While all Hillcrest employees are expected to attend to matters of safety and security, the following persons and groups are responsible for the implementation and monitoring of the Security Management Plan.
1. Agency level
At the agency level, security management is the responsibility of the agency Director of Quality Assurance and the Hillcrest Management Team.
2. Campus level
At the campus level, security management is the responsibility of the campus Program Director and their delegates (e.g., direct care Supervisors), and campus Environment of Care Committees.
At least once each month a residential campus Administrator will conduct and document an unannounced visit to and walk through of the campus during the overnight shift.

Sensitive areas include, but are not limited to:
• Areas where medications are stored.
• Areas where confidential student and client records and documents are filed.
• Areas where confidential employee records and documents are filed.
• Areas where controls for utilities can be accessed.
• Areas where money or expensive portable equipment is stored.
• Areas where potentially harmful equipment, tools and/or hazardous substances are stored.
• Campus swimming pools.
• Hillcrest computers and the computer network.
Sensitive areas will be locked at all times or constantly monitored when unlocked in order to control entry and egress. Any authorized, professional visitor to a Hillcrest campus is required to sign a Confidentiality Statement that outlines Hillcrest’s expectations for privacy and confidentiality for students, clients and student and client records.

Entry areas to campus swimming pools are locked and secured, and all pools meet or exceed local safety codes.

Access to Hillcrest computers, computerized student and client information and the Hillcrest computer network are restricted by a multi-level password system, with limited access and a firewall on the network. The Director of Information Services and the Executive Coordinator maintain copies of password lists. Access to the Internet is limited and is “filtered” according to standards set forth by the Federal Internet Protection Act. Computers used by students are not able to access the Hillcrest network. All networked computers utilize up-to-date virus software.

Key assignments are inventoried and controlled, and master keys are also inventoried, controlled and strictly limited to a small number of staff on a “need” basis.

During the overnight shift, exterior doors to all buildings are kept locked in order to limit entry to authorized personnel.

All Hillcrest work sites are small enough that almost all employees know one another. New or temporary employees are introduced to the community in brief information meetings, “Stand Ups”, which are conducted at the beginning of each shift.

All Hillcrest employees are required to wear HEC-standard photo identification at all times while working. Hillcrest maintains a database containing photos of all employees.

Visitors to any Hillcrest program site are required to sign in at the Reception area and to wear a Visitor’s Badge while on campus. All Hillcrest employees are trained to greet, confront and/or report any person who is not wearing a visitor badge and who is unknown to them or their coworkers. On residential campuses direct care supervisors make periodic sweeps of the campus during each shift, including a walk-through of each building on the campus during the overnight shift, providing additional security monitoring. Finally, student dormitories on residential campuses are monitored through the use of video camera, monitoring and taping equipment.

All Hillcrest employees are expected to report all potential or actual breaches of security or safety as soon as possible. Employees may report incidents, information and/or concerns to any supervisor or administrator at any Hillcrest site. If the security issue is not cause for immediate concern and response, employees may report the issue or concern to the campus Environment of Care Committee, or to the agency Administrator of Health, Safety & Wellness Programs, all of whom are obligated to investigate reported information and/or concerns in a thorough manner until they are appropriately resolved. Additionally, Hillcrest coordinates with local law enforcement agencies as needed.

All significant matters pertaining to security, including security-related incidents, are reported to and reviewed by campus Environment of Care Committees to insure that systemic security issues and possible patterns or trends are addressed and resolved.

Security issues at any Hillcrest campus or site are addressed by the supervisors, administrators and Environment of Care Committee at that campus, as well as by the agency Administrator of Health, Safety & Wellness Programs and Management Team. The agency has established relationships with local law enforcement agencies, and program administrators work in conjunction with local law enforcement agencies as needed. Safety and security in the environment of care, however, are shared benefits and fundamentally necessary conditions for which all employees are responsible. All Hillcrest employees are expected to be aware of and to attend to matters pertaining to safety and security in the course of their work. Employees are expected to report all potential or actual breaches of security or safety as soon as possible.

Program sites also address their unique security issues in ways best suited to their needs, campus setting and goals. For example, Hillcrest Center locks the Tetro Center at night and utilizes a call box at the entrance by which visitors can reach Supervisors on grounds.

The primary objectives of the Security Management Plan are to:
• Provide a secure and protective environment for students, clients, staff and visitors.
• Provide reasonable protection for the property of Hillcrest students, clients, staff, visitors and of the agency itself.
• Reduce the probability of harmful incidents.
• Hillcrest will accomplish these objectives in a manner compliant with regulations promulgated by the Mass. Dept. of Early Education and Care (DEEC), Mass. Department of Elementary and Secondary Education (DESE), standards established by the Joint Commission (JC), and all other applicable laws, regulations and standards.

Hillcrest Educational Centers is committed to the protection of Hillcrest students, clients, staff and visitors and to the physical property of the agency, students, clients, staff and visitors. The Security Management Plan and associated policies and procedures are intended to complement other plans, policies and procedures designed and implemented to insure a safe, secure, comfortable, and therapeutic environment of care.

