Multihazard EOP development & review for Texas districts
Every Texas district and public junior college must adopt and implement a multihazard emergency operations plan — TEC §37.108(a). After the 2025 session, a plan that was compliant two years ago is behind on its face: a missing sixth phase, outdated response terminology, no extracurricular provisions. We build and repair EOPs against the law as it reads now.
First, the citation most vendors get wrong
The multihazard EOP requirement lives in TEC §37.108(a) and (f) — §37.109, which some materials cite, is the School Safety and Security Committee statute. The distinction matters beyond pedantry: the EOP is a component of the same section that governs your three-year audit, which is why EOP quality shows up as audit findings. A vendor who miscites the statute is telling you how closely they read it.
What §37.108(a) requires of the plan
The plan must address all six phases and provide for, among other things:
- Employee training — explicitly including substitute teachers
- Classroom access to a telephone or electronic communication device
- Communications infrastructure using standardized response protocol terminology coordinated with the TxSSC
- Mandatory drills under TEC §37.114, with SB 57 accommodations
- Coordination with state health services and local emergency, law-enforcement, health, and fire agencies
- Implementation of the §37.108(b) safety and security audit
- Any other requirements established by the Texas School Safety Center
What changed in 2025 — the update checklist
| Authority | What your plan must now reflect |
|---|---|
| HB 121 | The plan must now address six phases — prevention, mitigation, preparedness, response, reunification, and recovery. Reunification is the new one, and it is the phase most existing plans handle worst. |
| HB 121 | EOP provisions for safety at extracurricular activities, against standards set by TEA — the implementing rules were adopted into 19 TAC in July 2026, so this is now concrete, checkable content. |
| HB 121 | Emergency response maps must be provided to every applicable emergency services district — not just to local police and fire. |
| HB 33 | Communications provisions must use standardized response protocol terminology developed in coordination with the TxSSC — plans using homegrown lockdown language need reconciliation. |
| SB 57 | Drill provisions must accommodate students with IEPs and 504 plans, and the safety and security committee gains special-education representation. |
Primary sources: the TEA correspondence School Safety 89th Legislative Updates and the enrolled bill texts at capitol.texas.gov. Plain-English summaries of each law are in our school safety law library.
Three ways to engage us
- Gap review. We read your adopted plan and annexes against current §37.108(a) requirements and the 2025 changes, and deliver a findings memo your safety committee can work from — fast, bounded, and often the only engagement a district needs.
- Full development. For plans too old to patch, we build the multihazard EOP with your safety and security committee — six phases, annexes, drill program, and the coordination documentation §37.108(a) expects.
- Audit-cycle bundle. The EOP is assessed inside your three-year audit anyway; reviewing it in the same engagement fixes findings before they become findings.
Why this pairs with the audit
The records review portion of the 2026–2029 audit methodology examines the EOP and its annexes directly — phases, terminology, drill logs, coordination records. Districts whose plans are current walk into the audit with their largest documentation category already clean. Districts whose plans are stale meet the same findings twice: once in the EOP review, once in the audit report.
Get your EOP reviewed before it becomes a finding
Send your entity type and campus count. A gap review is the fastest way to know where your plan actually stands.
We respond to every inquiry the same business day in most cases.