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Preparing Your Institution for a Catastrophic Event


Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005


Preparing Your Institution for a Catastrophic Event

The Federal Financial • Lack of electrical power or

Institutions Examination fuel for generators rendered
Council (FFIEC) member computer systems
agencies (regulatory agencies)1 inoperable.
and the Conference of
• Multiple facilities were
State Bank Supervisors are
destroyed outright or
relaying comments made by
sustained significant damage.
financial institutions regarding
lessons they learned from the • Some branches and ATMs
effects of Hurricane Katrina. were underwater for weeks.
Financial institutions have • Mail service was interrupted
responded admirably to the for months in some areas.
unique challenges raised by
successive hurricane seasons Business continuity plans
with significant storms. Major generally worked very well in
challenges faced by these enabling institutions to meet
institutions included the these challenges and to restore
following: operations swiftly. However,
the unprecedented magnitude
• Communications outages and duration of the effects of
made it difficult to locate Hurricane Katrina caused major
missing personnel. disruptions that exceeded the
• Access to and reliable scope of the disaster recovery
transportation into restricted and business continuity plans
areas were not always of some financial institutions.
available. Many institutions had to
adjust plans and improvise
1 Federal Deposit Insurance Corporation, Board of Governors responses to successfully address
of the Federal Reserve System, Office of the Comptroller of
the Currency, Office of Thrift Supervision, and National Credit
unexpected complications. For
Union Administration (collectively, the regulatory agencies). example, institutions adapted

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procedures to facilitate cashing Lesson Learned – Some

checks for non-customers. organizations may
Overall, institutions prevailed not have anticipated
in very difficult circumstances or prepared for the
through advance planning and
extensive destruction and
preparation, and by working
prolonged recovery period
together. As a result of these
efforts, the financial industry resulting from Hurricane
was able to assist customers and Katrina.
communities in their time of
greatest need.
Are we prepared?
Certain financial institutions
A disaster like Hurricane
affected by Hurricane Katrina and
Katrina, although infrequent,
its aftermath have relayed the
may require financial institutions
following experiences or lessons
to implement their disaster
learned that your institution
recovery plans and to improvise
may find helpful in considering
creative solutions to address
its readiness for responding to
unforeseen difficulties quickly.
a catastrophic event. You may
You may want to reassess how
want to consider this information
well your institution is prepared
when conducting a review of
for reasonably foreseeable
your institution’s disaster recovery
threats across all levels of the
and business continuity plans.
organization, not just from the
These lessons learned should not
perspective of recovering your
be construed as new regulatory
information technology.
requirements, nor do they
supplant or modify the guidance
How much planning/preparing
provided by the FFIEC in its
is enough?
Business Continuity Planning
Booklet.2 You cannot prevent or
anticipate all disasters, so you
2 More information on the FFIEC’s guidance on business
continuity plans is available at should prepare and practice
for them. Knowing where to

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

go and what critical functions mitigate the range of risks

need to be restored can provide that realistically may confront
confidence to you and your your institution. Developing,
employees when responding to implementing, and regularly
a disaster. Identifying potential testing disaster recovery and
threats, assessing their potential business continuity plans
impact, assigning priorities, and to ensure their continued
developing planned responses effectiveness for responding
are the basic principles of sound to changing business and
business continuity planning. operational needs takes time,
Such reviews often categorize resources, and money. You
threats on a scale from high to should consider how to strike
low, according to both their a balance between addressing
probability of occurring and the the threats your institution faces
impact each could have on the with cost-effective measures
institution. to mitigate those risks and
recognizing areas where it
The impact rather than the
may be either cost-prohibitive
source of the threat should
or impossible to alleviate your
guide the development of
institution’s exposure.
disaster recovery and business
continuity plans. For example, Lesson Learned – To be
a threat that presents a low realistic, disaster drills
probability of occurring and a should include all critical
low impact may not warrant functions and areas.
further review. However, every
threat that could pose a high
adverse impact generally How thorough should disaster
warrants further consideration drills be?
regardless of its probability of Disaster drills should be
occurrence. relevant to a specific location
You should implement (considering infrastructure,
reasonable safeguards to population centers, weather,

