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In this blog we identify the Top 5 reasons you should reduce the amount of documentation in your management system.
The Purpose of Documentation
ISO identifies the purpose of documented information as:
a) communication of information.
b) evidence of conformity.
c) knowledge sharing.
d) maintaining organisational knowledge.
ISO management system standards (e.g. ISO 9001, ISO 14001, ISO 45001) identify some mandatory documented information (see: "Documented Information Required" for a full list here: https://www.irmsystems.com.au/resources).
How Did We Get Here?
Feel your management system is overloaded with too much documentation?
You are not alone. In fact, one of the most common customer requests we get is "how can we reduce our documentation".
First, it is worth understanding the common reasons why so much documentation built up in the first place:
When we first developed our system - we created more documentation than we really needed.
Developing a new document become our "go to" approach for demonstrating how we meet any new requirement that may arise.
An auditor raised some non-conformances - so we developed more documentation to address them.
We have had several Quality/ Safety/ Compliance Managers over time, and they all like to add new procedures.
Our consultant told us we need these documents.
Documentation - The Top 5 Reasons You Should Reduce It
1. Legal liability
Can you consistently action all the stated commitments in your procedures?
In his book, Papersafe, Greg Smith explains why safety procedures that we don't implement consistently become your major source of legal liability in the event of a serious injury.
Smart legal types (on the opposite side) use this inconsistency to demonstrate you are not providing safe systems of work.
The same legal risk could arise in relation to food safety incidents, product issues and in delivery of your core services (particularly where those services impact on people - e.g. aged care, health, disability support).
2. Documents are a Poor Learning Tool
How do we learn? That's a big question - and beyond our area of expertise. However, pickup any model or guide on learning. Where does reading documents fit in? We learn by doing, observing, through demonstration and discussion. Oh, and there it is towards the bottom - through reading.
If your goal is to effectively share information and knowledge - why use the least effective medium?
We share some examples of the best practice we see in industry in our next Blog (How Do We Maintain a Management System With Reduced Documentation?).
3. Confusion and Inconsistency
Herbert Simon coined the term bounded rationality to describe the limits of our cognitive ability to process overwhelming amounts of information. Gerd Gigerenzer identified how we respond when faced with too much information: we make mental shortcuts and go back to what we know (a process he termed satisficing).
We often see organisations with multiple policies, procedures, registers and tools, for essentially the same thing (e.g. incident reporting).
The end result - incidents are under-reported or when they are, staff are confused about how to take action.
In these situations we strongly advise our customers to create one source of guidance.
4. Takes the Focus Off What's Important
We recently assisted an organisation with over 80 Safe Work Procedures (SWPs). 80+ SWPs that someone had to develop and maintain and staff are expected to follow.
The organisation was in a low risk industry. What if that effort was refocussed on their top 3-5 WHS risks and information was shared by through a variety of mediums and methods (consultation, verbal communication, training, on the job training and mentoring, video etc)?
If our goal is to communicate and share knowledge effectively, then it's time to reconsider our reliance on written documents.
5. Ingrained Inefficiency
You stop in at the local pizza shop. Before you order you are required to complete a Customer Evaluation Form, Induction and sign documents to confirm your commitment to behaving appropriately. You order.
Before the Chef commences, he has to complete a job-safety analysis (JSA) and acknowledge he will follow the work instructions. He has been cooking pizzas here for 30 years, but hey, you never know. The chef then inducts the rest of the team into the JSA.
Production is delayed, because the assistant Chef hasn't finished testing all the olives. You cancel the olives.
Unfortunately, head office has just ordered the chef to stop work on any pizza bases, as the flour supplier has not re-submitted their Safety Plan.
You are (a) hungry and (b) starting to wonder how they are still in business.
Okay - we are exaggerating a little, but we often see Organisations overestimate the level of written documentation "required" by regulation or standards. And yes, trying to comply with unnecessary documents ingrains a level of inefficiency that costs you serious time and money.
In the example of 80+ SWPs at 4. above - the Work Health and Safety Regulation requires an organisation to identify hazards, assess risk and apply the hierarchy of controls - but does not mandate that organisations develop a documented SWP for every operational task.
Similarly, ISO Standards clearly identify a focus on the processes needed to achieve your intended outcome (i.e. a safe workplace, consistent product etc) - not just documentation.
As a further example, we recently worked with an organisation seeking to meet NDIS Practice Standards. Read the requirements carefully and yes, some documentation (particularly records) is required, but the focus of the Standards is clearly on the "processes" an organisation uses to achieve the identified “outcome”.
The Hard Questions We Need to Ask Ourselves
Review your management system documents.
Are they really required by regulation, standards or customers? Do they serve an organisational purpose? Do they relate to a complex or high risk work task?
If not, get rid of them. Plain and simple. Guidance can still be provided via more effective learning approaches (on the job training, mentoring, communication and consultation etc).
Where to From Here?
Todays blog throws up two additional questions:
1. How Do We Maintain a Management System With Reduced Documentation? We will address this question in our next blog and include some examples of the best practice we have seen.
2. How Do We Go About Reducing the Number of Documents?
We addressed this question in:
Our December 2019 blog (https://www.irmsystems.com.au/post/paperwork)
Our April 2020 video blog identifies mandatory documentation required by ISO Standards. https://www.irmsystems.com.au/post/what-documents-do-we-need-in-our-iso-management-system
Concerned about what evidence you could show an auditor (other than documents)? See our March 2020 video: https://www.irmsystems.com.au/post/what-evidence-does-an-auditor-need
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