BACKGROUND & INTRODUCTION
In developing this plan the following factors were taken into account.
• Hillcrest residential and non-residential sites are located in suburban and semi-rural areas that have relatively low crime rates.
• Hillcrest students come from multiple states. Therefore the general flow of visitors from the community to Hillcrest sites; visitors to students and the security issues that accompany student visitation; and the possibility of student abduction, disturbance or other event performed by a family member or non-family visitor, are minimized and within controllable limits.
• Hillcrest staff to student ratios are comparatively high, including awake overnight staff. There are many staff, almost all of whom know one another, present throughout all hours of the day, and supervisors at each site periodically patrol the campus. This high staff and supervisor ratio help to minimize the possibility of student elopement and the undetected presence of unauthorized or unaffiliated visitors or intruders on site.
• Hillcrest utilizes video security cameras that are strategically located on campuses for supervision and security purposes.
• All Hillcrest staff are trained and authorized to take responsibility for maintaining a safe, secure environment of care.

1. Fire Watch
The National Fire Protection Association (NFPA) 101 Life Safety Code®, ed. 2006 (sections 3.3.91, 9.6.1.6, and A9.6.1.6) and Joint Commission standards require that, when a fire alarm and/or sprinkler system in an occupied building is out of service for any reason for a specified period of time:
a) the building must be evacuated, or
b) a Fire Watch must be provided continuously until the fire alarm and/or sprinkler system has been returned to service.

Whenever a fire alarm or automatic sprinkler system is out of service in an occupied building for more than 4 hours within a 24 hour period, Hillcrest provides a fire watch.
Depending on conditions, the agency may consider initiating a fire watch before the 4 hour mark is reached. However, if and when the 4/24 mark is reached in an occupied building, a fire watch will be provided

2. Definition
Providing a Fire Watch means designating a trained staff person whose sole responsibility is to look for and prevent fires within a designated area, typically one occupied building, as authorized by a program supervisor, administrator or maintenance supervisor. Fire Watch duties are not to be added to a staff’s normal duties; the person assigned to Fire Watch cannot be engaged in any activities beyond fire prevention and safety.

Maintenance managers and program supervisors are responsible for overseeing the activities of the individual(s) assigned to conduct the Fire Watch.

3. Rationale
In most cases, the evacuation of an occupied building on a Hillcrest campus is not practical and could be disruptive.

All HEC program staff are periodically trained in Rescue, Alarm, Contain, and Extinguish/ Evacuate (RACE) and the implementation of a facility-wide fire watch. The Fire Watch is a short-term alternative that safely allows continued occupancy of facilities. Therefore, all HEC program sites will utilize the following procedure for providing a fire watch.

Conditions and Procedures
a) Immediately following the deactivation of a fire alarm system in an occupied building, the Supervisor or a designee will:
1. contact the on-call maintenance staff;
2. notify the local fire department of the outage;
3. communicate the need for heightened awareness and vigilance to all staff on duty.

b) If more than one occupied building is affected by outages, the Maintenance on call person and the Supervisor or Administrator will decide how many staff will be assigned to Fire Watch, and their areas of responsibility, in order to insure safe conditions.

c) Fire Watch activities include:
(1) Monitoring the unprotected area(s) to detect conditions likely to cause and spread fires.
(2) Promptly notifying the fire department if a fire occurs.

d) The staff serving as Fire Watch will tour the building or buildings for which the Fire Watch staff is responsible, looking through all rooms and areas in the building for possible signs of fire or potentially dangerous conditions.

e) The person assigned to Fire Watch will not engage in any other program or campus related activities or events. At an Administrator’s discretion, additional staff may be called to the program if necessary to insure Fire Watch and safe conditions.

Cancellation of the Fire Watch

A Fire Watch will be cancelled only by the local Fire Department, based on an assessment that the fire alarm and/or sprinkler system is operating properly. Neither agency managers nor the person conducting the Fire Watch have the authority to cancel the Fire Watch without the approval of the local fire department.

Hillcrest maintains policies pertaining to the use of interim life safety measures (ILSM) as part of Hillcrest Policies and Procedures. These include written criteria to evaluate deficiencies and construction hazards for determining when and to what extent one or more of the following measures are applicable:
1. Ensuring free and unobstructed exits. Staff receive additional training when alternative exits are designated. Buildings or areas under construction must maintain escape routes for construction workers at all times, and the means of exiting construction areas are inspected daily.

2. Ensuring free and unobstructed access to emergency services and for fire, police, and other emergency forces.

3. Ensuring that fire alarm, detection, and suppression systems are in good working order. A temporary but equivalent system is provided when any fire system is impaired. If used, temporary systems are inspected and tested monthly.

4. Ensuring that temporary construction partitions are smoke tight and built of noncombustible or limited combustible materials that will not contribute to the development or spread of fire.

5. As required by the Life Safety Code®, NFPA 101, 1997 edition, Hillcrest immediately notifies the local fire department of any alarm system power disruption. As detailed below, Hillcrest provides a fire watch, whenever a fire alarm or automatic sprinkler system is out of service in an occupied building.

6. Providing additional fire-fighting equipment and training staff in its use.

7. Prohibiting smoking at all HEC sites.

8. Developing and enforcing storage, housekeeping, and debris-removal practices that reduce the building’s flammable and combustible fire load to the lowest feasible level.

9. Conducting fire drills on a quarterly basis on each residential and overnight shift in the dorm buildings, and monthly on the academic shift in all areas used as classrooms.

10. Increasing hazard surveillance of buildings, grounds, and equipment, with special attention to excavations, construction areas, construction storage, and field offices.

11. Training staff to compensate for impaired structural or compartmentalization features of fire safety.

12. Conducting organization wide safety education programs to promote awareness of life safety building deficiencies, construction hazards, and ILSM.