP plans reviewed were not updated or maintained in PANS.12\n\n2. The COOP plans we reviewed did not contain all pertinent information, such as\n essential functions, staffing needs, offload plans, and current contact information.\n Specifically:\n\n \xe2\x80\xa2 Three of the four district COOP plans did not identify essential functions, as\n required. Although responsibilities were identified for some functional areas,\n such as marketing business service network and finance, districts did not identify\n those critical activities necessary to continue operations in the event of a COOP\n activation.\n\n \xe2\x80\xa2 None of the 14 facility COOP plans we reviewed identified essential functions.13\n\n \xe2\x80\xa2 Four of the 14 facility COOP plans we reviewed did not identify staffing needs.14\n\n \xe2\x80\xa2 Five of the 1415 facility COOP plans we reviewed did not have offload plans.\n\n\n9\n The audit team requested COOP plans from 21 sites and received 19 COOP plans for review: one area plan, four\ndistrict plans, and 14 facility plans. Two facilities did not have COOP plans.\n10\n PANS provides Postal Service EMTs with a mechanism to communicate, coordinate, and collaborate effectively\nduring times of crisis. It is a web-based application that enables a nationwide staff to create, track, and manage\nemergencies through all stages.\n11\n During our audit, personnel at one facility developed that facility\xe2\x80\x99s first COOP plan.\n12\n In May 2006, the Vice President of Emergency Preparedness issued a memorandum requiring personnel to update\nand maintain COOP plans in the Postal Emergency Management System (PEMS). In September 2006, Postal\nService management changed the name of the system from PEMS to PANS. The name change did not affect the\nsystem\xe2\x80\x99s mission and functions.\n13\n The facility\xe2\x80\x99s COOP plan template did not require the identification of essential functions.\n14\n The staffing that is required at offload locations to support the volume and operations being diverted, as well as the\ncontinuation of other essential operations activities.\n15\n Installation offload plans are used to identify offload sites to process mail when the installation is closed and its\nCOOP plan is activated.\n\n\n\n 12\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\nThese situations occurred because Postal Service management did not establish\nsufficient internal controls and requirements to ensure COOP plans addressed federal\nand Postal Service guidance. Specifically, management did not ensure responsible\npersonnel updated the contact information of key COOP personnel at least annually.16\nIn addition, management did not establish:\n\n \xe2\x80\xa2 Requirements for mandatory training, including PANS training, for COOP\n personnel to ensure COOP plans were properly completed and maintained.17\n Fourteen of 20 personnel interviewed did not receive PANS training.\n\n \xe2\x80\xa2 An internal review and approval process to ensure COOP plans were properly\n completed, updated annually, and maintained in PANS.\n\n \xe2\x80\xa2 Guidance to identify and prioritize essential functions.18\n\n \xe2\x80\xa2 An EMCC19 at the area level to provide oversight to districts and facilities.\n\nAlternate Facilities\n\nIdentification\n\nResponsible Great Lakes Area personnel did not always identify appropriate alternate\nfacilities20 to ensure they could effectively continue operations. For example:\n\n \xe2\x80\xa2 Great Lakes Area officials identified two alternate facilities for the area office.\n However, both facilities were located within a 3-mile radius of the area office.