Tuesday, May 29, 2012

The danger of predictable procedures

Days go by. Years go by. A new procedure is added to an old one, the system expands and it becomes more and more difficult to manage. Special systems are developed to manage the more and more complex system, and others are put there to monitor that the system to manage the system is systematically and consistently applied.

We all know the story. We have seen it. Some even claim that this increasing complexity
brought down empires. When the purpose is to protect citizens from ills it is even easier to accept that there is no end to what can be done and, therefore, has to be done. Airport security is a very clear example in point. However, now after a decade of ever increasing scrutiny and more procedures, not only passengers, but also security officials, question the wisdom of this. In a poll reported by The Economist, 87% of the respondents thought that changes implemented since 2001 had done more harm than good.

Kip Hawley, the former head of the US Transportation Security Administration (TSA), says in an article in the Wall Street Journal that the system needs reform. Two of the issues he singled out are also of particular relevance to the organic inspection and certification system. By checking a multitude of minute details, focus is easily lost
from the really important issues. Tests conducted by the TSA itself show that when officers are busy hunting cigarette lighters and pocket knives they may very well overlook
the dummy bomb parts placed next to them. And by making the system predictable and rigid, terrorists are helped more than deterred.

Organic operators are not airline passengers and the odd fraudster in the organic sector is not a terrorist; it is likely there are many more organic fraudsters in my plane than terrorists. Nevertheless, these observations may well hold for the organic inspection
and certification system. I have come across certification bodies, and regulatory authorities for which ‘annual inspection’ meant literally every 12 months, making it completely predictable when the next inspector will come. The minute detail that is recorded and made an issue of – largely a result of standards and certification requirements growing exponentially – substantially reduces the attention that is given to
more important things, and in particular to any kind of qualitative evaluation. The word ‘evaluation’ is probably missing from most audit forms.

Instead of helping, quality management systems used by certification bodies, aggravate the problem. The main tool for quality management is a standard operating procedure, which essentially means actions are predictable – for fraudsters as well as all other operators. Creativity and acting on a hunch or intuition are largely banned from such a system. But making imaginative, unprecedented effort can yield a lot more than following a prescribed course. For instance, in most cropping systems, there is a specific period when fertilisrs are applied. However, a few weeks after an application it is basically impossible to determine whether a fertiliser has been used or not. Despite this, most farms are never visited at those times. Certification bodies could redirect their effort one year to visit most or all farms at the critical time – or the time of sowing to detect treated seeds, or the time of insect attacks to determine use of a pesticide. But it would not be possible to conduct full inspection visits because that would be too resource demanding. Likewise,
to make a full, comprehensive (on site and crosschecking information) audit of a whole supply chain of products randomly selected (or based on a suspicion) in shops could disclose fraud in a way that routine audits hardly ever do.

There are many good and creative measures that can be taken to improve the organic certification system, and there are many good ideas among the talented people working within the system. But the attention of certifiers, accreditors and regulators is far too
often directed at the management of a system of ever increasing complexity. Unfortunately, when systems are too rigid they also drive away creative people, as they can’t flourish. In this way, the system produces people who believe there is only one right way of doing the job. And that is not a good starting point – neither for disclosing organic fraud nor for detecting terrorists in the making.

Published as Leader in The Organic Standard issue 133

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