May a school make disclosures under FERPA’s health or safety emergency provision for emergency preparedness exercises?

No.  Disclosures made under the health or safety emergency provision must be “in connection with an emergency,” which means it must be related to an actual, impending, or imminent emergency, such as a natural disaster, a terrorist attack, a campus shooting, or the outbreak of an epidemic disease. 

K-12 School Officials
Postsecondary School Officials
Exceptions - Health and Safety Emergency