Understanding Limitations of NIMS

By Charles Bailey

Firefighter walks through floodwater after Katrina
AP Photo/Eric Gay
'Where NIMS begins to break down is when the incident has no known end such as Hurricane Katrina.'
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If I always appear prepared, it is because before entering on an undertaking, I have meditated for long and have foreseen what may occur. It is not genius which reveals to me suddenly and secretly what I should do in circumstances unexpected by others, it is thought and meditation.
—Napoleon Bonaparte, 1812

Success during a major emergency or even disaster is difficult to define and infinitely more difficult to measure. An earthquake strikes a populated area, hundreds are injured, scores die, and there are millions of dollars in damage. How do you look back on that and say, from an emergency services perspective, that we were successful? Complicating matters for emergency services are the twin notions of planning and preparedness. There is a sense that the quote by Napoleon is actually achievable. But we cannot disregard the roles of luck, chaotic event progression and immeasurable outcomes — it is not all about thought and meditation alone.

The National Incident Management System (NIMS) has promised, be it implicitly or explicitly, to provide an "all hazards" planning and thought process equally applicable across the entire domain of disaster events. Underlying the notion of NIMS are Western industrialized beliefs; that the universe and all things in it are controllable if only one can find the right system and people to control it. That NIMS focuses on control is evident in the strictly hierarchal organizational structure that it uses.

A second, equally critical notion underlies NIMS: that future states of being can be predicted. When dealing with simple and/or linear systems such assumptions are probable. For example, a chemist adding 3 moles of one well known chemical to 2 moles of a second well known chemical under standard temperatures and pressures can reasonably predict what will happen. However, disasters are by nature non-linear and they often defy linear behavior. But the notion of control fails in other ways; "Command and control of disaster doesn't work. It never has."1

Product of evolution
NIMS was not created in a vacuum. It was the product of evolution; taking a hodgepodge of response paradigms, mainly from in the wildfire arena, and merging them into a cohesive thought process. It is derived partially from a need to assert control, even when the world and the people in it may not be controllable. This control begins with a series of groupings that draws similarities (perhaps affinities is the better word) between all types of emergencies. In essence, if all emergencies are essentially the same, then my approach to each can be the same. This provides comfort as I have seemingly brought the incomprehensible event into the realm of a known, predictable quantity.

All-hazards planning assumed that for the purposes of emergency management, many kinds of catastrophes could be treated in the same way: earthquakes, floods, industrial accidents, and enemy attacks could be brought into the same operational space, given their common characteristics. Needs such as early warning, the coordination of response by multiple agencies, public communication to assuage panic, and the efficient implementation of recovery processes were shared across these various sorts of disaster. Thus all-hazards planning focused not on assessing specific threats, but on building capabilities that could function across multiple threat domains.2

Planning is predicated on prediction, which is by nature knowing what some future state of being actually looks like. Preparedness is predicated on planning and on the extension of planning that says I can actually do something about what is about to happen, what is happening, or what just happened.

However, the fail point is the wholesale adoption of the affinities. As Lee Clarke offers, "… the attempt to establish an affinity between the civil defense actions required to cope with localized natural disasters and the civil defense necessary to deal with nuclear war or accidents is essentially a fantasy."3 The assumption that all hazards are essentially the same is flawed. It then derives that an "all-hazard" approach based on such affinities is also flawed.

A natural extension of industrialization is rationalism: they go hand in hand. There are limits to rationalization, especially as evidenced in planning: "The usual way is probabilistic thinking and in the modern day it has become equated with rationality itself. Possibilistic thinking, by contrast, emphasizes potential consequences over the likelihood that some event or events will happen."4

Major incident
I recently had the pleasure of working on a major incident with a team of gifted players well versed in the application of NIMS for planned events. This was a group of people who teach NIMS, travel the country as members of incident management teams (IMTs). They had electronic forms that I found baffling. They understood and practiced the planning process to near perfection. Their end product was a 50-plus page incident action plan (IAP) that left very few stones unturned.

After being a part of that process, I had a few personal observations about NIMS.

I think that the adherence to NIMS structure was ceremonial in nature. When I say ceremonial, I don’t mean that people were just going through the motions. They were thinking, and thinking hard. They pushed themselves to go outside the box and consider a full range of possibilities. However, strict adherence to processes such as a "Planning P" were actually detrimental to the strong debate and dialogue necessary to flush out planning inconsistencies. It was as if we became slaves to the forms and to the briefings, losing our collective ability to really think about what was happening. Some of the items brought up for discussion might have had better outcomes if the discussions had been allowed to continue.

What I noticed about how NIMS was implemented for the planning process was that there was an infatuation with the process. NIMS-based planning was somehow transformed from being the framework of its original intent into the actual point of meetings.

