Are procedures hurting you?

Costs and performance metrics
Poorly written procedures can be a large financial drain on a company, and often executives do not realize that they are a cause. To minimize financial liability, a company needs to measure its procedures against reasonable metrics.

Some problems are obvious. Procedures are one of the first things reviewed during a regulatory audit, and any deficiencies found must be resolved quickly. Procedures should also be checked against commonly accepted industry practice. These practices may not be available in writing, and must be known from experience. A company is not obligated to follow all common industry practices, especially if its situation is unique. 

Procedures are also a large factor in many lawsuits. The standard of excellence for protection in a lawsuit may be much higher than that required for mere Code compliance.  There is no definitive metric for minimizing this cost, but some things that can be considered are clarity of instructions, avoidance of saying something more than one time, prudent use of when and how to be permissive as opposed to mandatory, and avoidance of vague terminology.

Perhaps the highest cost factor for poorly written procedures is poor decision making by personnel throughout an organization who have varying levels of responsibility. There is probably no way to measure this cost, but it can be very large. There are two factors necessary to minimize this cost. First, the procedures must be well written. They must include all the necessary material, they must be clearly understandable, and they must be difficult to misinterpret. Secondly, they must be written so that a person can quickly find needed information – an excellent procedure has no value if it cannot be located quickly when needed.

Finally, procedures are essential in providing knowledge transfer to a constantly changing workforce. New personnel seldom have the luxury of spending long periods of time with senior personnel to effect transfer of knowledge. It is becoming ever more important to capture that senior knowledge in written procedures so that it can be passed along. A company might consider obtaining a rough measurement of how much work is performed without the use of written procedures.

Well written procedures
Procedure writing is a skill that few people posses. Most people who have a great expertise in performing a task are not able to verbalize what they are doing very well in writing. In order to obtain a good procedure, then, there must be a collaborative effort between a person with the skill for performing the task and a person with skill for technical writing.

Format is very important. All procedures in a manual should have a consistent format.  The format should be clear and easy to read. The organization should be as simple as possible. Figures and tables should be clearly labelled and easy to read. Use of grey lines in tables helps to focus attention on the black text within the tables, which is what is important. In electronic presentations, colour can be very helpful. White space should be used appropriately.

Clarity is essential. Procedures should be as brief and simple as possible, while still being complete. Consistency, both in terminology and in editorial practices, is important to avoid confusion.

It is also important to write in such a way as to avoid the likelihood of misinterpretation. This is often difficult, and takes great writing skill. It is probably impossible to eliminate misinterpretation, but care should be taken to minimize the problem.

Procedures must be inclusive. A procedure for a given task has no value if it does not exist. Many companies have a large number of procedures that are not written. It is a challenge to capture this intellectual capital while it is available.

Procedures within a manual are often very interrelated. A part of one procedure affects what is done in part of another procedure. These interrelationships should be cross-referenced. Cross-references should be clearly indicated in both directions. Good cross-referencing can be a great help when updating procedures by reminding the reviewers to determine whether the referenced material also needs to be updated. If one procedure is updated and a related one is not, the two procedures may conflict with one another.

If a regulatory requirement applies, care must be used. If the regulation is written in prescriptive language, the procedure should be worded using the regulatory language as closely as possible to avoid potential slight changes of meaning. If the regulation is written in performance language, the company should usually enhance its procedure in whatever way best fits its particular needs.

Field personnel should not usually be directed to perform a task in compliance with a national standard. It is usually much better for a company to interpret the standard in perspective of its own unique situation, and to write its procedure in accordance with its own interpretation.

Although not required, it is often helpful to include a description of the piping system in the procedures manual. Such a description can give a new user or a regulatory inspector a quick overview of the physical layout of the system, including the type of piping material used, the maximum pressures permitted, the type of product being transported, and the source of supply.

If there is a regulatory requirement that does not apply to a company, it is helpful to include a statement in the procedures manual that specifically states that fact, along with an explanation of why that is.

A procedures manual should include information and direction on documentation. The retention of each document, hard copy or electronic, should be established. Forms should be carefully designed to coordinate with applicable procedures.

Locating needed information quickly
A growing challenge is being able to find needed information quickly. The first tool to use is simply a good organization to begin with.  If material is well organized, it is much easier to find information when it is needed.

Often little attention is paid to tables of contents, yet effective use of tables of contents can have a tremendous impact on how quickly information can be retrieved. Thought needs to be given to how detailed the contents need to be. There needs to be a balance between brief simplicity and detailed inclusion. If procedures within a manual are lengthy (multiple pages), it may be advisable to include a table of contents for each such procedure. This eliminates the need to scan an entire document to determine whether a particular topic is covered. A table of contents is not needed for short procedures.

Cross-references can be a great help in finding information quickly. Often a person needing information quickly may go to a wrong location within a manual, but one that is somewhat related to the desired information. A cross-reference can quickly guide that person to the proper location.

Since many procedure manuals are now available in electronic format, electronic word search capability is often available as part of the software package used. This can be a great help. One limitation, however, is that it requires use of the specific term used within the procedure. The search software does not compensate for “near misses”.

A well-designed index can be a tremendous tool for finding information quickly. Often the index is not nearly large enough to be effective. Many times there may be multiple ways that a term might be accessed, and all possibilities can be included within the index.  For example, a person looking for information on line markers might look for “line markers” or for “markers, line”. Since we cannot determine ahead of time what term a person might use, we can put both entries into the appendix. If an index entry applies to a specific paragraph within a procedure, the index should reference that specific paragraph, not the procedure in which it is contained. This avoids wasting time scanning an entire procedure for information located within a specific paragraph. If the manual is presented in electronic format, each index entry can be hyperlinked to its reference. This may be initially time consuming, but is not difficult to maintain once it is established, and results in an extremely effective tool for locating information.

Conclusion
Procedures are very important to a company. Poorly written procedures will very likely result in great costs, but those costs might not be immediately attributable to the procedures. Why permit your company to be placed in a position of high liability? Time and effort expended on procedures can reflect well on a company and produce large dividends for years to come.