Appendix G: Guidelines for Agencies
All Departments and Agencies
The following guidelines are drawn from the Task Force’s Final Report. Departments and agencies should incorporate these guidelines into their own family support plans and policies.
1. Adopt as flexible a set of definitions for “family members” as possible, where not already prescribed by existing statutes. The experiences of the airlines after air disasters have pointed to the need to recognize the diversity in contemporary family structures.
It has been the airlines’ experience that several individuals could consider themselves “family” of the victim, even if the law doesn’t formally acknowledge such a relationship. Such would be the case for fiancées, long-time companions, former spouses, step-family members, etc. With regard to notification, the definition should be as broad and flexible as possible, in order to best ensure that key family members are reached in a timely fashion by the government’s representatives possessing knowledge of the passenger’s status in an accident.
With regard to eligibility for support and benefits, for example travel to the site and workers’ compensation or death benefits, the definitions need to be more restricted and in accordance with existing laws and regulations, but still allow sufficient flexibility to respond according to the circumstances of the specific air accident. It may be appropriate to provide travel and accommodations to more than the legally-defined next of kin. The degree of affinity of a person to the victim should establish precedence, but agencies should remain sufficiently flexible, allowing a fixed number of travelers for example, while allowing the family to self-select those who participate.
2. Require passengers aboard a government flight to provide a point of contact by name and phone number to the agency operating the flight, prior to boarding. Commercial airlines have made the point of contact data collection optional for its passengers, given the delays and ensuing costs in completion of a form and the collection of data. However, the working group recognized the advantage of having an emergency point of contact to best ensure timely family notification. The practice of maintaining emergency data on family contacts is a long-standing one in the military. A similar practice should be adopted for nonmilitary Federal employees, in the interest of aiding agencies with their notification responsibilities. Enhanced manifests shall contain the passenger’s full name, and for each passenger, the name and phone number of one contact. Manifest forms can be flexibly designed according to agencies’ needs but should be available for immediate transmission by the quickest means should it be called for.
3. Each agency should identify a single point of contact for liaison with support agencies, and with affected families, in the event of a federal aviation disaster. There is ample evidence of the need for a clear line of communication and a single source of information for family members. The agency or Department sponsoring the flight should have lead agency responsibilities for ensuring that family notifications are made and information is provided to families as it becomes available. They should also be the main conduit to other agencies that might be participating in the sponsoring agency’s mission, or with the agency operating the aircraft, should that be different than the sponsoring agency. In addition, each agency should identify an emergency contact and after hours telephone number (i.e., Operations Center) for the NTSB to use in the event of a domestic or international emergency.
In the event of an accident overseas, the DOS has certain statutory responsibilities with regard to notification of death and conservation of the estates of U.S. citizen victims. The DOS will discharge these responsibilities by working closely with the sponsoring agency who will remain the lead agency with regard to family assistance. (The DOD is required to officially report the deaths of its military and civilian personnel.)
The sponsoring agency would also be the single point of contact for the families of both its employees, and any private citizens that might be involved. It would be the source for all information about status of loved ones, assistance to survivors, identification of remains, the investigation (in concert with NTSB), memorial services, recovery of personal effects, transportation of remains, funeral representation details, administrative and disciplinary actions when appropriate, survivor benefits counseling, and any other counseling or support issues that might arise. The key is to make it easy for family members to have a known and reliable point of contact, for both the short and long term.
The sponsoring agency would also be the primary point of contact for family members with other government branches and agencies, serving as a limited “advocate” for them by facilitating introductions to the right organizations and persons for whatever issues the families would want to pursue.
4. Develop proactive and sensitive family notification and media contact procedures. Those responsible for notifying family members face a difficult situation in many regards. First, they must have accurate and easily obtainable passenger and contact information. Then, they must deal with a many different family structures and people who are probably unknown to them. Apart from the sometimes non-traditional family makeup or boundaries, the truly “key” members of a particular family may not be known to those needing to make the call. Further, the government representatives could be deluged with incoming calls from a large number of persons claiming family status, tying up limited communications capabilities and diluting the agency’s best efforts to reach all the affected families as quickly as possible. Nonetheless, how the family is initially contacted and handled for the first couple of days makes all the difference in their perception of a caring and effective response. Families want to be contacted by the agency, or someone “in a position to know,” before hearing of the accident or their loved one’s death from the media.
