Developing Response Procedures to U.S. DOS Travel Warnings

March 22, 2010

By: Joanna Holvey Bowles, IFSA-Butler, Julie Friend, Michigan State University, Ines DeRomana, University of California

Authors' disclaimer: This resource is intended to provide advice and guidance to institutions or organizations interested in developing a review policy in response to U.S. Department of State Travel Warnings, it is not meant be interpreted as setting new standards for the field of education abroad.

On Sunday, March 14, 2010, the State Department issued a Travel Warning for Mexico. The National Security Council Spokesman Mike Hammer issued a statement about the murders of three people associated with the United States Consulate General in Ciudad Juárez, including a U.S. citizen employee, her U.S. citizen husband, and the husband of a Mexican citizen employee. Even though the FBI continues to investigate the backgrounds of the victims, the FBI has indicated that there is no evidence that the people who were killed in Ciudad Juarez were singled out because of their employment by the U.S. government or their U.S. citizenship.

While the text of the warning applies to specific geographic areas of Mexico, we know that university officials will interpret this in multiple ways. It is our intention to provide advice to you while recognizing your need to balance this with the policies of your own institution.

Deciding whether or not to send students to countries with a U.S. Department of State Travel Warning is a delicate matter on many campuses and in many organizations. The level of risk that an institution is willing to accept is a management decision - and there is no right answer to this question. For those that have inflexible blanket policies (Travel Warning = no travel), decision-making is relatively straight-forward, even if the result may not be palatable. Some institutions/organizations do not have any policies or restrictions tied to Travel Warnings. Other institutions/organizations, however, have developed flexible policies that trigger a review process when a Warning is issued. To do a thorough review, however, requires significant time and effort, which if harm is imminent, could put students, faculty/staff, currently abroad, at risk. Therefore, it's important to develop review criteria well in advance of need. Following are suggested guidelines to understand (or determine) your institution's tolerance for risk.

Suggested Guidelines

  1. This step must involve a variety of stakeholders at your institution because it is critical that everyone understands what the organization's/institution's risk strategy is as everyone has a role in effective risk management. Your stakeholders may include, but are not limited to, the president/provost, governing board/board of trustees, risk management, general counsel, international education/study abroad, undergraduate/graduate education, student health services, student life, etc. Some key considerations include, the ability to assess risks (in general and in a crisis), the preparedness for/response to emergencies (including evacuation), and whether or not travelers are required to have international health insurance coverage, whether or not your underwriter covers claims occurring in a country with a Travel Warning, the amount and availability of emergency funds, etc.

  2. Collect data on student enrollment abroad. List the location and duration of programs in the area of concern, and the number of students in each place. (We find it helpful to plot this out on a map). Note the type of accommodations, partner institution, and consider daily activities that involve risk – taking public transportation, for example (which may be high or low risk, depending on the location, time of day, and type of transport). List what type of programs your students are enrolled in (direct-enrollment, provider, faculty-led, branch campus, etc.) and what type of activities they are engaging in (classroom time exclusively, cultural activities, excursions, internships, service learning, research, etc.). This will help you consider what type and level of support are available if a problem occurs and any risks associated with student engagement, which can vary greatly by location. For example, on its face, an NGO internship located in a township seems high risk, but if the project is of high-value to the community and the employees/volunteers well-regarded by area residents, safety may be assured by community members. Also consider the participants' maturity, language ability, ties to community, flexibility, and readiness to respond to emergencies, etc.

  3. Contact relevant partners abroad, if not during your planning process (as part of your general emergency preparedness procedures) then now in your assessment phase. Discuss what risks are of concern, what their risk culture is, what steps are being taken, and resources used, to mitigate such risks, and what their emergency response plan is. Be prepared to accept that your institution and your partner abroad may have different risk cultures and a different perception of what constitutes a speedy response to a crisis. Understand that there are subjective and objectives views of risk so you must consider risks and risk management when choosing a partner to minimize the potential of vicarious liability (if you are offering a joint activity) and the public relations consequences for perceived less-than-adequate decisions of a partner. Understand that between total safety and absolute danger, we all reach a level of safety that is acceptable. (Regarding the Travel Warning issued for Mexico, remember that our Mexican colleagues have been dealing with local risks for a long time. Some institutions have developed sophisticated information networks, communication protocols and emergency plans. Don't reinvent the wheel if you don't have to!)

  4. Contact any students, staff or faculty abroad as soon as possible to inform them of the Warning (hopefully, their travel was registered with the State Department, so they received an e-mail from the Embassy already), and report that you have consulted with your local partners and are in the process of a safety and security assessment. Indicate your decision-making timeline and to whom travelers or their families can direct questions. You may also wish to prohibit travel to cities or states mentioned in the Travel Warning, adding that the penalty for doing so could be dismissal from the program. Most importantly, elicit student input. Does he or she feel safe or unsafe? Why or why not? What personal measures to they take to feel safe, etc?

  5. Compare student activities and program locations to the risks outlined in the Travel Warning (or other information that has caused you to evaluate the program). Note any overlap and consider whether or not such risks can be reasonably mitigated by changing the program's location, altering an itinerary's route, selecting a different mode of transportation, eliminating certain activities, adding staff, restricting student free time, enacting curfews (undesirable and often difficult, but not entirely impossible), etc. Understand that there may be no ways to reasonably mitigate risk without compromising the academic goals of the program. In this case, you may need to return to step one. We really are talking about managing the risk to an acceptable level, not eliminating it. Decide when and where your institution can take an educated risk by analyzing your institution's tolerance for risk and how prepared it is to respond to an emergency resulting from dangers/risks outlined in the Travel Warning. Be sure to allow yourself the leeway to change your course if conditions change. It is highly recommended to develop a list of tripwires that would trigger a review the program/location.

  6. Know how you will communicate about risks with your constituents (students/parents/spouses). Be clear with students (and parents), from the start, about your institution's approach to risk (you warn them of risks, advise them where to get information, give them information, etc.) to allow them to make informed decisions about participation. (This goes back to step 1).

  7. Determine the likelihood of imminent harm and the availability of “escape routes” as the likelihood increases. For example, the invading Russian army en route to Tbilisi in August 2008 coupled with the closure of the airports and the arranging of U.S. government convoys to Yerevan, Armenia, made it seem likely that harm was imminent.

  8. Once your institution/organization has made a decision and all relevant stakeholder have had a chance to provide input, (also recognize that your decision may vary between programs in the same country), work with your public relations and general counsel offices to craft a clear and concise message that outlines your due diligence. Be sure to include a reference to your refund policies, and be prepared to respond to those who disagree with your position. Prepare talking points in advance paying as much attention to the process for communicating with stakeholders as you do to explaining the content of the information; work with your campus risk manager and legal counsel.

This process that must be tailored individually to each organization/institution, appears difficult and time consuming the first time you implement it, and often is, but it becomes more streamlined over time.