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threats of terrorism, natural to protect employees from

disasters, etc.) and include potentially harmful exposure
worst-case scenarios. You to contaminated bank records,
may want to reconsider the cash, or contents in safe deposit
frequency and scope of future boxes.
testing strategies to incorporate
more thorough functional and How should we assess disaster
full-scale tests of all support drills?
operations, business lines, and Performance assessments after
geographies. each disaster test help ensure
These periodic tests are most that each simulation improves
effective when they simulate the institution’s ability to recover
realistic disasters and require the from a catastrophic event. After
processing of a sufficient volume conducting a drill, you should
of all types of transactions review the results to determine
to ensure adequate capacity what worked correctly, what
and capability at all recovery went wrong or not as expected,
sites. The tests should also what areas can be improved,
consider all critical functions and and what, if any, adjustments to
applications, use only off-site your plans are needed.
data and supplies, and include
some level of improvisation to Who should participate in
meet unexpected events. disaster drills?
Your organization’s successful
For example, you may want recovery can hinge on the
employees to practice using efforts of key personnel, and
manual back-up procedures those key personnel may
(e.g., debit and credit tickets) change. As a result, you
to process transactions until should promote a “we’re in
electronic systems are restored. this together” attitude and
Or, a disaster drill could simulate recognize that all employees
situations that involve the can contribute to an institution’s
restoration of damaged loan disaster recovery and business
files or documents, and how

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

continuity efforts. Employees at communication methods might

every level of your organization include two-way radios, cellular
should know their role in the telephones with out-of-state area
disaster recovery and business codes and/or text messaging
continuity plans. capability, satellite telephones, or
personal data assistant (PDAs).
Lesson Learned – Employees could use these
Anticipate disruptions in less-traditional communication
communications services, methods to report their location
possibly for extended and obtain current information.
periods of time. In addition, you may want
to establish a central point of
contact outside the potential
How can we communicate? disaster area and make pre-
Hurricane Katrina illustrated established toll free telephone
that a widespread disaster numbers available for employees
can strand employees without and customers.
access to working land-line
or cellular telephone services. What about the mail?
You may want to develop, A widespread disaster can
test, and update a contact disrupt the U.S. Postal Service
list for senior management, for an extended period. During
employees, customers, vendors, Hurricane Katrina, customers
and key government agencies. with automatic deposit and bill
Maintaining copies of this payment services experienced
information at all sites, plus one less difficulty in maintaining
or more off-site locations, can their accounts. You may want
be very helpful in the event of a to encourage or assist your
disaster. customers in establishing direct
You also may want to develop deposit account relationships or
alternate ways for locating and automatic bill paying services
communicating with employees to mitigate disruptions in their
and customers. Less-traditional finances.

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Lesson Learned – Critical In addition, you may want

staff may not be able to consider what type(s) of
to reach their assigned credentials employees will need
recovery location. to gain access into a disaster
area, as authorities may restrict
Where is everybody?
What alternate transportation
Your disaster recovery and
methods could be considered?
business continuity plans
should not assume that In the aftermath of Hurricane
all key personnel will be Katrina, many financial
available at designated sites institutions had employees
to assist in recovery efforts. scattered across the region
Evacuation orders, safety and with limited access or means
health hazards, or damaged to reach the institutions’
infrastructure (e.g., washed- facilities. To address this, some
out roads, collapsed bridges, institutions arranged alternate
and downed power lines) may transportation methods, e.g.,
prevent employees from timely carpools, bus services, and air
reporting to assigned locations, connections. Some institutions
despite their best efforts. also developed plans to shift and
transport employees either from
You may want to identify or into affected areas.
alternative, prioritized gathering
place(s) for employees to meet Lesson Learned – People
after a disaster. Similarly, you are essential to the
may want to develop multiple, recovery of operations.
alternate, prioritized contact
arrangements for employees to
follow if they are unable to reach What about my family?
their assigned location given Employees’ foremost priority
the likelihood of simultaneous will be the safety and welfare
communications disruptions. of themselves and their

