Over-Compliance or ‘Too Much of a Good Thing’

“Someday when I get the chance, I am going to fix this process and ‘Do it Right’”.  The anal-retentives in the world cheer and the rest moan and grumble upon hearing this.  Luckily, that chance seldom comes and we can stay focused on ‘Real Work’.  Occasionally, we are forced to face the dilemma.  The Sarbanes-Oaxley Act, updates to FDA guidances, pending audits, new software, new manufacturing techniques demand we ‘Do It Right’.

 ‘Do It Right’ consists of two steps. 

• The first step is to design a process. 
• The second step is harder.  It consists only of following Step 1.

This sounds deceptively simple.  That is the problem.  The bait suggests the solution is obvious, but the trap is sprung when you step inside.  The outside pressure to ‘Take charge’ and ‘Manage the process’ mingles with enthusiasm and fear to create the contradiction. Remember, you will have to comply with the process at all times. It doesn’t end with submitting the remediation.  I have learned. ‘Doing It Right’ is never easy.  Although the journey is hard, there are some pitfalls to avoid.

 OVERSIMPLIFICATION 

• “The attendant needs to monitor every occurrence…”;
• “I must be notified every time”; 
• “The manager must review every event”.

These sound necessary and are tempting to invoke, The trick word is ‘EVERY’.  This word should be avoided. If Alerts are sent EVERY time, if reports are sent EVERY day, if the manager must review EVERY item, we diminish the importance of the event.  The choice becomes spending too much time sifting (Compliant but inefficient) or too much time ignoring (Non-Compliant).

 OVERCOMPLICATION

     Bad: Black, White, Grey, Light Grey, Dark Grey, Charcoal

    Better: Black, White, Other

 Limit the subjective choices.  The data becomes based on what mood the user is in rather than the status of the event / item / step.  Inconsistencies of choices are a waste of time.  Use smaller categories only if ‘Other’ becomes too large to manage.

 APPROVAL ZEAL

Many approval rules are based on good intentions like “We cannot blindside management”; “Management must be involved”;  or “We need another set of eyes”.

If one approval is good then more is better. I have seen approval processing crawl at a snails pace from the originator, to the manager, to the director, to the VP, to the compliance VP, the CEO and then back down again. This is necessary for some things like going to war, selling a business, building a new plant, but not for office supply purchases or daily IT checklists. We do not want to require micro-management with our processes.  I believe in graduated approval levels and monthly status/performance reports.

 BLIND OBEDIENCE

“We don’t have time to do it ourselves”. Outside resources can help jumpstart your project and help define your processes.  They can assist you while your employees are doing ‘Real Work’.  They may have created the process hundreds of times while your group has never attempted it.  By virtue of experience and training they are experts in their fields, but they are not experts in your business.

 If you need outside help, get it.  Just do not accept everything they say verbatim.  You must prepare for a dialogue with your expert.  Understand the rules and push back when something doesn’t fit your organization.  Explain what is wrong and work together to find a solution that works best with your company.  You will have to comply with the process. You will have to explain it to the auditors.  It won’t matter if your expert understood it.  You have to understand it.

 OVEREXUBERANCE

 Don’t let your enthusiasm bulldoze everyone around you.  Just because it is obvious to you, doesn’t mean it will be embraced by your peers.  Take your time and work the issues.  Keep it as simple as you can get away with. Be generic if possible.  Your wording can become a requirement instead of the suggestion it was meant to be.  Ask “WHY” a lot.

 Go over it and over it and over it again.  Remember, you will have to live with it.

 …wc