Business Continuity

Pandemic Planning Considerations

“By failing to prepare, you are preparing to fail.”
                                                     Benjamin Franklin

If this is the first time planning for a Pandemic, then understanding the seriousness of this threat can be gleaned from understanding the following facts.  These viruses can spread quickly and explosively worldwide, as did the influenza pandemics in 1918, 1957, 1968, and 2009; they can cause limited outbreaks, such as the influenza A (H3N2) variant (H3N2v) virus in the United States associated with agricultural fairs in the summer months of 2011, 2012, and 2013; or continue causing limited animal-to-human transmission of virus, such as the influenza A (H5N1) and influenza A (H7N9) viruses in Asia.

Furthermore, novel influenza A viruses, even when transmissible in a closed setting, do not always result in a pandemic, such as the 1976 influenza A(H1N1) outbreak in Fort Dix, New Jersey, and the 2011–2013 H3N2v outbreak in the United States. 

Identifying and responding to this wide range of situations require systematic frameworks that describe the progression of events; weigh the risk of emergence and potential public health impact of the novel virus; evaluate the potential for ongoing transmissibility, antiviral resistance, and disease severity; and can be used to develop time-sensitive decisions about interventions (e.g., community mitigation measures, medical countermeasures, and vaccines).

Preparedness and response frameworks provide a common basis for planning across different jurisdictions and ensure transparency in decisions made and actions taken.

Significant progress has been made toward developing pandemic plans, as well as preparedness and response frameworks, during the past decade. Efforts by the World Health Organization (WHO), CDC, other U.S. government agencies, and state and local jurisdictions have addressed pandemic preparedness planning.

Lessons regarding gaps in U.S. influenza decision-making frameworks have become evident with each event and exercise. The recent emergence of human disease caused by H3N2v in the United States and H7N9 in China has demonstrated the need to align existing documents and frameworks into one useful tool that can be used to guide ongoing planning and response efforts.3 

The 4 Pandemic Planning Pillars—surveillance, vaccine and antiviral drug delivery, emergency response, and communication—are a solid foundation for pandemic preparation. Although state pandemic plans may have different structures, reliance on these pillars has remained more or less constant over time.

The World Health Organization (WHO) has developed an alert system to help inform the world about the development of the different stages towards a pandemic. The alert system is comprised of six phases.

The current situation with the HPAI-H5N1 virus in animals and humans places the world in pandemic alert phase 3. This means that H5N1 is currently causing disease (and deaths) in humans, but is not yet spreading efficiently from human to human. The situation with the ‘Mexican flu’ H1N1 virus placed the world in Pandemic alert phase 6. This means that there are large clusters of infection with an extensive and sustained human-to-human spread in the general population at different continents. 

Long before a Pandemic occurs it is the responsibility of businesses to have planned and prepared.  A formal Business Continuity Plan for the organization will be planned and tested along with individual departmental pandemic plans as a component of the Business Continuity Plans.  Below are the standard phases for these plans.  In addition, HR will require some changes to absenteeism policies.

Regular awareness activities will be communicated to staff such as pay and benefits during pandemic and some other considerations such as:

1. Sick leave policy changes
2. Social distancing (i.e. meetings / restaurants / etc.)
3. Develop an illness identification checklist
4. Illness notification process
5. Inability to turn up for work (sick relatives / closed schools / etc.)
6. Fear of returning to work policies
7. Extended absence from work policies
8. Forced absence from work policies
9. Trauma/bereavement services
10. Travel policy
11. Return to work policy
12. Quarantine when returning from travel policy

Pandemic Escalations

As part of the Business Continuity plan knowing the phases of a pandemic is necessary to begin the escalation to a full pandemic response.  Adding these and policy differences are important for all Business Continuity Plans.  By using the standard escalations used by the World Health Organization (WHO) and the Center for Disease Control (CDC).  It is possible to sign up for email updates from this organizations to help with regular monitoring.  The News agencies should not be relied upon for information about these escalations.

Interpandemic period

• Phase 1: No new influenza virus subtypes have been detected in humans. An influenza virus subtype that has caused human infection may be present in animals. If present in animals, the risk of human infection or disease is considered to be low.
• Phase 2: No new influenza virus subtypes have been detected in humans. However, a circulating animal influenza virus subtype poses a substantial risk of human disease.

Pandemic alert period

• Phase 3: Human infection(s) with a new subtype, but no human-to-human spread, or at most rare instances of spread to a close contact.
• Phase 4: Small cluster(s) with limited human-to-human transmission but the spread is highly localized, suggesting that the virus is not well adapted to humans.
• Phase 5: Larger cluster(s) but human-to-human spread still localized, suggesting that the virus is becoming increasingly better adapted to humans but may not yet be fully transmissible (substantial pandemic risk).

Pandemic Period

• Phase 6 Pandemic: increased and sustained transmission in general population. Recently it has been recognized that a very crucial event in the emergence of a pandemic virus is the transition from phase 3 to phase 4, which may go much faster than previously supposed. This is an important insight, since, at this transitional stage, major intervention strategies can still be initiated and implemented successfully in countries with a well-developed pandemic preparedness plan. This proved to be the case with the emergence of the ‘Mexican flu’ pandemic in 2009. It took three days between phase 4 and 5, and six weeks between phase 5 and 6.

FFIEC Examinations

Financial Institutions, Technology Service Providers and/or other vendors and providers to financial institutions will want to pay close attention to the FFIEC Booklet, Appendix D which explains the requirements for Pandemic Planning3 which specifically explains that there are distinct differences between pandemic planning and traditional business continuity planning. When developing business continuity plans, financial institution management typically considers the effect of various natural or man-made disasters that differ in their severity. These disasters may or may not be predictable, but they are usually short in duration or limited in scope. In most cases, malicious activity, technical disruptions, and natural/man-made disasters typically will only affect a specific geographic area, facility, or system. These threats can usually be mitigated by focusing on resiliency and recovery considerations.3

Typical Errors in Planning for Pandemic

Appendix D: FFIEC Pandemic Planning

FFIEC Booklets: http://ithandbook.ffiec.gov/it-booklets/business-continuity-planning.aspx

Traditional business continuity and pandemic planning require management to follow a cyclical process of planning, preparing, exercising, responding, recovering, and continuous improvement. However, pandemic planning requires additional actions to identify and prioritize essential functions, employees, and resources within the institution and across other business sectors. The issues discussed below highlight the specific challenges faced by management and the mitigating controls that should be considered when developing a pandemic plan.