KM on a dollar a day

Musing on knowledge management, aid and development with limited resources

Afraid of responsibility? Try regulation.

with 7 comments

My colleague Mark recently started a personal blog (which incidentally helped finally get me off the fence to start blogging too). He recently posted a piece “guidance and when to ignore it” that really resonated with me, and got me thinking about both the value and the pitfalls of regulation and guidelines and how we develop and use them. I’m referring here mainly to the world of aid and development – but I think the same ideas might have a broader application too.

Of course rules and guidelines do perform useful functions: they are good to ensure  standardization and consistency, when we know the right way or best way to do something – they are especially good for assembling and operating things, and good to deal with compliance issues such as legal and administrative requirements. They can be a good way to capture and share good practice and try to ensure it is being followed on the ground.

Rules are less good when we don’t know the best way to do something, or how the rules will be interpreted and implemented by the people they are intended for. They are also frequently not good when done quickly in the aftermath of an unforeseen crisis in order to “make sure this never happens again”.

Here are some of the problems that we face with rule writing:

  • The rules can’t cover every eventuality. Trying to cover every eventuality is a fruitless activity since there will always be some exceptional circumstance that we weren’t able to predict, and the more we try to map out every eventuality then the more complicated, and potentially confusing the rules will become.
  • Do we actually know the best way to do things (even if we think we do). Although guidance can be a good way to ensure people follow well founded good practice, there is a risk to putting things into guidance where we don’t really have strong evidence that we know the best approach since at best we close off possibilities to improve procedures by not allowing variation, at worst we institute sub-standard procedures as institutional practice.
  • They can stifle innovation and improvements due to compliance. Related to the above point – if procedures are monitored and reported on for compliance, and reputations are influenced as much by whether the follow the rules as whether they improve programmes, then people will not risk stepping out of the box to try something new, for risk of sanction.
  • Having rules can put us on autopilot. In other words, having everything written down step by step makes it easy for us just to follow procedure, without thinking about whether what we are doing makes sense in the situation we face. Also if we follow the rules then surely we are not responsible if something goes wrong – after all we did what we were supposed to do.
  • The cost of compliance can be worse than the risk we are trying to avoid. If regulations are overly onerous, or are in place to address risks that are in reality extremely unlikely, then the cost of implementing a rule (in terms of money, people’s time and lost opportunities) could far exceed the benefits. This often happens in reaction to a crisis (accounting scandals, financial crises, terrorist threats?) and in the development world frequently as a result of a bad audit. What can be worse is that the rules put in place in these circumstances may have more with being seen to do something, rather than them actually being effective, even against the risks they are supposed to address.
  • Unintended consequences. Guidelines – like anything theoretical put into practice, can have consequences not foreseen at the time they were written. People misinterpret the rules, or find ways to work around them to get their work done. The more complicated the rule, the greater chance it will not be implemented as intended. Sometimes the response when this is discovered is to make the rule yet more detailed and complex to try to close any loopholes and misinterpretations  – often this has the opposite effect from that intended.

So what can be done about this? I don’t have all the answers – but here are a few suggestions:

  • Get input and feedback on new rules and guidelines from those who will be implementing them to see if they are useful, feasible and that they are understood correctly.
  • Build ongoing mechanisms to provide feedback and have discussion on adequacy of guidelines from the perspective of those using it.
  • Don’t do manuals and guidelines if we don’t really know what we are recommending works/is the best way – it’s maybe better to be clear that this is a good practice, tool or guideline to help inform decision making – but be clear that it’s not ”the law”.  Differentiate in guidance between “must dos” and “good practices to consider”.
  • Whenever a new guideline is being considered, look at whether the cost imposed is merited given the risk being addressed or the potential benefit gained. Verify this in practice once the rule is in place.
  • Once in a while do a thorough review of guidance to check its all consistent and that it is all really necessary. Try to make a conscious effort to simplify, streamline and delete on a regular basis to avoid that the system of rules becomes ever longer and more complex.
  • Have a helpdesk or some other kind of ongoing means of communication to keep rule makers and rule followers in touch with each other to get feedback on how well rules are understood, how they are interpreted and how well they work in practice.
  • When using manuals and guidelines we have to make sure we don’t go into autopilot, but still think about what we are doing and whether we should follow the guidelines or make a reasoned decision not to follow it. The organizations where we work need to support managers to take this kind of accountability on themselves and not be punished for doing the right thing in practice over the right thing in law.

What do you think?

Written by Ian Thorpe

November 29, 2010 at 10:30 am

Posted in Uncategorized

7 Responses

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  1. Great post Ian! It really hits home too. One thing that your post reminded me of was hearing Robert Chambers from IDS speak once about determining a few clear minimum standards, rather than trying to come up with a rule for everything, and then trusting people to follow those standards. IBM’s social media policy is sometimes used as a good example of that. http://www.ibm.com/blogs/zz/en/guidelines.html

    Linda Raftree

    November 29, 2010 at 11:01 am

  2. […] established set of procedures, but these are usually best expressed in the form of guidance (and see my earlier critique of guidance). In practice though I’ve often seen the term used for practices about which there is […]

  3. […] 1. Wrapping ourselves in red-tape. In large organizations there is a guideline and a procedure for everything, frequently written in unclear bureaucratic language,  often trying to mitigate every possible risk, however unlikely, except the risk that the guideline will be too complex to understand or follow. Given the difficult in drafting guidance, and getting agreement on it, the guidance is likely to be out of date with recent developments, or unintentionally conflict with other existing guidance, or by buried in some obscure corner of the intranet that no-one visits. Of course guidance is necessary, but I can’t help but feel that the way much guidance is written gives the impression that following rules is more important than achieving results, and that fundamentally all these rules exist because we don’t trust our staff to be  responsible and accountable (not you and me you understand – but those other idiots who don’t know what they are doing or can’t be trusted). I expanded on this theme more in a previous blog: afraid of responsibility – try regulation. […]

  4. […] past posts I’ve talked about the problems of relying too much on rules, guidelines and so-called “best practices” in development work. And while big organizations […]

  5. Many thanks for helpful information in your posting Afraid of responsibility?

    Try regulation. KM on a dollar a day…
    Bye…

    Dubai Offshore

    September 23, 2012 at 6:38 pm

  6. […] are not always the most effective or sustainable.  I’ve written previously about the dangers of over-regulation and of how that can sometimes give the illusion of control over a situation when in fact by making […]

  7. […] some of the problems with how we develop rules and the large number of them (see earlier post “afraid of responsibility – try regulation”). But rules are also very valuable in ensuring that as public employees are accountable both to […]


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