BY: Stacey Pisani
Comments: No Comments
This is the first article in Kestrel’s Drones 101 series.
Industries like transportation, manufacturing, utilities, mining, construction, oil and gas, and agriculture are crucial to our country’s infrastructure, particularly in a rapidly changing global market. Yet these industrial sectors continually face the challenges of an aging workforce and high-risk job tasks, including exposure to moving freight cars, high-voltage transmission lines, and hazmat materials and risks of slips, trips, falls, maiming and premature death.
Fortunately, drones are an emerging technology that offers a solution both to the shrinking workforce and as an additional mitigation tactic for various operational safety needs of heavy industries.
What was once a very niche market, drones are emerging into an important new phase: everyday use of drone technology in the workplace. It’s no longer just tech-savvy companies that are using drones. Enterprise-level Unmanned Aerial System (UAS) operations are becoming a big deal in industry. Organizations ranging from municipalities and agriculture companies to the Fortune 500s are getting involved in drone operations.
In another three to five years, it will potentially make business sense for nearly every major industrial company to incorporate UAS technologies into their operations for two reasons:
- Drones are effective at both mitigating risks and increasing operational efficiency.
- Drones are a tool that can bolster workforce recruitment and retention efforts.
Terminology & Technology
As drones become more popular and the industry continues to grow, newer and more varied versions of them are hitting the market, making it difficult to keep up with the technology and the related terminology.
If you’ve observed or read anything about drones, you may have noticed a few acronyms thrown around, and that can be a little confusing. Some of the most common terminology includes the following:
- Drone is used to define just about any type of Unmanned Aerial Vehicle (UAV). The term refers to many different types of an unmanned aircraft of various sizes, which are used for multiple functions, ranging from armed forces aircraft to hobbyists taking amateur digital photography.
- Unmanned Aerial Vehicle (UAV) refers to the platform, airframe, or body of the craft you are flying. The term can be used interchangeably with drone.
- Unmanned Aerial System (UAS) includes the vehicle or aircraft, the controller, and the link(s) that connect them. A small Unmanned Aerial System (sUAS) is a UAS weighing less than 55 pounds at takeoff and landing.
It is best practice to use UAS in formal documents like policies and procedures. If you have a diverse approach that includes both light and heavy drones, then specifying whether a document pertains to sUAS or UAS operations would be optimal, as the regulations vary based on weight, and your operational policies and procedures would need to reflect this.
Types of UAS
While there are variety of drone technologies on the market, the three main types of UAS available in the commercial space are the following:
- Multi-rotor UAS is the most popular drone type for both commercial use and for hobbyists. This type of drone is typically less difficult to operate. They offer vertical take-off and landing and the ability to hover, both of which can result in highly detailed data points and targeted insights. Quad-, hexa-, and octo-copters are all available (i.e., 4, 6 or 8 rotors). There are a number of typical use cases of multi-rotor drones, including industrial inspections, aerial mapping, site planning and monitoring, cause finding, resource management, crop spraying and many more.
- Fixed-wing UAS function more like an airplane than their multi-rotor counterpart. These drones often resemble small airplanes or mechanical stingrays. They consist of two fixed wings on either side of the craft. This design provides for more efficient aerodynamics and longer flight times (~45-60 min per flight). Fixed-wing have high aerial coverage (up to 2,400 acres per flight) but offer less detailed imagery, are typically unable to hover, and are more suited for covering large areas of land, resulting in large data sets with less detail than you would collect using a multi-rotor or a hybrid UAS. These drones require a suitable runway area for takeoff and landings and are usually able to carry heavier payloads than other types of UAS. Typical uses include beyond visual line of sight (BVLOS) operations, photogrammetry and 3D mapping, crop inspections, and other tasks that require significant area coverage.
- Hybrid UAS are gaining popularity, as these platforms offer the benefits of a vertical takeoff and landing and the ability to fly quickly in a forward motion to cover larger areas of land, while still having the ability to hover. Hovering allows for close-up inspections and produces more detailed information than a quick fly by. Hybrids range in their load carrying capability. Hybrids can be used in many of the same ways as fixed wings and multi-rotors but are most excitingly known for their use in delivery services and unmanned air taxi applications.