Ideally, notification by an agency to family members of their loved one's death or injury should be in person. If it is performed by other means, it should be followed promptly by a person-to-person contact from either the agency, the American Red Cross, or another official entity, if offered to and accepted by family members.
When making initial notification to a family that a loved one was a passenger on an aircraft involved in an aviation disaster, the agency should inquire if there is another family member who should also receive formal notification. These secondary contacts would be notified after initial notification to families of all passengers. Families should designate a primary contact point for purposes of information sharing in the aftermath of the disaster. While it may be necessary for families to have more than one contact point, agencies should try to get the family to limit the numbers of contacts, keep the agency out of any family dynamics like “factions,” and have the family keep itself informed.
Agencies should put in place systems and procedures to establish communication with family members as soon as possible. Information should be provided on a “rolling basis” -- that is, make speedy initial contact, even with incomplete information, and keep making regular periodic contact with the family, either when new information is available, or simply to let them know that additional information is not available. Both are vital to the families’ ability to cope.
The sponsoring agency should assume primary responsibility for establishing and especially, sustaining contact with family members. If a third party is involved initially, (e. g. Red Cross, or DOS for incidents in a foreign country) assume primary contact duties as soon as possible. Adopt policies to ascertain the family’s needs (financial and otherwise) in the immediate aftermath of aviation disasters, and provide assistance as appropriate. Its representatives should specifically inquire if the person contacted is alone, and needs support, and follow through as necessary.
Agencies should advise family members that the name of their loved one will not be publicly released by the agency until the family has personally notified other family members. Ask the family contact how much time is needed to complete their own notifications within the family. Establish procedures designed to respect the privacy of family members after an air crash. Inform families that it is their choice if they want to interact with the media. Family members of the victim should have time to cope with the initial shock of the tragedy prior to having the victim's name publicly released, and should be provided an opportunity to personally notify other loved ones of their family member's involvement in an aviation disaster. Agencies should work closely with the NTSB, which should serve as a liaison between family members and the press during the initial days following an aviation disaster and work with the families and the media to appropriately limit media contact with the families so that families can decide in advance whether they wish to speak with the media.
5. Consider paying for family members' travel expenses (including on-site room and board) related to the accident. As a best practice, departments and agencies should be encouraged to transport family members to crash sites when feasible, and to memorial services or monument dedication ceremonies. It has become a general practice with commercial air carriers to do so, and it addresses key psychological needs. While the government is somewhat hampered in its ability to provide such services for accident-related events, there is leeway to enable travel and accommodations to take place (Appendix D).
Additionally, the following key principles as articulated in Recommendation 1.3 of the ADFAA Task Force Final Report should be adopted, should a department or agency decide to offer transportation and accommodations to family members:
6. Ensure that government employees who are assigned to interact with families following an aviation disaster are screened and receive adequate training. The families of the CT-43 crash reported a wide spectrum of impact by those government representatives who made initial contact with them, ranging from excellent to disastrous. Clearly, the untrained and unaware can needlessly compound a difficult and tragic situation even through unintentional actions and statements. Just as important are the contacts made by government representatives with family members in the longer term. Recommendation 1.4 of the ADFAA Task Force Final Report delineates key mental health and emotional components of training programs for anyone who interacts with victims’ families and should be adopted by government agencies as part of their response plans.
NTSB will coordinate a partnered effort among OPM, which provides expert consultation in the matters of mass trauma and grief dynamics, the ARC, and the DOJ (Office for Victims of Crime), DOS (Overseas Citizens Services), and HHS (Federal Occupational Health division), which provide much of the notification to families who lose loved ones, to develop employee screening processes and training programs to best equip the government with the proactive and compassionate response that is critical to the families’ needs in dealing with tragic loss.
