Writing Policy and Procedure Manuals in a Small Campus Police Environment
By Robert A. Johnson
After serving as a law enforcement officer in a large full-service police agency for nearly 40 years, the responsibility for writing policy for a small campus police environment seemed a unique challenge. My job required reviewing and revising existing policy, as well as creating some policies from scratch. What was not obvious in the beginning, however, was the extent that agency cooperation, planning, and organization would be critical to the success of the mission.
Crime fighting in a campus environment normally is category specific: the majority of offenses fall into three or four major categories. University police officers seldom must exhibit specific procedural knowledge of more than a handful of crimes. I found that writing policies in this environment required specificity with regard to agency requirements, as well as criminal law and procedure. The need to revise, update, and modify many old directives either procedurally outdated or compromised by existing law added to the scope of the mission. For example, policies regarding domestic violence, internal early warning systems, juvenile procedures, pandemics, criminal intelligence, homeland security, incident command, and bias-based profiling required frequent updates to remain consistent with current practices and law enforcement mandates. As a result, new procedures and reporting requirements became part of the revisions, necessitating frequent meetings with command and component personnel.
One expert describes the well-written directive as supplant to a system of best guesses, common sense, and good luck.1 Policy writers must establish consistency, responsibility, and standardization through well-written policies and procedures as this information will guide behavior and avoid agency sanctions. They must ensure they do not place the first responder in harms way, open the organization to liability, overdirect simple tasks, or saturate agency members with verbiage that does not facilitate further understanding of the subject matter.
A directive should be specific enough to impart agency procedure and capture the essence of current law yet remain flexible enough to allow for appropriate decision making. Therefore, policy writers must commit time to planning each directive and grouping of directives. Although the task can prove daunting at times, the following chronological steps may help the writing process proceed smoothly with minimal internal resistance and the best chance for success.
Before any writing or planning begins, the chief executive of the agency should prepare correspondence that will introduce the writer and reflect the job to be accomplished. Although this may prove one of the few times the chief executive will have direct involvement in the process, all agency members (sworn and civilian) must understand the purpose of the endeavor, the expectation of cooperation, and that the project enjoys the support of their leader.
Mr. Johnson, a retired captain with the Anne Arundel County, Maryland, Police Department, currently serves as a policy analyst with the University of Maryland, Baltimore Police Force.
Policy writers should acquire an organizational chart early in the process. The chart will become the basis upon which responsibility for work completion is determined. Therefore, it must be available, updated, and accurate.
Information acquired as a basis for constructing policy and procedure can come from various places. Old manuals, directives, special orders, pamphlets, memorandums, and training materials can facilitate a general understanding of how the agency has responded in the past to specific situations and mandates. Although the collection of static documentation can help policy writers, written documents do not replace one-on-one meetings with key personnel. Such meetings also can establish relationships not widely known or understood (e.g., as in the case of state regulatory agencies that mandate officer training or federal law that regulates the dissemination of law enforcement records). Information obtained from documents or meetings should become part of the written directive.
Additionally, the influence of standard operating procedures should be limited to standardizing work in an individual component; they usually should not be relied upon to construct written directives. Policy writers should spend minimal time reviewing them. Although their value in assisting with the acclimation of new employees should not be underestimated, the information is not interchangeable.
As a starting point, leaders should hold a meeting with command personnel who have the authority to require cooperation from agency components. This group should establish ongoing expectations, including dates and times for further meetings, timelines for completion, and discussions about the visual aspect of the written directive (e.g., one column versus two columns, double spacing, headers and footers).
Moreover, a policy writer should request a list of key agency personnel who can provide specific information, easily accomplished if the writer already is employed by the agency. However, if the writer was recently hired, leaders should appoint a sworn liaison officer to assist with information acquisitions.
One of the most frequent complaints about agency policy and procedure manuals involves the lack of subject-matter groupings that ultimately leads to frustration when attempting to find a particular passage or procedure. As a result, policy writers should consider grouping like subject matter and presenting the finished product as coherent and user-friendly.
Some agencies experience a lack of accountability for forms, including some rogue or unauthorized ones created by well-meaning individuals or components without benefit of organizational review. The resulting overload of forms and lack of control over the numbers and types of forms used makes it nearly impossible to keep written directives current. As a result, leaders should create a system for approving, numbering, and disposing of unauthorized forms.
Deciding what directives policy writers should write, update, or delete can become a time-consuming task. Leaders should network with agencies of a similar size to review their directives. Often, policies and procedures prove similar between agencies and may only require incidental attention, especially when the policy is consistent with the Commission on Accreditation for Law Enforcement Agencies (CALEA).
In addition, state law enforcement regulatory agencies and training commissions usually maintain resources to assist in policy making and often have sample written directives. Departments also can obtain an encompassing array of written directive topics from the International Association of Chiefs of Police (IACP) Policy Center.
The Writing Process
Policy writers should avoid the expression of abstract views, opinions, or verbiage that does not contribute to the understanding of the subject matter. Moreover, they should provide information in a straightforward, simple, and direct way that complements the discussion.
Because the finalized version of the policy and procedures manual likely will be available for citizen review, writers should avoid law enforcement slang or jargon. Further, the words shall, will, or must reflect mandatory action, and the terms should or may identify some level of personal situational choice.
Each written directive should introduce the subject matter through a statement of purpose followed by a statement of policy. The statement of purpose should offer a clear reason for the topic under discussion, and the statement of policy should provide a brief overview of agency philosophy. Policy is not synonymous with procedure or purpose; these two brief introductory statements are not interchangeable. Policy statements in each directive should begin with the phrase, “It is the policy of.…”
Normally, a numerical designation should identify each section of the manual. For example, if section 4 contains all agency directives on the use of force, every directive in that section should be designated as 4.1, 4.2, 4.3, and so forth. A Roman numeral should identify every major topic, which policy writers should further explain under subtopics identified by letters of the alphabet. All written directives should be numbered consecutively and include effective and revision dates, as well as the signature of the chief executive. A title page, contents section, and index portion also should be included.
Review, Revision, and Submission
The review process should include a senior staff member intimately familiar with the internal organization, as well as its crime-fighting activities. In some cases, the review process may involve several command staff officers, subject-matter experts, and specific component personnel responsible for accomplishing the work as outlined in the directive.
Minor changes to written directives occur over time as they are more widely viewed, and a change in one directive may require a change in others. Policy writers should present the final product to the chief executive for signature upon completion of the entire manual and not submit sections individually.
If agencies issue the manual as a hard copy, they should use a three-ring binder suited for holding the written directives. This way, each directive easily can be removed when changes occur. Additionally, they should consider establishing an accessible computer file or e-mail notification system or issuing a CD. For vehicles with mobile data computers, software programs exist that will monitor changes to directives and the associated accountability process.
Writing procedures and policy for campus law enforcement works best when preceded by proper preparation. Before policy writers begin, they must have a clear understanding of how the organization functions and how crime operations and administrative support operations mesh to accomplish the work of the agency. Procedures and policies must be clear and simple and contain accurate information sufficient to take any situation to fruition without leaving the agency open to civil liability or the individual vulnerable to agency sanctions.
Writing policy and procedures requires a commitment to a specific format that will permit a user friendly approach to finding information, assessing resources, reviewing, and revising. To that end, the chief executive’s authorization of the completed manual and the availability of the manual to all agency personnel will provide the basis for success.
1 Michael Carpenter, “Put It in Writing: The Policy Manual,” FBI Law Enforcement Bulletin, October 2000, 1-5.