In addition to the drone itself, there are many types of payloads, which is a generic term for the cameras, sensors, or other equipment that can be attached to and carried by drones:
- Specialized cameras are the most often used payloads for drones.
- Various cameras offer the ability to gather higher resolution images with greater detail.
- LiDAR units can be attached to gather data points from any work site, which can then be translated into 3D-modeling efforts to aid in volumetric applications.
- Thermal/infrared cameras provide heat sensing capability.
- Gas detection cameras detect fugitive gas leaks at pipelines and tanks.
- Multispectral and hyperspectral sensors are electromagnetic energy sensors that offer insight into details on resources that would otherwise be invisible to the human eye.
- Environmental sensors (e.g., chemical sensors) can measure chemical compositions and traces of particular chemical substances, including radioactive particles and particulate matter.
Undoubtedly, the types of drones and the payloads will continue to expand as the market and applicability of drones continues to grow.
Learn more about Kestrel’s UAS Program Management services. Stay tuned for the rest of our Drones 101 series, featuring:
- Terminology & Technology
- Drone Program Management
- Top 6 Tips for Managing Your Drone Program
Cost-effective management of environmental liabilities is a challenge for any organization, but it is particularly challenging for those companies with a large portfolio of liabilities at varying stages of maturity. The complexity of liability management is increased even more for those organizations adhering to generally accepted accounting practices (GAAP), which apply additional requirements to the process. Ultimately, the goal of liability management is to create a reliable system that enables the company to minimize risk and quickly drive projects to closure with as little expenditure of internal and external resources as possible.
The manner in which a liability is accounted (and managed) is based largely on the liability itself and the available information. Environmental liabilities are typically managed as either loss contingencies or asset retirement obligations (AROs). A company may also decide to address certain environmental liabilities as operating expenses or capital expenditures. Regardless, companies should employ a cross-functional team (i.e., finance, law, operations, and EHS departments) to establish and document a repeatable and defensible process—consistent with applicable GAAP standards—for how the liability will be managed. Further, companies should develop standard procedures that define how and when costs associated with the liabilities are estimated.
Environmental Loss Contingencies
An environmental loss contingency represents the cost to remediate an environmental liability where:
- It is probable that the liability has occurred, and
- The cost can be reasonably estimated.
The GAAP for loss contingencies is established in Accounting Standards Codification (ASC) 450-20. In very general terms, environmental loss contingencies include environmental investigations and remediation that are not the result of normal operations and that are generally triggered by a regulatory agency action or order.
As stated, the goal of loss contingency management is to create a system to cost-effectively minimize risk and quickly drive projects to closure, while keeping in mind the ultimate outcome of enabling future final use options to return the property to productive and valuable use without rebound liability.
Lifecycle Costs of Remediation
While the most significant cost of a remediation project is typically the expense of the remediation itself, the overall lifecycle cost of a project can be impacted significantly by the following:
- How efficiently a project moves from stage to stage (milestones) and, ultimately, to closure. Many projects get stuck at some point along this path, often significantly increasing the overall project lifecycle cost. Maintaining project velocity through each milestone can keep costs in check.
- The project team’s understanding of critical aspects of the Conceptual Site Model (CSM) before remedies are selected and implemented. Often, projects jump to a remedy—particularly interim remedies—before there is a clear understanding of the CSM (i.e., constituents of concern (COCs), pathway, receptors), resulting in premature or only partial remediation.
- Failure to address all risks associated with a site. This can include physical risks associated with buildings, foundations, and other historical operating structures and equipment.
- The project team’s understanding of the designed project end point. A periodic assessment of the end point of a project is vital to aligning stakeholders and ensuring that all efforts are directed toward the desired outcome. As data and information are collected on a project, it is sometimes necessary to reset the project strategy toward an alternative end point.
- How efficiently and effectively the project team communicates critical project information for decision making. A portfolio-based approach establishes a standard way of communicating project activities, schedule, and budget. This allows for more efficient communication between critical internal stakeholders (e.g., legal, public relations, real estate, and senior management) and with external consultants/advisers.