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

families. You may want to have obtain basic necessities. Some

discussions in advance with institutions reported that they
employees regarding their have developed short-term and
personal plans in the event of long-term plans for meeting
a disaster. You may also want essential human necessities
to tell them what steps will be to encourage employees to
taken to provide for employees remain in the area(s) where the
and their families who might institution is operating and so
need to stay in a disaster area or that employees can focus on
at a back-up facility. resuming financial operations.
These plans addressed supplies
Is everyone okay? and services such as:
A widespread disaster can • Food, drinking water, and
overwhelm medical services. safe lodging
Besides keeping basic first aid
supplies stocked and easily • Vital supplies such as
accessible, you may want medicine, clothing, etc.
to make preparations for • Child care, especially if
employees who have special schools are closed
needs. Catastrophic events not
only cause physical injuries, Lesson Learned
they also create very stressful – Replacement supplies
situations. Your employees may may be difficult to obtain
feel considerable stress after a during a protracted
disaster for an extended time. recovery period.
What basic necessities will
people need? How do we obtain more
Damaged infrastructure, supplies?
disrupted support services, and A widespread disaster can
a prolonged disaster recovery severely disrupt normal support
period can make it extremely services and cause a prolonged
difficult for employees to recovery period. Most

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institutions’ disaster recovery of routinely used forms, some

and business continuity plans institutions maintained a master
provide sufficient supplies at set of routinely used forms at an
the primary operations center alternate but easily accessible
and the back-up site to permit site.
several days of operation.
Employee safety is of
However, obtaining replacement
paramount importance and
supplies as initial stocks are
should carefully be considered
exhausted can be difficult as
in deciding whether to attempt
stores may not be open, and
temporary repairs. However,
new shipments may be delayed
some institutions found it
due to transportation delays or
useful to maintain some basic
damaged infrastructure.
supplies such as tarps, plywood,
Some institutions reported tools, etc. to board up broken
that they instituted long-term windows, prevent water
arrangements to replenish basic leakage from exposed roofs,
supplies such as business forms etc. Demand for these materials
and fuel over an extended will surge and may be in short
period, although this process supply following a widespread
can encounter unexpected disaster.
obstacles during an emergency.
Lesson Learned – Financial
For example, some institutions
contracted to have replacement institutions’ facilities could
fuel and other supplies delivered be damaged or destroyed,
as existing stocks were depleted. creating a need for
However, military personnel, alternate facilities.
law enforcement officers, or
rescue workers had priority in
some cases for these supplies, If our facilities are not safe,
especially fuel. Consequently, what alternate facilities could
you may want to consider this we use?
possibility in your planning. Facilities should be safe prior to
With respect to replenishment allowing personnel to re-enter

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

the premises. A professional of agreements in place prior

inspection may be necessary to a disaster could significantly
or advisable as some types of improve your institution’s ability
structural problems are difficult to resume operations more
to detect. An inspection of your expeditiously and efficiently after
sites may determine that the a catastrophic event.
damage to these premises is
Some disasters can affect
so severe that it is not safe to
a large geographical area.
resume business operations at
Technological advances in
those locations.
warning systems enabled
Your risk assessments and financial institution managers to
planning should contemplate activate disaster recovery and
that your facilities may not be business continuity plans 72
available, and that alternate to 96 hours prior to Hurricane
facilities arrangements Katrina making landfall. Before
may become necessary. deciding which alternative
Some common substitute to pursue, most institutions
accommodations arranged by monitored and/or tracked the
institutions in the aftermath predicted path of any adverse
of Hurricane Katrina included conditions; thereby enabling
renting undamaged buildings personnel to select a location
or leasing mobile units. Also, a less likely to be affected by the
number of financial institutions potential disaster.
entered into “partner institution”
or “buddy bank” agreements. What procedures do we
These included organizations follow to establish temporary
opening shared facilities facilities?
and unaffiliated institutions You may want to determine
granting affected institutions in advance what types of
access to teller stations. Other building inspections and permits
institutions executed reciprocal are required for temporary
agreements where IT systems facilities and to maintain
were shared. Having these types contact information for the

