More Information and More Training Does Not Necessarily Mean Better Performance
Saturday, 6 March 2010
I was browsing Edward Tufte’s website the other day and stumbled upon a one-paragraph post in which he described being brought in to consult with a large pharmaceutical company to help clarify and simplify their drug labeling and supporting information. His complaint was that he couldn’t make much progress because of the conflict between regulatory and business requirements.
He didn’t provide details but I think I know what he meant. We have experience working with pharma companies and have run into a similar roadblock. Everyone might want to do something but either the fear of fines/penalties (and the associated bad press) or the reluctance to endure the soul-crushing approval process required for any change keeps them from doing it…it just isn’t worth it. The regulations want to cover every possible outcome…the result is that all risks are treated equally — the most remote risk has to be addressed as fully as more likely risks. The result is that companies avoid rocking the boat wherever possible.
For example, let’s say you have a part of a process that you think could work better. Maybe you even occasionally have problems with it. Everyone might believe the right thing to do is to make a change to the process. But that would be very difficult. Of course you would need to actually figure out the change and document it and train the employees…that is a given. But in a regulated industry, you will probably also have to re-validate the process, which is time-consuming and costly…you really don’t want to do it if you don’t absolutely have to.
The result is that it is almost always easier (and preferred by management) to not change the process. Instead, you change the procedures and train the employees more. The first and most common fix to any problem becomes information and training.
The bad news is that creates a snowball effect…everyone has to be retrained, sure, but also those additional materials have to be kept current. Every time there is a correction, there is more information and training to update. Over time, that adds up to a lot of resource and cost but with little return in value.
The fix isn’t to learn to be more efficient at making information and training revisions (though, that never hurts). And it isn’t to sneak process changes in somehow so they don’t require re-validation (if that’s even possible). The real fix is a different model for regulation and rule-making. I don’t know what it would look like or if it’s even possible (or would even be welcomed in the industry). But the mountain of constraints creates an environment where performance is limited, not by capability, but by risk avoidance.
For an interesting talk on how this same principle plays out in our legal system, check out Philip Howard’s talk on www.ted.org “Four Ways to Fix a Broken Legal System.”