Non-compliance in Complex Operations - A Case Study Led Discussion
Authors: Hudson T. G. L. , Hudson P. A. R. , Hudson P. T. W. 
Published: September 2024

Objectives/Scope

The paper discusses the factors that contribute to non-compliant behaviour in complex operations. The anonymised results of a number of in-depth analyses and meta-analyses across multiple industries including Oil and Gas and Aviation are used to consider the organizational causes of non-compliance and the possible remedies available to organisations. These range from physical plant changes to amendments to contracting regimes.

Methods, Procedures, Process

Situations where non-compliance was more likely to occur were identified using investigation methods: meta-analysis of incidents using the Meeting Expectations modelthe procedures and practices questionnaire based upon the "Hearts and Minds" safety culture approacha series of workforce interviews and focus groupsphysical on-site observations as well as human factors analysis of the locations.

The results are placed within the concepts of loci of control, span of control, and the risk dimensions managed to provide an understanding of what is driving non-compliance.

Results, Observations, Conclusions

The analysis points to the main drivers for non-compliance falling into a number of broad categories. Each of these categories have distinct contributing factors that have different organizational remedies.

These categories are: Operational pressure: The workload in the environment creates the (perceived) need to create deviation from documented procedures to enable the execution of assigned tasks in a timely fashion.Physical environmental mismatches: The physical environment does not actually conform to the design standards that the procedures are written for.Complex interactions: The complexity of interactions between parties creates a breakdown in prioritization in tasking and the lack of lines of accountability creates confusion and non-compliant behaviours. The solutions for the different categories can be seen as the explicit acceptance that the space the organisation operates in is more complex than the rule set the workforce is subjected to.For operational pressure the organisation has to explicitly recognise the situations where the workload is too high. The most common place for this is in planning. This can then be remedied by either changing the workload or providing more resources.For Physical environment mismatches the organisation has to explicitly accept that not all rules are fit for purpose. The introduction of tools such as variance procedures provide the ability to remain in compliance with the reason for procedures rather than the procedures as written.For Complex interactions the organisation has to explicitly recognise that even simple operations can be subjected to highly complex interactions. By managing complex interactions and ensuring proper accountabilities organisations can limit their exposure to these situations. This often entails changes in key performance indicators and contract structures.

Novel/Additive Information

The paper describes non-obvious managerial solutions to non-compliance.