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governmental authorities that may want to reassess its location

have jurisdiction over these and the probability that it may
matters. Federal and state bank be affected by the same risks that
regulatory agencies expedited threaten your primary locations.
or waived many application In addition, you may want to
procedures for establishing a provide your primary regulator
temporary facility after Hurricane the names, alternate telephone
Katrina. numbers, and addresses of
personnel to contact if evacuation
Lesson Learned – The and/or disaster recovery plans
location of any back- have been activated.
up site can be critical
to successful recovery Do the recovery facilities have
efforts. sufficient capacity?
The number of institutions
affected by Hurricane Katrina
Where should the back-up site
created unexpected demands
be located?
on some servicers’ back-up sites.
In the aftermath of Hurricane You will want to ensure that your
Katrina, data recovery efforts for back-up facility has adequate
some financial institutions were capacity to process transactions in
hampered by limited access a timely manner.
to back-up sites that were in
close proximity to the primary In assessing this capacity, you
location. Institutions with may want to consider not only
back-up sites reported that they the needs of your customers in
found them most useful when an affected area, but also the
they were located sufficiently far demands that other affected
away so as not to be affected institutions may place on a given
by the same infrastructure back-up site or servicer. You may
and other risk elements as the want to reassess processing
primary operations center. capabilities and joint testing of
your recovery plans with your
If you have a back-up site, you servicer.
Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

How do we assure that we will Depending on their capacity,

have electrical power? these machines usually can
Many financial institutions’ provide power for critical
primary and back-up facilities operations, but typically should
lost power in the aftermath not be used to meet all electrical
of Hurricane Katrina because needs.
the power transmission grid You also may want to consider
was not operational. It is not appropriate locations for
uncommon for all of a financial operating a generator and
institution’s facilities to be on for storing fuel. Fuel storage
the same power transmission containers and generators
grid. Therefore, you may want can leak, and generators
to check with your local power may produce deadly carbon
company to determine how monoxide gas and can be
it supplies electricity to your subjected to the same damage
primary operations center and that the site experiences.
your back-up site(s). If the same
source supplies electricity to both Lesson Learned –
sites, you may want to consider Processing transactions
an alternate location or explore may be extremely difficult.
the feasibility of installing an
independent power supply at
one of the facilities. How can we overcome
difficulties in processing
What about back-up power transactions electronically?
sources? The widespread power and
Many institutions affected by telecommunications outages
Hurricane Katrina used portable after Hurricane Katrina hindered
generators powered by gasoline electronic transaction processing.
or propane as a primary back-up Most institutions had multiple
power source. Some institutions types of back-up and timely
pre-wired generators for their back up of data, which assisted
most important equipment. in recovery of applications

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and business resumption. In shipments of cash prior to

