by Massimo Balducci
Personally I’m persuaded that compliance approach could teach us something on how to face the COVID-19 crisis. To prove my point I will first of all remind us briefly of the basics of compliance approach. Roughly speaking I daresay that compliance refers to a mechanism of supervision to be used while working in a process oriented way, or, if you wish, in a re-engineered organisation. What implies working in a re-engineered organisation? Whoever is involved in an organised production is called upon all the time to find an answer to the following question: “what am I supposed to do now?” Nobel prize winner H.A. Simon thought that anyone called upon to make such a decision is supported by some mechanisms able to reduce her/his decision making complexity.
We have two couples of such mechanisms. First couple: hierarchy and tradition. When called upon to decide what to do, the employee asks his/her boss for directives (hierarchy). If later on the same case should occur, s/he would not bother the boss and would replicate the same behaviour s/he had had before according the the boss’s directives (tradition). Second couple: professional know how and processes. Once faced by a problem whatsoever, the employee looks for guidance at what formalised processes forecast for such a case and to her/his professional know how to fill in the gaps. Two additional comments are necessary here.
First of all a comment concerning regulations. In the case of the first couple, rules follow the model “who has power/authority on what” (e.g.: Mr. Rostagno is in charge of supply management); in the case of the second couple, rules follow the model “every time that……., then….” (e.g.: every time a package is being delivered, the one in charge at reception shall check if the item delivered complies with the order”). A second comment is due concerning the socio-technical complexity of the environment where one is operating. In traditional environment –usually pretty stable and not really developing- authority and tradition prevail. Whereas in dynamic and turbulent environments processes and professional know how are a must.
Supervision in the case of organisations oriented to authority and tradition is based on the person of a supervisor, sort of wise person who is capable to decide what is being done correctly from what is being done wrongly, without having stated before (ex ante) what is right and what is wrong. In the case, on the contrary, of organisations oriented to processes and professional know how, the supervisor (here usually called auditor) checks in itinere if processes are being complied with. As a matter of a fact, we feel entitled to say that Italy is just in the middle of a transition from an authority and tradition based culture to one oriented to professional know how and work processes. This transition is painful: former control mechanisms are no longer there and new compliance mechanisms are being announced, but find it difficult to get actually implemented. Safety on the work place is where the gap between formal announcements and actual implementation is most striking. How often, even though they are prescribed, are sanitary masks not actually used?
How often, even though they are prescribed, are safety gloves ignored? How often do surgeons smoke in the operating room? How many hospitals implement the hygiene standards that would require daily disinfection actions? Lacking compliance with such standards are usually not due to the wish of the employer to save on operating costs, but rather to employees who do not like to be compelled into formalised procedures and to the use of tools that to some extent would hinder her/his ability to move freely. It is here, however, to be stressed that where these standards (usually regulating processes) are being severely complied with, the diffusion risks of COVID-19, as of any infection whatsoever, is strictly under control, much more so than in environments where micro-organisational detailed checking tools are being lazily implemented to the advantage of authoritarian generalised case.
Generally speaking where on the workplace one is guided by processes checked regularly to see if they are correctly complied with, macro systemic medieval ukases appear useless. Where risk management techniques are correctly implemented data should be carefully analysed. If the Italian authorities would do so, they would probably find out that: (i) the overall death rate in the last weeks has not increased, (ii) most of the casualties are due in the end to the fact that in Italy there is a low rate of hospital beds per 1,000 inhabitants (3,8 compared to 8 in Germany) and an incredibly low rate of intensive care beds (5,700 for 60 million inhabitants compared to 28,000 of Germany with 81 million inhabitants).
The governors of Lombardy Region and of Veneto Region (the two Italian regions with the highest per capita income on IRAP (imposta reddito attività produttive, the regional tax that mostly finances the health system) instead of asking to block the economy of the country should simply plea guilty and not make the situation worse by asking for measures that are of no use. In Benelux countries teleworking is a daily habit for two main reasons: (i) to reduce facility costs (office space, heating, etc) and (ii) to curb environmental pollution (if you work at home you do not use your car or the bus). This was already possible because all bureaucracy is on computer and organised according to processes, whereas data is collected in huge databases.
It has not been a problem to extend this already existing habit. In my department at the university of Florence, teleworking these COVID-19 days is implemented the following way: one day the secretary goes to the department to photocopy the papers to take home, the following day s/he works at home. Teleworking usually is not appreciated by employees whose performance can be easily evaluated by computer based checks. In Italy, we still hing to the authoritarian approach, preferring to control how much time the employees spend in the office rooms, controlling via badge when they check in and when they check out, i.e. controlling the employees’ time, instead of controlling their output and outcome.
Distance learning is another issue for singling out the difference between working according to processes and working according to hierarchy. At the VUB (Vrije Universiteit Brussel) and at Leiden, for instance, in the classrooms only skills are being taught, while know how teaching is completely done remotely. In the Vlanderens, the COVID-19 crisis seems to trigger off a process where all teaching in the future will be remotely done along with deep internships. Where working according to processes is common, there appears to be a limited need of authoritarian ukase to counter the COVID-19 diffusion. Where processes are scarce (like in Italy) the diffusion speed of the virus is high and the attempt to curb it relies on authoritarian useless ukases.
The author, Massimo Balducci is a Professor at the University of Florence (Firenze) and one of the authors at our Italian website www.riskcompliance.it. He is an expert working for the European Network of Training Organizations of Local and Regional Authorities (ENTA). Massimo is an author of several publications in French, English and Italian about Public Management.
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