A Management System – How formal does it have to be?

In my last post I talked about the Legionnaire’s disease in the Bronx this summer.  I followed the health department investigation unfold on the nightly news.  There were several likely suspects and  it wasn’t long for the cause of the outbreak to be determined to be a cooling tower on the roof of a new hotel with modern air conditioning equipment.  Very unfortunately twelve people lost their lives and many others were sickened, because the Legionella bacteria was allowed to grow in the warm, moist micro-environment of the air conditioning cooling tower.  We frequently talk about “living on the edge” in this blog and almost always in a way that begins with a person proactively deciding to take that chance and “live on the edge” as it were.  Many who practice this type of behavior strongly argue that it is their choice to do so and that this self determination should be the end of the story.  In previous blog posts I have countered this argument by indicating that frequently what one person decides to do can have catastrophic outcomes for others around them.  That was the situation forthese poor victims in the Bronx.  They had no idea that the air they were breathing contained the bacteria that would soon sicken or kill them.

I posited that the root cause of this situation was the lack of a formal management system.  Although hotel personnel were quoted in the newspapers saying that they followed recommended maintenance procedures they did not have records that indicated the last time the cooling tower was tested or cleaned.  The reason for a lack of records is a lack of a formal management system.  I can see the eyes rolling on many of you who are reading this now.  Formal management systems have become synonymous with large volumes of paper, binders of procedures that are too hard to follow, records that are kept only to gather dust and hours of wasted productive time.  Perhaps this commonly held view point has formed because of the demands that are put on organizations who would like to be certified to international standards such as ISO 9000, the quality management system, QMS, standard or ISO 14001, the environmental management system, EMS, standard.   It is true that there is a fair amount of effort to be invested in building a management system to one of these global standards,  especially if there is little formal material to start from.

As I think I have indicated before I might come to view formal management systems with a somewhat biased view.  I have witnessed building a QMS, and later an EMS, where as a result drove a dramatic improve in results.  As is typically the case in big organizations, I once had a product allocation assignment that didn’t have an obvious home in the bureaucracy and so I was assigned to temporarily to the quality group.  This was a microelectronics company engaged in integrated circuit manufacturing.  I was frequently  in a quandary as to where to allocate the manufacture of a new product because the yields of those currently being manufactured varied greatly from lot to lot.  A great degree of the available capacity was always being taken up with remake of lots that didn’t yield enough good product for the orders before us.  The ISO 9001 standard was coming into being at the time (just goes to show you how far back my experience runs) and some forward thinkers in the quality group joined with the managers of the manufacturing facility in an effort to build a QMS.  To make a long story short, the team studied the production methods being used and found a great degree of variability in what were thought to be hard and fast procedures.  They found that by formally reviewing product failures that certain patterns always seemed to be present.  Engineering and circuit designers then became interested and began the effort of formalizing procedures for machine set up and in redesigning away from weak areas of the circuitry.  Over a period of a year or two the average yield out of this clean room rose from 40% to over 95%.  Even more importantly the success was permanent.  The results were so good my product allocation position was no longer necessary and I moved on to an environment, health and safety assignment.

I saw similar issues when I came to the EHS assignment individual interpretations of what constituted appropriate response to regulation, procedures that were more like common practices and a general approach that could stand some formalization.  So having just experienced what happened within the quality world we built a team to improve the results in the EHS area as well.  Although our measures of success were different, the formalization of process and procedures, the understanding of what had to be managed and the quest for constant improvement as is taught within the standards yielded similar successes.  We certified our EMS to the ISO 14001 standard through a third party certification agency.   More importantly measures such as the number of citations for being out of compliance fell precipitously to almost nill.  External audits  of our facilities, which we performed on a three year cycle ,were hard pressed to issue any findings post EMS.   Again these results held over several audit cycles which to me was an indication of how well entrenched the management system was embedded in the organization.

OK you are saying that I still have not answered the question as to size.  Well I guess the answer to that is actually hard to come by.  For instance, procedures which are developed in building the EMS but that should have been in place whether there is a management system or not, are they to be counted in determining the size?  Building an inventory of those pieces of equipment or of the chemicals used and disposed of as is required by a formal management system but should have been present if one is using good management practices, are these to be burdened as part of EMS development?  Keeping records to prove that things are actually getting done isn’t that just common sense and logical?  So if records aren’t there and need to be is that the fault of the management system, I think not.  Thus, if you think that amount of work and the degree of paper work is too much to adopt a formal management system approach then I would challenge you to think again.

I learned an important concept while working for a British company in the later stages of my EHS career.  The term “Fit for Purpose” was frequently used when deciding how much, or how big or how extensive any endeavor was to be.  All too often we tend to jump to the extremes when thinking about the formalization of processes.  We envision miles of paperwork, arduous procedures and in general a drag on being productive or innovative.  When you think about this, these are the same arguments that workers who choose to “work on the edge” typically use to justify not following rules and regulations.  The size of the management system should never be used as a reason for not instituting a formal management system.  Instead, the determination of what is fit for the purpose intended should be the guiding principal employed.

Yes the ISO standards have lots of structure and long lists of things that must be included when developing a management system.  How did those lists get developed and by whom?   International standards like the ISO 14001 EMS standard are developed by a team of professionals in groups called Technical Committees.  They write the standards in a way that anyone, especially those who would start from nothing, can build an EMS based on the collective knowledge of people who have spent many years pursuing their trade.  For many of us numerous requirements of the standard are already in our organizational approach but probably not formalized in a way that truly sets the expectations as one would expect.  There are a few rules that can be applied to our informal systems that can help in making the transition to a more formal and lasting approach.

The first rule is : If it isn’t written down it doesn’t exist.  Sometimes this simple statement is the hardest to get our minds around.  Much of our informal management system approach is based on word of mouth procedures.  Over time this verbal  telling of what or how things need to be done will inevitably cause a drift from what was initially expected and that can lead to catastrophic results.  The second rule: What gets measured gets managed.   How can one know what has to be done if there is no understanding of what one has? Very often we assume we know what is happening on the shop floor or how the chemicals used in the shop are stored and transported but if we haven’t gone out and listed these things down we might miss a very important aspect of our operations to devastating effect.  Lastly: If there is no record of something being done then it didn’t.  If there is no record, or feedback loop to insure that an action was taken then it becomes impossible to prove or improve on its effectiveness.  If a management system is based on these three rules a Fit for Purpose approach can result in a very simple but effective way of managing your business for today and into the future.

Just think what those people in the Bronx would be doing now if a formal Fit for Purpose management system was in place at that hotel this summer.