define a desired system goal grant the most latitude to workers, but poten- tially provide them with the least sup- port. Another alternative approach to mediate the absolute nature of rules is to build in non-binding language so that the direction takes on more of an advisory nature. Of course, given the nature of our business, this can’t be used in every case, but it does give managers a good option for reducing restrictions on workers in less critical situations. The caveat here is that when rules are less restrictive on ac- tion, the overall goal has to be unam- biguous. A good approach to finding this balance is to mirror uncertainty with restrictiveness. Where a task or process has a lot of variability built in, rules should also allow workers sufficient latitude and judgment to perform effectively—and safely. Despite our good intentions, a lot of rules are created in offices and boardrooms far removed from the actual work, and that percep- tual disconnect creates a good deal of unnecessary heartburn. In very time-conscious industries like avia- tion, we tend to develop and push out rules without first evaluating them, and later checking to see that they accomplish what we intended. This is improving as more aviation operators are designing change management and safety assurance processes that allow them to better understand how effective safety efforts are within their organizations; but a complementary approach is the routine involvement of affected workers in the develop- ment of rules. This sounds simple enough—and it can be—but finding the time for focused collaboration seems to be the biggest roadblock to Aviation Business Journal | 4th Quarter 2015 more consistent involvement of em- ployees in rule creation. There is a lot of recent research that shows not only that participation in rule development increases the perception that rules are legitimate and supportive, it also decreases routine non-compliance dramatically. Conversely, a reluc- tance to participate in the process of rule formulation might indicate that employees do not trust managers, and that a culture of blame is pres- ent. Involving personnel affected by rules in the process of their develop- ment reinforces the fluidity of rules and procedures as constructs that should be continuously evaluated for effectiveness, and updated as opera- tional demands change. Though an awful lot of attention is focused on the top-down aspects of safety culture, gaining bottom-up support is every bit as important, and often more challenging. Building involvement into rule development is a great first step to increasing trust and buy-in among those who are most respon- sible for the success of the system. It isn’t any surprise that rules are most effective when those charged with following them understand them, though in high-consequence industries like aviation, the volume of rules can be overwhelming when it comes to training. Although it isn’t a small task, education about rules and the reasons they exist is a critical component to reducing misunder- standing and violations. This is where the employee involvement we dis- cussed previously can really pay off. Changing a person’s explicit knowl- edge about a procedure is not particu- larly difficult, but changing ingrained, tacit knowledge requires more effort. We’ve all likely seen examples of this with senior employees whose long-set ways of doing things are passed on to newer members of the organization despite clear rules to the contrary. Involving those workers in the pro- cess of developing rules and proce- dures, and then in educating others, is an effective tool to changing long-held beliefs that might otherwise contrib- ute to routine violations. At its core, education about rules is the primary process for shaping how people per- ceive them symbolically (remember our earlier discussion about rules as support versus as excessive control?). Well-developed training reduces the sort of goal conflicts that often lead to rule violation in the first place. Finally, rules can be made more effective by applying them only when necessary. Much like PPE is a last resort when a hazard cannot other- wise be avoided or engineered out of a process; rules should be treated as a necessity only when equipment or process design require it, or when reliance on organizational norms is too informal because of identified safety risks. A good practice as we evaluate rules is to continuously ask what might be done to make the rule obsolete. Lockout functions or speed limiters are examples of engineered solutions that negate the need for additional rules, because they automatically constrain operations. This, though, is another kind of restriction, and as such should be treated as a balancing act in the same way as rule creation. The benefit to engineering or design solutions is that they counteract the allure of writing rules as seemingly simple solutions, and naturally reduce goal conflicts and the rule violations 41
