Food for thought
How a shift in mindset changes how you look at the standards
This year I’ve been working on customer standards full time (I think it’s going to be my forever job!), adding them to, or aligning them with the BRCGS standards. Although I’ve been working with these standards for over 20 years, every time I look at them – due to the level of detail that I’m getting into – I find that l have a lightbulb moment and learn something new.
This time, my ‘light bulb moment’ has been even bigger than normal, so I thought I’d share it with you, as it’s very topical.
To explain, I’m going to give you some context and background.
The project I’m currently working on, involves putting customer standards into our audIT.app. software. I’ve already put the the four BRCGS standards in there, so now it’s just a case of working through all the customer standards to align their requirements to our 18 compliance topics where possible, or add their requirements in.
The key to this lightbulb moment is around the 18 compliance topics. To ensure that all the different standards can be aligned, we’ve developed our own structure, which turned out to be 18 topics (senior management commitment, document management, continuous improvement etc).
The 18 topics are the basis of audIT.app, as the audits are built around them. To set up audIT.app you have to define for each topic, who the accountable manager is. Building and developing accountability is a key aspect of culture, as it means that each member of the team understands which part of the standard they’re accountable for, and which part their responsible for.
This means that:
- The HR or People manager is accountable for the personnel topic.
- The engineering manager is accountable for maintenance.
- The senior manager is accountable for the senior management commitment section.
- And so on.
When a non-conformance is identified from a topic, audIT.app automatically sends it to the accountable manager – as they’re the one that must ensure it gets done.
That all sounds pretty straightforward – right?
Well, yes and no – and this is where my lightbulb moment came in!
If you now look at the standard and read a clause with accountability in mind, you’d be thinking to yourself… Who is accountable for getting that done?
The way that clauses are written, based on many topics sitting within a theme – it means that even one clause is relevant to many topics, and in keeping within the mindset of accountability – it would have many.
I’d already been splitting up the clauses, as many talk about different topics even in one sentence. But layering accountability on top highlights how confusing the clauses are when read by different accountable managers.
Let’s take an example of a clause from a well-known standard, about quantity control.
“Sites must have a documented procedure for the management of declared contents. This must cover all products to ensure conformance to the legal requirements in the intended country of sale. In the absence of country legislation, the procedure must ensure compliance to the customer specification for each product.
Where statistical methods are used to manage quantity, appropriate procedures and equipment must be in place.
Records must show the finished pack results for each batch and show they comply with the product specification and any declared contents. For products produced/packed to average weight/volume, records must show the average and upper/lower results for each batch.
Procedures must detail the actions to be taken if the results fail to meet the specification including the segregation of non-conforming products.
Results must be signed off by a competent person at the end of each batch.
All personnel involved in the management of product weight, volume and count must be trained in the associated procedures and equipment use.”
Now if you look at this ONE clause and identify who’s accountable, you’ll find that it covers many departments. Let’s go through it.
The first paragraph covers two areas of accountability – those who define which piece of legislation you’re working to (regulatory) which sits in senior management commitment, and also the department who are accountable for document control:
“Sites must have a documented procedure for the management of declared contents. This must cover all products to ensure conformance to the legal requirements in the intended country of sale. In the absence of country legislation, the procedure must ensure compliance to the customer specification for each product.”
The next paragraph sits with those who manage measuring equipment and calibration:
“Where statistical methods are used to manage quantity, appropriate procedures, and equipment must be in place.”
The third paragraph covers two departments; you’ve got the product development team who generate the specification information, and the operations team who are accountable for process records:
“Records must show the finished pack results for each batch and show they comply with the product specification and any declared contents. For products produced/packed to average weight/volume, records must show the average and upper/lower results for each batch.”
The fourth paragraph belongs to those who are accountable for incidents:
“Procedures must detail the actions to be taken if the results fail to meet the specification including the segregation of non-conforming products.”
The second to last paragraph refers to supervision, which would again sit with senior management commitment.
“Results must be signed off by a competent person at the end of each batch.”
And the last paragraph is for the person who’s accountable for training:
“All personnel involved in the management of product weight, volume and count must be trained in the associated procedures and equipment use.”
You may be thinking that this is interesting, but what’s the point?
Well, this means that just this one clause needs to be separated and translated so that it’s relevant to seven different departments. Or another way of looking at it is, one topic (for example, quantity control) needs to sit in seven different procedures.
Each department needs to know different things about that topic, as they all contribute differently. You can’t give them all the same instruction to work to, you have to adapt the information provided so it’s relevant to each team. And, where one team’s accountability finishes, another begins, so there must be a robust handshake between them.
So, for the past four months, that’s what I’ve been working on…
I’ve changed how I read the standards, to align them to those who are accountable for them and translate them into something that makes sense to the reader. It’s been really hard going, causing lots of headaches – but the results are exciting, and I know it’s going to be a game-changer for the industry – especially those who work and train using our products.
The next time you read one of your procedures, just think about who it’s written for. You may realise that you’re training staff on procedures that contain information that’s not relevant to them. Think about how your trainees know which parts of that procedure you want them to understand, and which parts they don’t.
This clause needs to be separated and translated so that it’s relevant to seven different departments.
Great point, but if the procedure is written well, several responsibilities ought to be captured within it. Having separate procedures for different functions increases the nightmare of control of those documents and is not something I would advocate.
Hi Carol, I’m definitely not saying we should be writing different documents for each department. We need to come up with a clever solution – perhaps by segregating the procedure and defining training by each section. It’s not something I’ve formalised a proper solution for yet! 🙂
Kassy
Brilliant analysis. You have identified why many sites generate N/Cs because one person is not responsible for all of the requirements, even in the most simple of clauses.
Should not Standard writers take this into account when structuring and developing standards and classifying clauses into sections, which in general do not align with the way most businesses are organised?