Portfolio-Based Management Model
There are several key elements to developing an effective portfolio-based management model, including those described in the sections below.
Standard Project Milestones
Controlling a large number of ongoing site remediation projects requires establishing a series of standard project milestones (i.e., project progressions) and associated work subtasks. This standardization establishes a common language and sets the framework for developing common subtasks for project budgeting and scheduling.
A milestone structure for remediation projects would typically include the items listed below. This structure can be adapted to projects where certain impacts to groundwater or soils can move at different velocities through project milestones.
- Project startup: Early project activities that typically include records review, strategy development, regulatory agreement negotiations, etc.
- Preliminary site investigation: Initial data gathering to assess the nature and extent of the impacts; may end with a Remedial Investigation Report (RIR)
- Site characterization and risk assessment: Complete characterization of the site to develop a CSM based on COCs, pathways, and receptors, and to identify physical aspects of the site that must be addressed as part of the project
- Feasibility study: Assessment of alternative remedial options
- Final design: Post-regulatory approved remedy design
- Implementation and OM&M: Remedy implementation and ongoing operation, maintenance, and monitoring
- End point: The targeted point for each project when all work necessary to eliminate the risk has been conducted or the point when no further work will result in additional risk mitigation
Standardized Work Breakdown Structure
For each of the milestones, a common set of subtasks is established to facilitate the development of detailed project workplans and for schedule and cost tracking. These subtasks ensure that workplans consider all the activities required to complete the work and allow for standardization across projects.
Having standardized project milestones and subtasks creates an additional benefit in that they can be used to create a more consistent and documented method for estimating contingent liability under ASC 450-20. By developing lifecycle cost estimating rules for each milestone, a company can ensure that its projects are using a common estimating logic (i.e., known and estimable) for determining the cost of investigation, design, and remedy implementation. A similar process could also be developed to ensure common estimating standards are applied to AROs ASC 410.
Project Control and Change Management
One common flaw in remediation projects is the tendency to enter into interim remedies or to identify a remedy that is not supported by data. This often results in incomplete remedies being implemented or remedies being installed that are not tied to a clear end point.
Developing standard project workplans allows for efficient project control and change management. As work progresses through milestones, data and information emerge to help identify a data-driven set of alternative remedies or a presumptive remedy. The disciplined progression of a project through milestones prevents projects from jumping to a preferred remedy without supporting data.
In addition, periodic review meetings—a key project control—create touch points to:
- Review all aspects of the project’s scope, schedule, and budget
- Test the validity of the end point
- Emphasize the continued forward momentum of the project
Centralized Project Database
Implementing a centralized database, such as Kestrel’s liability and asset management tools, to house all project workplans and other key documents provides another valuable project control. The central project database becomes the real-time repository for project information. Functionality includes the following:
- An internal database for tracking project scope, schedule, and budget for projects in a web-based workplan format
- Exportable workplans for use outside the database
- Password-protected access of the system to allow consultants to see only their projects and company staff to see all projects
- Front-end dashboard to allow senior management to monitor key project activities/status at a glance
- Ability to store key documents for each project
- Customizable project information page that houses project information (e.g., key contacts, project details, COCs, involved media)
- Customized project reports and summaries
- Ad hoc query capability
Periodic Project Reviews
Despite all good intentions, projects (particularly complicated ones) can drift off track or hit dead ends. When these situations occur, Integrated Site Reviews (ISR) can keep projects progressing to the appropriate end point.
A formal ISR can include an external facilitator for larger, more complex projects or be adapted by the project team for smaller projects. An ISR typically follows these steps to validate the project’s direction or to reset a new direction:
- An ISR team is formed consisting of a cross-functional group of stakeholders that could include the consultant, legal, internal environmental manager, real estate, operational staff, and other outside experts. Pulling together all stakeholders ensures that there is alignment and agreement on the selected end point.
- The ISR team meets (typically for no longer than a day) and goes through a structured review of technical, regulatory, legal, and third-party project drivers.
- Depending on the stage of the project, a blue sky set of alternative end points is identified.
- The alternative end points are developed, discussed, and evaluated.