some cases, however, manual the expected onset. These
processing was required. institutions also reported the
While this may be a short-term need to plan for enhanced
solution, connectivity with the security precautions.
data processing facility is critical
in order to restore and sustain What if the vault and/or ATMs
routine financial services. If are damaged?
telecommunications cannot be Damaged vaults and ATMs
recovered, transaction items were significant concerns for
must be physically transported some institutions affected by
to other processing sites. Hurricane Katrina. Currency
Lesson Learned – Be can be damaged or ruined by
water or pollutants. You may
prepared to operate in a
want to keep vault cash in clear,
“cash only” environment. waterproof bags to minimize the
possibility of contamination from
Why would we need more standing water.
cash? Lesson Learned – The
Power and telecommunications financial industry is
outages can disrupt all electronic dependent on numerous
forms of payments, such as critical infrastructure
debit and credit card payments. sectors that potentially
Customers and employees have competing interests.
remaining in, or evacuating
from, affected areas may need
unexpectedly large amounts of What is our level of priority for
cash to pay for critical goods overall disaster relief efforts?
and services. In anticipation of
While the financial system
hurricanes or other disasters
is recognized as a part of the
with advance warning, some
critical infrastructure3, financial
financial institutions developed
3 Refer to the USA Patriot Act of 2001 and the Critical Infra-
plans for ordering larger structure Protection Act of 2001.

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

institutions have to compete dhspublic/display?theme=11&co

with the restoration of other lntent=3138.
critical components during
Lesson Learned – A
recovery efforts. Some financial
institutions have joined regional financial institution’s
coalitions to facilitate critical involvement in
infrastructure planning efforts. neighborhood, city,
By anticipating and addressing state, federal, and non-
such issues in advance, you profit or volunteer
can better prepare your staff to programs can facilitate a
overcome unexpected obstacles. community’s recovery from
For example, obtaining a catastrophic event.
additional cash (a critical
commodity in an affected
area) can hinge on whether How can we work with other
telecommunications and programs?
electrical services have restored The Department of Homeland
power and processing capability Security recognized that non-
to institutions or ATMs, the governmental organizations,
transportation authorities have such as non-profit, volunteer,
reopened traffic routes, and the and private sector entities, play
petroleum industry has provided a fundamental role in response
fuel so armored couriers can and recovery efforts. These
enter and leave disaster zones. organizations can contribute in
ways that are, in many cases,
You may want to contact local
key to a community’s successful
and state officials to understand
recovery after a catastrophic
the priority that will be given to
event4. You may want to contact
financial institutions to restore
local chapters of these entities to
critical services. You can reach
discuss ways the organizations
your state homeland security
might work together to benefit
contact at
the community.
4 More information on the TSP Program is available at

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What can regulatory agencies Emergency Agencies

do to assist us? American Red Cross
During the past hurricane
(202) 303-4498
season, the regulatory agencies
communicated with the industry NOAA National Weather
and the public through a variety Service
of media, including television
and radio broadcasts, websites, (301) 713-0622
and national call centers. You
may want to maintain a list of Operation Hope
regulatory points of contact and
reference data to establish clear (888) 388-HOPE or (888) 388-4673
lines of communication between
Ready America
your institution and primary
regulator. A current list of some (800) BE-READY or (800) 237-3239
important regulatory telephone
numbers and website addresses The Salvation Army
is included in this booklet.
(202) 289-4001

Department of Homeland
(202) 282-8000

Federal Emergency
Management Agency
(800) 621-FEMA or (800) 621-3362

- Photos are courtesy of USGS, NSF, NPS,

NOAA, and the Los Angeles County Fire

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

Federal Regulatory State Regulatory Agencies

Agencies Alabama State Banking
Federal Financial Institutions Department
Examination Council (334) 242-3452

Federal Deposit Insurance Alaska Dept of Community

Corporation and Economic Development
(877) ask FDIC or (877) 275-3343 (907) 465-2521

Arizona Department of
Federal Reserve System
Financial Institutions
(202) 452-3000
(602) 255-4421
National Credit Union Arkansas State Bank
Administration Department
(703) 518-6300 html
(501) 324-9019
Office of the Comptroller of
the Currency California Dept of Financial Institutions
(202) 874-4700
(415) 263-8555
Office of Thrift Supervision Colorado Division of Banking
(800) 958-0655 or (202) 906-6000
(303) 894-7575

Connecticut Department of
(860) 240-8299

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State Regulatory Agencies Hawaii Division of Financial

- continued Institutions
DC Department of Insurance, (808) 586-2820
Securities and Banking Idaho Department of Finance
(202) 727-8000 (208) 332-8000

