Lack of Formal Documentation – Not a Root Cause

When conducting root cause analysis, “Lack of formal documentation” is a suggested root cause I have often come across. It seems superficially like a good, actionable root cause. Let’s get some formal documentation of our process in place. But, I always ask, “Will the process being formally documented stop the issue from recurring?” What if people don’t follow the formally documented process? What if the existing process is poor and we are simply documenting it? It might help, of course. But it can’t be the only answer. Which means this is not the root cause – or at least it’s not the only root cause.

When reviewing a process, I always start off by asking those in the process what exactly they do and why. They will tell you what really happens. Warts and all. When you send the request but never get a response back. When the form is returned but the signature doesn’t match the name. When someone goes on vacation, their work was in process and no-one knows what’s been done or what’s next. Then I take a look at the Standard Operating Procedure (SOP) if there is one. It never matches.

So, if we get the SOP to match the actual process, our problems will go away won’t they? Of course not. You don’t only need a clearly defined process. You need people that know the process and follow it. And you also want the defined process to be good. You want it carefully thought through and the ways it might fail considered. You can then build an effective process – one that is designed to handle the possible failures. And there is a great tool for this – Failure Mode and Effects Analysis (FMEA). Those who are getting used to Quality-Based Risk Management as part of implementing section 5.0 of ICH E6 (R2) will be used to the approach of scoring risks by Likelihood, Impact and Detectability. FMEA takes you through each of the process steps to develop your list of risks and prioritise them prior to modifying the process to make it more robust. This is true preventive action. Trying to foresee issues and stop them from ever occurring. If you send a request but don’t get a response back, why might that be? Could the request have gone into spam? Could it have gone to the wrong person? How might you handle it? Etc. Etc.

Rather than the lack of a formal documented process being a root cause, it’s more likely that there is a lack of a well-designed and consistently applied process. And the action should be to agree the process and then work through how it might fail to develop a robust process. Then document that robust process and make sure it is followed. And, of course, monitor the process for failures so you can continuously improve. Perhaps more easily said than done. But better to work on that than spend time formally documenting a failing process and think you’ve fixed the problem.

Here are more of my blog posts on root cause analysis where I describe a better approach than Five Whys. Got questions or comments? Interested in training options? Contact me.

 

Text: © 2019 DMPI Ltd. All rights reserved.

Image: Standard Operating Procedures – State Dept, Bill Ahrendt