- In the end, the current end point is either validated or a new end point is developed.
- All necessary changes to the project workplan are made.
Companies can respond to the challenge of managing contaminated properties by either internally staffing up to provide day-to-day oversight of the projects or by outsourcing the projects to a consultant, who can efficiently execute the project and serve as the public face. Whichever route a company decides to take, following the key elements described above will allow for effective portfolio-based management that will reach the desired end points.
Regulatory enforcement, customer and supply chain audits, and internal risk management initiatives are all driving requirements for managing regulatory compliance obligations. Many companies—especially those that are not large enough for a dedicated team of full-time staff—struggle with how to effectively resource their regulatory compliance needs.
Striking a Balance
Using a combination of in-house and outsourced resources can provide the appropriate balance to manage regulatory obligations and maintain compliance.
Outsourcing provides an entire team of resources with a breadth of knowledge/experience and the capacity to complete specific projects, as needed. At the same time, engaging in-house resources allows the organization to optimize staff duties and ensure that critical know-how is being developed internally to sustain compliance into the future.
Programmatic Approach to Compliance Management
Taking a balanced and programmatic approach that relies on internal and external resources and follows the three phases outlined below allows small to mid-size companies to create standardized compliance management solutions and more efficiently:
- Identify issues and gaps in regulatory compliance
- Achieve compliance with current obligations
- Realize improvements to compliance management
- Gain the ability to review and continually improve compliance performance
Phase 1: Compliance Assessment
A compliance assessment provides the baseline to improve compliance management and performance in accordance with current business operations and future plans. The assessment should answer the following questions:
- How complete and robust is the existing compliance management program in comparison with standard industry practice?
- Does it have the capability to yield consistent and reliable regulatory compliance assurance?
- What improvements are needed to consistently and reliably achieve compliance and company objectives?
It is important to understand how complete, well-documented, understood, and implemented the current processes and procedures are. Culture, model, processes, and capacity should all be assessed to determine the company’s overall compliance process maturity.
Phase 2: Compliance and Program Improvements
The initial analysis of the assessment forms the basis for developing recommendations and priorities for an action plan to strengthen programs, building on what already exists. The goal of Phase 2 is to begin closing the compliance gaps identified in Phase 1 by implementing corrective actions, including programs, permits, reports, training, etc.
Phase 2 answers the following questions:
- What needs to be done to address gaps and attain compliance?
- What improvements are required to existing programs?
- What resources are required to sustain compliance?
Phase 3: Ongoing Program Management
The goal of Phase 3 is to improve program processes to eliminate compliance gaps and transition the company from outsourced compliance into compliance process improvement/program development and implementation. This is done by managing the eight functions of compliance—identifying what’s needed, who does it, and when it is due. Ongoing maintenance support may include periodic audits, training, management review assistance, Information Systems (IS) support, and other ongoing compliance activities.
For one Kestrel client, business growth has increased at a rate prompting proactive management of the company’s regulatory and compliance obligations. Following a Right-Sized Compliance approach, Kestrel assessed the company’s current compliance status and programs/processes/procedures against regulatory requirements. This initial assessment provided the critical information needed for the Kestrel team to help guide the company’s ongoing compliance improvements.
Coming out of the onsite assessment, Kestrel identified opportunities for improvement. Using industry standard program templates, in combination with operation-specific customization, Kestrel created programs to meet the identified improvement from the assessment. Kestrel then provided onsite training sessions and is working with the company to develop a prioritized action plan for ongoing compliance management.
Using the appropriate methods, processes, and technology tools, Kestrel’s programmatic approach is allowing this company to implement EHS programs that are designed to sustain ongoing compliance, achieve continual improvements, and manage compliance with efficiency through this time of accelerated growth.
Making the Connection
Kestrel’s experience suggests that the connection between management and compliance needs to be well synchronized, with reliable and effective regulatory compliance commonly being an outcome of consistent and reliable program implementation. This connection is especially important to avoid recurring compliance issues.
Following a programmatic approach allows companies to realize improvements to their compliance management and:
- Organize requirements into documented programs that outline procedures, roles/responsibilities, training requirements, etc.