Delaware Office of the State Illinois Dept of Financial

Bank Commissioner Regulation – Division of Banking
(302) 739-4235
(217) 785-2900
Federated States of
Micronesia Banking Board Indiana Department of
(691) 320-2015 Financial Institutions
Florida Office of Financial (317) 232-3955
Iowa Division of Banking
(515) 281-4014
(850) 410-9800
Kansas Office of the State
Georgia Department of Bank Commissioner
Banking & Finance (785) 296-2266
(770) 986-1633 Kentucky Office of Financial
Guam Department of
Revenue and Taxation (502) 573-3390
(671) 475-1817

Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

State Regulatory Agencies Minnesota Department of

- continued Commerce
Louisiana Office of Financial
Institutions (651) 296-2135
(225) 925-4660 Mississippi Department of
Banking and Consumer
Maine Bureau of Financial
(601) 359-1031
(207) 624-8570
Missouri Division of Finance
Mariana Islands Department
of Commerce (573) 751-3242
(670) 664-3008
Montana Division of Banking
Maryland Commissioner of & Financial Institutions
Financial Regulation (406) 841-2920
(410) 230-6101
Nebraska Department of
Massachusetts Division of Banking and Finance
Banks (402) 471-2171
=Government&L2=Our+Agencies Nevada Financial Institutions
+and+Divisions&L3=Division+of+ Division
(617) 956-1500 (702) 486-4120

Michigan Office of Financial New Hampshire Banking

& Insurance Services Department,1607,7-
154-10555---,00.html (603) 271-3561
(517) 335-3167

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State Regulatory Agencies Oregon Division of Finance &

- continued Corporate Securities
New Jersey Department of (503) 378-4140
Banking and Insurance Pennsylvania Department of
(609) 292-3420 Banking
New Mexico Financial banking/site/default.asp
Institutions Division (717) 787-6991
(505) 827-7103 Puerto Rico Bureau of
Financial Institutions
New York State Banking
Department (787) 723-8004
(212) 709-3501 Rhode Island Department of
Business Regulation
North Carolina Banking
Commission (401) 222-2405
(919) 733-3016 South Carolina State Board of
Financial Institutions
North Dakota Department of
Financial Institutions board/board.html (803) 734-2001
(701) 328-9933
South Dakota Division of
Ohio Division of Financial Banking
Institutions BANK-HOM.htm
(614) 728-8400 (605) 773-3421
Oklahoma State Banking
(405) 521-2782
Mt. St. Helens Oklahoma City, OK - 1998 San Francisco, CA - 1989 Hurricane Katrina - 2005

State Regulatory Agencies West Virginia Division of

- continued Banking
Tennessee Department of (304) 558-2294
Financial Institutions Wisconsin Department of
(615) 741-2236 Financial Institutions
Texas Department of Banking (608) 261-9555
(512) 475-1300 Wyoming Division of Banking
Utah Department of Financial (307) 777-7797
Institutions Conference of State Bank
(801) 538-8830 Supervisors
Vermont Department of (202) 296-2840
Banking and Insurance
(802) 828-3307

Virgin Islands Division of

Banking and Insurance
(340) 774-7166

Virginia Bureau of Financial

(804) 371-9657

Washington Department of
Financial Institutions
(360) 902-8704

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Emergency Contact Information

Neighborhood (Local) Contact

Name _______________________________________________
Work ____________________ Home ____________________
Address _____________________________________________
City, ST _____________________________________________

Out-of-State Contact
Name _______________________________________________
Work ____________________ Home ____________________
Address _____________________________________________
City, ST _____________________________________________

Emergency Notification
Who do we notify if something happens to you?
Name _______________________________________________
Work ____________________ Home ____________________
Email _______________________________________________

Emergency Contact Information

Doctor Name ________________________________________
Phone ______________________________________________
Police Phone _________________________________________
Fire Phone __________________________________________