Public school districts in Buffalo, USA and Toronto, Canada reviewed their safe schools policies in 2008. Revised Codes of Conduct are compared to earlier versions and each other, and a conceptual policy web is used to understand how local, state/provincial, national, and international influences affect local safe school policies. The comparison demonstrates that while influenced by international beliefs about unsafe schools and youth violence, affected by local social, economic, and historical contexts, and constrained by state/provincial and federal policies, local school districts are nevertheless able to exercise some agency. The study also highlights the importance of Ontario's Human Rights Commission as a policy actor, and suggests zero tolerance for non-serious incidents may be practised in Buffalo schools. This finding and the continued practice of excluding students from schools in both districts as a discipline approach casts doubt on the sincerity of governments' commitments to evidence-based policy in education at all levels. Contributions of the conceptual policy web for policy analysis are discussed.