Best Practices


The tragic shooting at Marjory Stoneman Douglas High School in Parkland, Florida, in February was somehow made worse by the revelation that it could have been prevented, as there were numerous red flags that presaged the event but were either ignored or mishandled. Similarly, it came to light a few months ago that thousands of names of dishonorably discharged military personnel banned from owning firearms had somehow escaped being reported. This gap led to a massacre at First Baptist Church in Sutherland Springs, Texas, in November.

These tragedies have made me wonder: Are risk assessments of critical systems being carried out and acted upon? How are these systems being audited?

Dont let your system gaps or inadequacies be diagnosed after the fact. Risk assessment, procedure development, training, audit and system improvement are critical to your business performance. Here are some things to think about related to system design and audit.

With regard to systems, separate your business and your safety systems and make sure that both have a written set of processes and are subject to an audit cycle. The degree of detail will depend on your business size and complexity. (A good model to follow in the safety area is the ExxonMobil Operations Integrity Management System, to which you can find references online.)

Next, you should conduct a risk assessment process throughout your organization. (You may want to refer to my column on risk assessment in LubesnGreases May 2014.) Risks should be documented and decisions made as to whether the risk will be terminated, treated, transferred or taken. This assessment should be reviewed and progress evaluated on an annual basis, especially with regard to medium- and high-level risks. Each level of management should review the results and a summary should be given to the highest level team and the CEO. Be sure to identify risks that may be associated with new raw materials and products, processes, IT systems and macroeconomic or industry conditions.

Task your management with ensuring that proper training is in place for your safety and business systems. This includes training for new employees as well as refresher training for experienced personnel. Consider some kind of proficiency test or other ways to confirm that the training has been understood and internalized. Periodically organize a mock incident to test how the system actually works.

Ensure that you have an audit process in place. It is good practice, in my experience, to have some outside expertise on your audit team. Hire a safety expert from outside your company to participate in your safety audit on a rotating basis, perhaps every two to three years. Similarly, have an experienced external auditor participate in business audits on a regular basis. Involve staff from your own company on the audit teams, too, as audits provide an excellent opportunity for people to learn how other parts of the company operate and to hone their skills in the risk management area.

If yours is a large company, you likely have well-documented business and safety processes and a well-defined audit process in place. You should not be complacent, however, and should think about the culture in which audits are conducted, reviewed and acted upon.

Sometimes a company culture can be one in which only a successful audit (meaning few or minor gaps identified) is welcomed. Managers may cross their fingers and hope that the audit team avoids the tough areas, and may even steer them toward the lower-risk processes or those that are most under control. This is not the right attitude. If you can befriend the audit process and welcome fresh, outside eyes that may be able to see what you cannot, then you will be in a better place in the long run.

Another tip: There is a happy medium that must be reached regarding the level of detail you document and the level of specificity you require. At one end of the spectrum, if you are overly detailed and specific, your processes become extremely long, and it becomes difficult to train people in them. Additionally, you may end up focusing on relatively unimportant details and end up with findings and follow-ups that do not actually reduce your risk in a significant way. On the other end of the spectrum are processes that are too vague or that lack critical steps and activities. Such systems may evade audit findings and result in too much risk being taken or in too much variability in the way that individuals carry out the business process.

There are no easy answers here, but I recommend that you ask these questions about your processes and documents:

Is the purpose of the business process clear? Who owns the process? Is it up to date?

Are the steps clearly described and sufficient to satisfy the business purpose?

What are the risks in this process, and how are they dealt with?

How are people trained in this process?

How can I measure the outcomes? Do these measures show improvement over time?

How is this process improved?

In the lubes and additives business, product quality is especially important given the complex nature of industry specifications, demanding and expensive testing regimes and the reputational risks that could result from a quality lapse. Be sure that your processes for ensuring product quality are robust, well-documented and well-understood by the people who carry them out on a day-to-day basis. Also, pay attention to the quality processes of your raw material suppliers and to the processes of any laboratories involved in the qualification or release testing of your finished products.

A focus on well-documented processes, proper training, appropriate and valued auditing, and continuous improvement will reduce business exposure and ultimately result in greater profitability and sustainability.

Sara Lefcourt of Lefcourt Consulting LLC specializes in helping companies to improve profits, reduce risk and step up their operations. Her experience includes many years in marketing, sales and procurement, first for Exxon and then at Infineum, where she was vice president, supply. Email her at or phone (908) 400-5210.

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