\n Using alternate facilities within 3 miles of the primary site increases the risk that a\n single incident, such as a power outage or act of terrorism, could affect the\n primary and alternate sites.\n\n \xe2\x80\xa2 The xxx xxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx xxxxxx identified only one\n alternate facility. The alternate facility identified could not absorb all of the xxx\n xxxxx xxxxxx mail, and was located about 250 miles away in a different Postal\n Service area. During our audit, management acknowledged that the alternate\n facility selected was not a good choice because of its limited capabilities and\n distance from the xxx xxxxx xxxx. They took corrective action and identified two\n additional alternate facilities located in the Great Lakes Area, closer to the\n primary facility.\n16\n The Postal Service IEMPs for districts and installations require the responsible managers to update COOP plans\nannually or whenever circumstances dictate.\n17\n FEMA offers several online COOP courses at no charge, including \xe2\x80\x9cContinuity of Operations Awareness Course,\xe2\x80\x9d\nIS-546, and \xe2\x80\x9cIntroduction to Continuity of Operations,\xe2\x80\x9d IS-547. In addition, the Postal Service has provided IEMP and\nother COOP related training.\n18\n FEMA\xe2\x80\x99s FPC 65 states that essential functions should be identified and prioritized.\n19\n The ASM requires that EMCCs be established in each area to assist inspectors in charge and district managers in\ndeveloping emergency plans.\n20\n FPC 65 provides guidance to identify and prepare alternate operating facilities as part of their COOP plans. To\nminimize risks, distance and geographical location should be considered when selecting alternate facilities.\n\n\n\n 13\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\nThese situations occurred because management did not establish specific guidance for\nidentifying alternate facilities, such as the number of alternate facilities that should be\nidentified, and criteria for location and mail volume or capacity. According to guidance\nprovided by FEMA in FPC 65, at a minimum, an all-hazard risk assessment should be\nperformed when selecting alternate operating facilities to ensure COOP.\n\nTesting and Exercises\n\nResponsible Great Lakes Area personnel did not always conduct tests and exercises to\nensure alternate facilities could effectively receive and process the primary facilities\xe2\x80\x99\nmail.21 For example, the xxx xxxxx xxxx and Bulk Mail Center did not conduct any\nexercises or tests of alternate facilities.\n\nThis occurred because management did not establish sufficient requirements for\npersonnel responsible for COOP at primary and alternate facilities to conduct tests and\nexercises to ensure alternate facilities could effectively process the primary facilities\xe2\x80\x99\nmail. For example, personnel at alternate facilities did not download sort plans in mail\nprocessing equipment to ensure the equipment could effectively handle mail from\nprimary facilities.\n\n\n\n\n21\n FPC 65 provides guidance to plan, conduct, and document annual tests and exercises to demonstrate the plan\xe2\x80\x99s\nviability and identify deficiencies\n\n\n\n 14\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n APPENDIX C: GREAT LAKES AREA, DISTRICTS, AND FACILITIES\n\n GREAT LAKES AREA\n\n NAME CITY STATE\n 1 xxxxx xxxxx xxxx xxxxxx Bloomingdale Illinois\n\n DISTRICTS\n\n NAME CITY STATE\n 1 Xxxxxxx Chicago Illinois\n 2 Xxxxxxx St. Louis Missouri\n 3 Xxxxxxxx Milwaukee Wisconsin\n 4 xxxxxxxx xxxxxxxx Carol Stream Illinois\n\n FACILITIES\n\n