- Support management efforts with technology tools that create efficiencies and improved data management
- Conduct the ongoing monitoring and management that are vital to remain in compliance
- Gain the inherent capacity, capability, and maturity to comply, review, and continually improve compliance performance
An audit provides a snapshot in time of a company’s compliance status. An essential component of any compliance program—health and safety, environmental, food safety—an audit captures compliance status and provides the opportunity to identify and correct potential business losses. But what about sustaining ongoing compliance beyond that one point in time? How does a company know if it has the processes in place to ensure ongoing compliance?
Creating a Path to Compliance Assurance
A compliance assurance review looks beyond the “point-in-time” compliance to critically evaluate how the company manages compliance programs, processes, and activities, with compliance assurance as the ultimate goal. It can also be used as a process improvement tool, while ensuring compliance with all requirements applicable to the company.
This type of review is ideal for companies that already have a management system in place or strive to approach compliance with health and safety, environmental, or food safety requirements under a management system framework.
Setting the Scope
The scope of the review is tailored to a company’s needs. It can be approached by:
- Compliance program/topic where the company has had routine compliance failures
- Compliance program/topic that presents a high risk to the company
- Compliance program/topic that spans across multiple facilities that report to a central function
- Location/product line/project where the company is looking to streamline a process while still ensuring compliance with multiple legal and other requirements
While each program, project, or location may differ in breadth of regulatory requirements, enforcement priorities, size, complexity, operational control responsibilities, etc., all compliance assurance reviews progress through a standard process that ties back to the management system.
Continual Compliance Improvements
Through a compliance assurance review, the company will define and understand:
- Compliance requirements and where regulated activities occur throughout the organization
- Current company programs and processes used to manage those activities and the associated level of program/process maturity
- Deficiencies in compliance program management and opportunities for improvement
- How to feed review recommendations back into elements of the management system to create a roadmap for sustaining and continually improving compliance
An environmental and safety compliance leader with over 20 years of corporate, academic, and government experience, Becky Wehrman-Andersen has joined Kestrel as a Senior Consultant, based out of Des Moines, Iowa. Becky has hands-on experience in chemistry safety, regulatory compliance, hazardous waste management, emergency response, training, compliance assessments, EPA negotiations, and biological and chemical sciences.
Becky has particular expertise in hazardous waste management, hazardous waste site assessments, special waste identification and permitting, complex hazardous pharmaceutical disposal strategies, emergency response, risk identification and technical support. She is an expert in chemical risk management and environmental compliance, and has exceptional experience as an expert witness and in negotiating EPA and DNR penalty reduction. Further, Becky is adept in safety program management, training, and market development consultation. She is a professional speaker/trainer with extensive experience in training on the technical aspects of EPA, OSHA, and DOT compliance and chemical risk minimization, and is a North American Hazardous Materials Managers (NAHMMA) and Solid Waste Association of North America (SWANA) certified trainer.
Read Becky’s complete bio for more information.
BY: Stacey Pisani
Comments: No Comments
Talk about starting an Unmanned Aerial System (UAS) (a/k/a “drone”) program is happening at companies of all sizes, but establishing the right foundations to ensure these kinds of programs don’t fail is far less pervasive. At DJI AirWorks 2018, Kestrel Consultant, Industrial UAS Programs, Rachel Mulholland’s presentation, “Bringing Your Drone Program to Scale: Lessons Learned from Going Big” laid out what it means to achieve success and avoid failure with the technology.
Commercial UAV News recently caught up with Rachel to further discuss her presentation, which focused on UAS applications for infrastructure, explored why UAS programs fail, and detailed the foundations of a successful drone program. In the published interview, she details some of her lessons learned from out in the field, what it means to deal with positive and negative assumptions people have about the technology, why it is so important to have a UAS Program Operations Manual, and much more.
BY: Stacey Pisani
Comments: No Comments
The AirWorks 2018 Conference is focused on the growing commercial drone industry and how developers, partners, and operators can work to reshape the global economy with drones. This year, Kestrel Management will be teaming with Union Pacific Railroad to talk about our experience and lessons learned from managing industrial-scale drone programs.