The screening and training processes, once developed, should be a mandatory part of each agency-specific response plan, which is consistent with the ADFAA Task Force’s recommendation for airlines in this regard.
7. Provide emergency mental health services for family members in partnership with the NTSB and through the Employee Assistance Program model for assessment and referral for longer term care. According to the NTSB plan, the ARC provides counseling for family members at the crash site or at their homes for those who do not travel to the site. One different dynamic of the response to a government air disaster is the widespread existence of Employee Assistance Programs (EAP). OPM, as the government’s EAP policymaker, should develop sufficient policies in partnership with the NTSB, the ARC, and with EAP providers to be able to respond with proper crisis intervention in the immediate aftermath of an air disaster, and with assessment and referral to outside grief counseling in the longer term through the classic EAP model for those who so desire.
The division of Federal Occupational Health (FOH), of the Health Resources and Services Administration of the U.S. Public Health Service, is the government’s largest (but not only) single EAP provider. It has over 400 interagency agreements covering more than 1.4 million Federal employees (including the Postal Service), and has screened and certified a nationwide network of over 6,000 licensed professional counselors. FOH and other federal EAP providers should assist the ARC, which is the first responder in accordance with the NTSB Family Assistance Plan. Should the ARC not be in a position to respond, the FOH would be able to provide those services. Should ARC need augmentation, FOH is situated through its national provider network to assist them.
An agency needing to provide such emergency services to either family members or its own employees in the aftermath of an air disaster should first evaluate its own EAP’s capabilities and respond appropriately. But should the EAP be evaluated as inadequate for the task, the agency point of contact should contact FOH which could then either augment or fully provide the emergency services and counseling needed.
OPM EAP policy writers should amend basic EAP requirements for agencies to reflect the need to be able to fully address emergency mental health services for not only employees and their family members, but family members of private citizens involved in government air disasters. EAP has been consistently expanded in its scope to include these groups in disaster situations. Humanitarian expenses such as these can, through precedent (the Oklahoma City Federal building bombing) and Attorney General and Comptroller General decisions be considered within the realm of a department’s or agency’s “necessary expenses.” We urge the speedy enablement of such practices through OPM policy.
OPM should require those agencies that routinely participate in aviation missions to have the ability to deliver those services, either through their own EAP or in an agreement with FOH.
8. Develop policies to ensure personal effects are returned to family members. While recognizing that the identification and association of personal effects is difficult, families often have an emotional need for the return of the last articles of clothing the passengers wore or the purses or wallets that the victims carried, as such effects are the last association or connection with their loved one. It is critical that the families be consulted about the personal effects of the passengers, that the government return personal effects to families unless retained for accident or criminal investigation, and that any unclaimed possession will be retained by the responsible agency for a minimum of 18 months.
The process for the return of unassociated personal effects is deliberate and can be time consuming. To do this correctly, all items are first cleaned as needed, inventoried, numbered, and photographed. Once this process is complete, a photo catalogue is produced and sent to all victims or their families. To allow for a wide range of emotional reactions upon receipt of the catalogue, notify the families before it is sent, or clearly identify the mailing container as to its contents. Instructions should be provided on how to claim an item. Once all victims or families have responded, items claimed by only one person are returned per their instructions. Claims by more than one party must be substantiated and proven by pictures, invoices, or other means. The item is returned once ownership is determined. There is a growing number of commercial firms that specialize in the proper preparation and return of personal effects. The NTSB can provide the firms’ names for agency consideration. Agencies should contact the DOS (Overseas Citizens Services) if the disaster occurred in a foreign country or if a victim resided overseas, for their assistance concerning the protection and return of personal effects, property, and estates. The DOS has a statutory responsibility to safeguard the estates of deceased U.S. citizens overseas.
9. Consult with family members in planning memorial services and markers. The erection of memorials and the holding of services are recognized as key elements in the healing the grief that family members experience. Should services be held and/or a monument built, involve interested family members early and keep them involved as appropriate. Some important factors are: notification of all families, due consideration to the diversity of backgrounds and beliefs, easy accessibility to the monument by visiting family members, and public and private funding sources.