NAME CITY STATE\n 1 xxxxx xxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxxxx Carol Stream Illinois\n 2 xxxxxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxxxx Champaign Illinois\n 3 xxxxxxx xxxx xxxx xxxxxx Forest Park Illinois\n 4 xxxxxxx xxxxxxxxxxxxx xxxxxxx xxxxxx Chicago Illinois\n xxxxxxx xxxxxxx xxxxxxx xxxxxxxxxx xxx Chicago Illinois\n 5\n xxxxxxxxxxxx xxxxxx\n 6 xxxxxxx xxxxxxxx xxxx xxxxxx Detroit Michigan\n 7 xxxx xxxxx xxxxxx xxxxxxxx xxxxxx Fort Wayne Indiana\n xxxxx xxxxxx xxxx xxxx xxxxxx Grand Michigan\n 8\n Rapids\n xxxxx xxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx Grand Michigan\n 9\n Rapids\n 10 xxxxxxxxxxxx xxxx xxxxxxxxxx xxxxx Indianapolis Indiana\n 11 xxxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx Madison Wisconsin\n 12 xxxxxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx Milwaukee Wisconsin\n 13 xxxxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx Palatine Illinois\n 14 xxx xxxxx xxxx xxxx xxxxxx St. Louis Missouri\n 15 xxx xxxxx xxxxxxxxxx xxx xxxxxxxxxxxx xxxxxx St. Louis Missouri\n 16 xxxxxxxxxx xxxx xxxx xxxxxx Southfield Michigan\n\n\n\n\n 15\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n APPENDIX D: STATUS OF CONTINUITY OF OPERATIONS PLANS\n\n\n Updated\n Completed or Identified and\n Updated Essential Maintained\n Name Annually Functions in PANS\n1 xxxxx xxxxx xxxx xxxxxx Yes Yes No\n\n DISTRICTS\n\n Updated\n Completed or Identified and\n Updated Essential Maintained\n Name Annually Functions in PANS\n1 Xxxxxxx Yes No No\n2 Xxxxxxx Yes No Yes\n3 Xxxxxxxx Yes Yes Yes\n4 xxxxxxxx xxxxxxxx Yes No No\n\n FACILITIES\n\n Updated\n Completed or Identified and\n Updated Essential Maintained\n Name Annually22 Function in PANS\n1 xxxxx xxxxxx xxxxxxxxxx xxx Yes No No\n xxxxxxxxxxxx xxxxxxxx\n2 xxxxxxxxx xxxxxxxxxx xxx Yes No Yes\n xxxxxxxxxxxx xxxxxxxx\n3 xxxxxxx xxxx xxxx xxxxxx Yes No No\n4 xxxxxxx xxxxxxxxxxxxx xxxxxxx Yes No No\n xxxxxx\n5 xxxxxxxxxxxxxxx xxxxxxx xxxxxxxxxx Yes No No\n xxx xxxxxxxxxxxx xxxxxx\n6 xxxxxxx xxxxxxxx xxxx xxxxxx No No No\n7 xxxx xxxxx xxxxxx xxxxxxxx xxxxxx No N/A23 N/A\n8 xxxxx xxxxxx xxxx xxxx xxxxxx Yes No No\n9 xxxxx xxxxxx xxxxxxxxxx xxx Yes No Yes\n xxxxxxxxxxxx xxxxxx\n10 xxxxxxxxxxxx xxxx xxxxxxxxxx xxxxx Yes No No\n11 xxxxxxx xxxxxxxxxx xxx xxxxxxxxxxxx Yes No Yes\n\n22\n The xxxx xxxxx xxxxxx xxxxxxxx xxxxxx and xxxxxxxxxx xxxx xxxx xxxxxx did not have a COOP plan. In addition,\nthe xxxxxxx xxxxxxxx xxxx xxxxxx and xxxxxxxxx xxxx COOP plans were not updated annually as required. The\nlatest plans were dated September 2004 and September 2006, respectively.\n23\n Not applicable because plan was not completed.\n\n\n\n 16\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n Center\n Updated\n Completed or Identified and\n Updated Essential Maintained\n Name Annually Functions in PANS\n12 xxxxxxxxx xxxxxxxxxx xxx No No No\n xxxxxxxxxxxx xxxxxx\n13 xxxxxxxx xxxxxxxxxx xxx Yes No No\n xxxxxxxxxxxx xxxxxx\n14 xxx xxxxx xxxx xxxx xxxxxx Yes No No\n15 xxx xxxxx xxxxxxxxxx xxx Yes No Yes\n xxxxxxxxxxxx xxxxxx\n16 xxxxxxxxxx xxxx xxxx xxxxxx No N/A N/A\n\n\n\n\n 17\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n APPENDIX E: MANAGEMENT\xe2\x80\x99S COMMENTS\n\n\n\n\n 18\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 19\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 20\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 21\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 22\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 23\n\x0cPostal Service Continuity of Operations SA-AR-08-009\n for the Great Lakes Area\n\n\n\n\n 24\n\x0c'