The Ergonomics of Compliance
Mark's Note: Today's guest post is by Ryan Leach on a topic that I think is important, especially for hospitals — the idea of ALWAYS being ready for accreditation visits, surveys, or audits. Organizations should be ready every single day, rather than jumping through hoops and relying on heroic and special efforts to “get ready” every few years.
By Ryan Leach
Many industries face the compliance conundrum. The compliance conundrum occurs when staying in regulatory compliance interferes with business as usual operations. In highly regulated industries, where regulating bodies conduct periodic audits, the strain of the compliance conundrum is even more apparent.
Audits are unpredictable by nature. This unpredictability can lead to underprepared, or ‘knee-jerk', reactions to return us to a state of compliance when an audit is approaching. We try to minimize these knee-jerk reactions by operating in a state that is audit ready at all times. However, a lot of times this means periodically returning to a state of compliance rather than engineering a state of compliance.
Typically, ergonomics focuses on safety issues, where our interactions with systems and tools are studied and manipulated to reduce the strain on our bodies. The goal is to remove repetitive strain injuries, which are caused from exerting too much force or awkwardly positioning ourselves to complete tasks. We've all been told to lift with our legs, rather than our arms.
We see ergonomics applied to commercial products, such as gardening tools. We might see shovels or rakes that are marketed as more ergonomic, where the shapes of these tools are made to reduce the strain from using them.
Why not look at the strain of staying in compliance as an ergonomic issue?
The International Ergonomics Association breaks down the study of ergonomics into three areas: physical, cognitive, and organizational.
Physical aspects involve systems and procedures.
Cognitive aspects involve education and participation.
Organizational aspects involve management and teamwork.
In each area, we want to reduce strain.
For physical aspects, strain may be caused by additional time and effort needed to stay compliant. When the only tool you don't have is a hammer, every other tool starts to look like one. However, in regulated processes, the end doesn't justify the out-of-compliance means.
Many times, when we find ourselves trying to cut corners, we're doing it as a way to compensate for an inefficient or disorganized system. 5S can be used to organize an area, so that we have what we need, when we need it. SMED can be used to engineer the corner-cutting in a way that is compliant. Poka-Yoke can be used to corner-cut-proof a process.
For cognitive aspects, the strain may be caused by any additional mental processing needed to stay compliant. It takes less time to guess than to research an answer.
Visual Management can be used to show states of compliance vs. non-compliance to remove the guesswork. This also improves participation, as it creates a cognitive pressure when a system shows an out of compliance state. Good compliance engineering also removes the cognitive stresses of knee-jerk reactions.
For organizational aspects, the strain may be caused by unassigned ownership in areas of compliance. Plausible deniability is a quick way to avoid responsibility.
When compliance is built upon organized teamwork, the stress of compensating for others is removed. The success or failure happens as a team.
A lot of times, operating out of compliance is a result of short-term thinking. The stresses of an audit may not happen frequently enough to outweigh the short-term satisfaction of cutting corners. When it becomes less strenuous to stay compliant, we have successfully engineered compliance ergonomics.
About Ryan Leach: Ryan has a degree in Chemical Engineering and is the author of the ebook, The Mistake Economy. He explores the fundamentals of business and personal improvements at SimpleContinuousImprovement.com. You can find him on Twitter as @simplecimprove.