We had no major emergencies during the actual event. There was no requirement for cooperation, communication or coordination between the multiple agencies, and for that reason it would appear as if the structure worked. The question is whether or not it would have worked under stress. The general consensus was a sigh of relief that NIMS had worked.

I am still not convinced that NIMS is useful for the urban environment with its complex interlocking systems. I am convinced that it has not been and will fail to be an effective tool for the management of an exponentially expanding event. NIMS processes are too linear, hierarchical and cumbersome for the large-scale evolving event.

NIMS has only demonstrated its utility in limited circumstances: 

  • When the possible outcomes are limited by scope, complexity, and/or geography.
  • When the planners have had experience in similar circumstances of the same scope, complexity, and/or geography.
  • Before an event actually occurs, when the scope, complexity, and/or geography are limited and the possibility of adverse actions is limited i.e., a large parade absent the threat of terrorism.
  • In the decay phase of an incident not limited by scope, complexity, and/or geography, where recovery is the main focus.

While some would argue with me on the above points, I think they will be hard pressed to find literature to support the effective use of NIMS methodologies for rapidly expanding events. So while federal mandates compel us to use NIMS-based approaches, I think we would be wise to understand the limitations of NIMS and to create and employ more effective mechanisms for managing incipient incidents experiencing — or with the potential for — exponential growth.

Large-scale wildifires
It would appear that NIMS works for large-scale wildfires. I would argue that those events are within the realm of the known. Typically these fires are not in populated areas; they are limited by the boundaries of the forest, and they do not cause catastrophic loss of critical infrastructure. In other words, the problem can only get so big. People are impacted but not on a large life and death scale and commanders can communicate easily.

NIMS also seems to work on a very small scale at the average structure fire or accident scene. The critical point to make here is that any system of management would work at these events because they are limited in scope. Three houses on fire at one time is a big deal for the people who live in those houses but in the scheme of disruption of everyday life those fires are hardly noticeable. The typical resource allotment for a structure fire could be easily handled by a single commander or by a commander with one or two subordinates.

Where NIMS begins to break down is when the incident has no known end such as Hurricane Katrina and 9/11, or when the scope is beyond the imagination of planners. No one has yet to prove the utility of this system during rapidly expanding events with no clear sense of scope, either in magnitude or time. It comes back to the fact that disasters are not linear events but that NIMS is a linear system. "Systems functioning in chaotic regimes may show a tendency to be highly sensitive to their initial conditions. This means that small changes or errors can have amplified effects."5 In situations of rapid expansion that are sensitive to initial conditions, the systems used to respond necessary have to be non-linear and based on supporting the self organizing that the literature supports will happen anyway.

This is not to say that NIMS is not important. The commonality of language and structure that NIMS offers is far superior to any ad hoc system of large incident management. NIMS also allows for outside people to move into a scene and overlay a sense of continuity, cohesion and order to chaos. NIMS can bring order when chaos has died of its own accord. NIMS cannot bring order to active chaos.

Punch in the face
To quote a less obvious source, Mike Tyson once said, "…everyone has a plan until they get punched in the face." This too is true of planning for fire department operations. Our punch in the face may be an IED in a crowded mall or three simultaneous three-alarm fires. Either way our planning processes can only go so far. The solution to an effective response is to create a force capable of operating with minimal direction under a set of simple and clear objectives laid out in advance by our leadership. This idea applied to event planning would be restated to say that the plan has to be so simple and so clear in intent that any firefighter in the field can understand the objectives and know how to develop strategic and tactical approaches to the problems they face.

What I notice is that field personnel in the urban environments I know do not find the NIMS processes to be as intuitive as the planners do. They wanted simple plans in simple words. It was and remains difficult to translate what was a superbly done incident action plan (and it was a fine document) into terms that made it useful to the people charged with making the plan work.

Most people will agree that we will fight the way that we train, and we train to act under the guidance of standard operating procedures for a few minutes and then under the command of a chief who will dictate all further actions. We may ask our unit officers to manage groups or divisions but usually for small events of limited scope. We almost never ask them to lead a multi-agency task force and we don’t train for such things. It stands to reason they would be confused when suddenly tasked in such a way.

I do not write to discourage the use of NIMS but rather to challenge planners and commanders to understand the limitations of NIMS much like they understand the limitations of the personnel and materiel. NIMS is a response framework that provides guidance but it is not a sacred document. It must be modified when modification is necessary to secure the greater good.


1) Lee Clarke's Worst Cases

2) Andrew Lakoff, From Disaster to Catastrophe: The Limits of Preparedness

3) Lee Clarke, Mission Inprobable

4) Lee Clarke, Understanding Katrina

5) Gus A. Koehler, What Disaster Response Management Can Learn From Chaos Theory

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