Are Rules Squelching Safety? Continued from page 39 Because rules don’t effectively capture experiential knowledge, “more is better” doesn’t apply, and additional rules can actually contribute to a net loss of organizational knowledge. Any time we rely on rules to shore up expectations, we have to deal with the challenge of how rules are interpreted by those who make them versus those who use them. These interpretation differences act in two dimensions as users attempt to dis- cern what rules mean in terms of op- erational usefulness, and what rules represent as an implicit message. The issue of usefulness speaks to the gap between work as it is imagined and work as it is actually performed. While a safety manager may imple- ment the mandatory use of personal protective equipment (PPE) for a specific maintenance process—and be right to do so based on the per- ceived risk of hand or eye injuries for example—the worker at the sharp end may find the use of PPE a hindrance to working with a small, delicate part. From the symbolic perspective, rules can be interpreted as support- ive of the worker to completing tasks successfully, or as irrelevant instru- ments for control or blame. Of course, there are shades of grey between these two extremes, but in practice there are a lot of organizations in our industry who are heavily loaded with rules that are seen by the workforce as unnecessary roadblocks to work, compromising the coordination that rules are often intended to engender. Wherever rules exist in any form, there are certain to be violations. In our industry, these violations very often occur because we place work- ers in the midst of some powerful 40 goal conflicts. When a line techni- cian makes a choice to reposition an airplane with no wing walker (or fewer than are required), the work- safety tension that exists between the desire to safely complete a task and the need to satisfy the demands of a time-constrained customer is clearly visible. The potential for misalign- ment between process safety and personal safety also exists. When a worker does not use hearing protec- tion because it attenuates the sounds of a co-worker whose commands must be heard to successfully ac- complish a task, personal safety is abandoned in favor of process safety. This disconnect can happen in reverse as well, where workers may violate procedures to assure personal safety within a process. In either case, routine violations of rules are one of the most frequently cited threats to organizational safety control. Perhaps most concerning is when rule viola- tions become more frequent, they are embedded in the organizational cul- ture. This means new members have to learn two sets of operating knowl- edge, and the gap between ‘work as done’ and ‘work as we think it is done’ becomes increasingly wider. All of these issues so far point to a central issue with respect to rules that concern safety: that rules are a requirement for any complex organi- zation to function, but that individual ingenuity is necessary for the creation of new solutions. These opposing ideas come with similarly dichoto- mous messages, one reminding members of the organization of their responsibility for safety and using good judgment, and the other cau- tioning that rules must be followed and there is no room for judgment. This dilemma is not always present, but it certainly is prevalent in avia- tion organizations. Signs and rules requiring workers to wear PPE at all times, even when a hazard is not pres- ent, discourage the use of individual judgment. Again, this is not intended to suggest that rules on the use of PPE should be abandoned. Rules, though, are a simplification of the risk acceptance process. In simplify- ing that decision-making, workers no longer maintain clear ownership of, or responsibility for, their decisions. Making the most out of rules We’ve established that having organizational rules is a neces- sary component of safety, but rules undoubtedly present a number of challenges, many of which require a delicate—and dynamic—balancing act as needs and demands change. One strategy for making rules function more effectively is to actively evalu- ate how restrictive they are. In a lot of aviation organizations, rules and procedures present the only ac- ceptable way to complete a task or process. When rules are dissected by their purpose, though, it becomes more obvious that we have options in how they are framed. If rules are a way to improve safety or achieve a minimum level of safety by defin- ing behavior in response to probable situations, then the next question to ask is whether the rule we create speaks to concrete behaviors, the process of deciding the right action, or the broad goal of the system. You’ve probably concluded that rules that define specific actions are the most restrictive, and rules that Aviation Business Journal | 4th Quarter 2015