October 30 – November 1, 2018
Kestrel Presentation: Bringing Your Drone Program to Scale: Lessons Learned from Going Big
Thursday, November 1 at 11:00 a.m.
Rachel Mulholland, Kestrel Management Consultant, Industrial UAS Programs
Edward Adelman, Union Pacific Railroad, General Director of Safety
This presentation will discuss the risks and opportunities associated with building an industrial drone program and share some of the lessons learned from our experience. We’ll discuss common questions, including the following:
- What does it take to build an industrial drone program?
- How can UAS technology fit into your current business model?
- What challenges can occur with fleets of certified remote pilots and unmanned vehicles?
- How do you ensure you operate in compliance with FAA regulations?
- What are some common pitfalls to avoid and best practices to incorporate into your program?
Why You Should Attend
If you currently have a drone program or are looking to implement one, this event is for you!
- Attend sessions focused on the industry track most relevant to your business: construction, energy, agriculture, public safety, infrastructure
- Network with companies that are on the forefront of enterprise drone adoption
- Get a preview of the latest drone technologies
- Receive hands-on training from experienced industry leaders and instructors
The U.S. Court of Appeals for the District of Columbia Circuit ruled on Friday, September 21, 2018 that the EPA must implement the Obama-era Risk Management Plan (RMP) Rule. This comes on the heels of the Court’s ruling on August 17, 2018, which stated that EPA does not have authority to delay final rules for the purpose of reconsideration. Usually, the Court would allow 52 days for the EPA to consider appealing the order and to plan how to implement the rule; however, groups supporting the regulation argued that it can’t wait.
Read more about the currently Court ruling.
On Monday, September 17, 2018, the Office of the United States Trade Representative (USTR) released a list of approximately $200 billion worth of Chinese imports, including hundreds of chemicals, that will be subject to additional tariffs. The additional tariffs will be effective starting September 24, 2018, and initially will be in the amount of 10 percent. Starting January 1, 2019, the level of the additional tariffs will increase to 25 percent.
In the final list, the administration also removed nearly 300 items, but the Administration did not provide a specific list of products excluded. Included among the products removed from the proposed list are certain consumer electronics products, such as smart watches and Bluetooth devices; certain chemical inputs for manufactured goods, textiles and agriculture; certain health and safety products such as bicycle helmets, and child safety furniture such as car seats and playpens.
Individual companies may want to review the list to determine the status of Harmonized Tariff Schedule (HTS) codes of interest.
Maturity assessments are designed to tell an organization where it stands in a defined area and, correspondingly, what it needs to do in the future to improve its systems and processes to meet the organization’s needs and expectations. Maturity assessments expose the strengths and weaknesses within an organization (or a program), and provide a roadmap for ongoing improvements.
A thorough program maturity assessment involves building on a standard gap analysis to conduct a holistic evaluation of the existing program, including data review, interviews with key staff, and functional/field observations and validation.
Based on Kestrel’s experience, evaluating program maturity is best done by measuring the program’s structure and design, as well as the program’s implementation consistency across the organization. For the most part, a program’s design remains relatively unchanging, unless internal modifications are made to the system. Because of this static nature, a “snapshot” provides a reasonable assessment of the design maturity. While the design helps to inform operational effectiveness, the implementation/operational maturity model assesses how completely and consistently the program is functioning throughout the organization (i.e., how the program is designed to work vs. how it is working in practice).
A design maturity model helps to evaluate strategies and policies, practices and procedures, organization and people, information for decision making, and systems and data according to the following levels of maturity:
- Level 1: Initial (crisis management) – Lack of alignment within the organization; undefined policies, goals, and objectives; poorly defined roles; lack of effective training; erratic program or project performance; lack of standardization in tools.
- Level 2: Repeatable (reactive management) – Limited alignment within the organization; lagging policies and plans; seldom known business impacts of actions; inconsistent company operations across functions; culture not focused on process; ineffective risk management; few useful program or project management and controls tools.
- Level 3: Defined (project management) – Moderate alignment across the organization; consistent plans and policies; formal change management system; somewhat defined and documented processes; moderate role clarity; proactive management for individual projects; standardized status reporting; data integrity may still be questionable.
- Level 4: Managed (program management) – Alignment across organization; consistent plans and policies; goals and objectives are known at all levels; process-oriented culture; formal processes with adequate documentation; strategies and forecasts inform processes; well-understood roles; metrics and controls applied to most processes; audits used for process improvements; good data integrity; programs, processes, and performance reviewed regularly.
- Level 5: Optimized (managing excellence) – Alignment from top to bottom of organization; business forecasts and plans guide activity; company culture is evident across the organization; risk management is structured and proactive; process-centered structure; focus on continuous improvement, training, coaching, mentoring; audits for continual improvement; emphasis on “best-in-class” methods.
A gap analysis can help compare the actual program components against best practice standards, as defined by the organization. At this point, assessment questions and criteria should be specifically tuned to assess the degree to which:
- Hazards and risks are identified, sized, and assessed
- Existing controls are adequate and effective
- Plans are in place to address risks not adequately covered by existing controls
- Plans and controls are resourced and implemented
- Controls are documented and operationalized across applicable functions and work units
- Personnel know and understand the controls and expectations and are engaged in their design and improvement
- Controls are being monitored with appropriate metrics and compliance assurance
- Deficiencies are being addressed by corrective/preventive action
- Processes, controls, and performance are being reviewed by management for continual improvement
- Changed conditions are continually recognized and new risks identified and addressed
The logical next step in the maturity assessment involves shifting focus from the program’s design to a maturity model that measures how well the program is operationalized, as well as the consistency of implementation across the entire organization. This is a measurement of how effectively the design (program static component) has enabled the desired, consistent practice (program dynamic component) within and across the company.
Under this model, the stage of maturity (i.e., initial, implementation in process, fully functional) is assessed in the following areas:
- Adequacy and effectiveness: demonstration of established processes and procedures with clarity of roles and responsibilities for managing key functions, addressing significant risks, and achieving performance requirements across operations
- Consistency: demonstration that established processes and procedures are fully applied and used across all applicable parts of the organization to achieve performance requirements
- Sustainability: demonstration of an established and ongoing method of review of performance indicators, processes, procedures, and practices in-place for the purpose of identifying and implementing measures to achieve continuing improvement of performance
This approach relies heavily on operational validation and seeking objective evidence of implementation maturity by performing functional and field observations and interviews across a representative sample of operations, including contractors.
Performance within an organization is the combined result of culture, operational systems/controls, and human performance. Culture involves leadership, shared beliefs, expectations, attitudes, and policy about the desired behavior within a specific company. To some degree, culture alone can drive performance. However, without operational systems and controls, the effects of culture are limited and ultimately will not be sustained. Similarly, operational systems/controls (e.g., management processes, systems, and procedures) can improve performance, but these effects also are limited without the reinforcement of a strong culture. A robust culture with employee engagement, an effective management system, and appropriate and consistent human performance are equally critical.
A culture assessment incorporates an assessment of culture and program implementation status by performing interviews and surveys up, down, and across a representative sample of the company’s operations. Observations of company operations (field/facility/functional) should be done to verify and validate.
A culture assessment should evaluate key attributes of successful programs, including:
- Vision & Values
- Goals, Policies & Initiatives
- Organization & Structure
- Employee Engagement, Behaviors & Communications
- Resource Allocation & Performance Management
- Systems, Standards & Processes
- Metrics & Reporting
- Continually Learning Organization
- Audits & Assurance
Assessment and Evaluation
Data from document review, interviews, surveys, and field observations are then aggregated, analyzed, and evaluated. Identifying program gaps and issues enables a comparison of what must be improved or developed/added to what already exists. This information is often organized into the following categories:
- Policy and strategy refinements
- Process and procedure improvements
- Organizational and resource requirements
- Information for decision making
- Systems and data requirements
- Culture enhancement and development
From this information, it becomes possible to identify recommendations for program improvements. These recommendations should be integrated into a strategic action plan that outlines the long-term program vision, proposed activities, project sequencing, and milestones. The highest priority actions should be identified and planned to establish a foundation for continual improvement, and allow for a more proactive means of managing risks and program performance.