Conducting Root Cause Investigation Meetings vs. Facilitating Problem Solving Discussions

I began this Deviation and CAPA series with the intent to share what I call the human performance improvement (HPI) touch points; where HPI and the CAPA quality system have cross -over connections.  See The Big Why of Deviations and Why Do CAPAs Fail Their ECs.  In this two-part blog, I will reveal another noteworthy HPI crossover connection.

If you perform a Google search on CAPA process and the ensuing steps, the results are varied but in general, industry follows a routine process that looks like the following:

  • Compliant “CAPA” Program includes procedures for:
    • Discovery and Notification
    • Containment
    • Impact Assessment
    • Product Investigation
    • RC Investigation
    • Corrective Actions (CA)
    • Prevention Actions (PA)
    • Effectiveness Checks (EC)
    • Close

If you are satisfied with the results you are getting, great, more success to you!  One of the misconceptions about today’s CAPA process is that it suggests the steps start and end cleanly and the process moves in a linear fashion. I have one of those theory vs. practice moments where what is supposed to happen “if you correctly follow this process” does not happen in reality.  That somehow it’s the fault of the lead investigator if it’s not progressing as described. 

Deviations and CAPA investigations are not theoretical. As the investigation unfolds and the true story is discovered, we learn quickly that the process is really iterative.  Often we find ourselves back at the beginning, rewriting the event details and fine tuning the problem statement or re-examining the root cause because a repeat deviation occurred.  Frustrated that the clock is ticking and the pressure to get ‘em closed is always in the forefront of the investigation, there is no time allowed to think outside this process; no room for creatively solving the problems.  The mere mention of creativity makes some compliance professionals break out in hives. 

I get it.  The intention of the process is to provide a structured approach to conduct the investigation and manage the related CAPA when assigned.  Otherwise, it’s too overwhelming and unwieldy.  We could go down a rabbit hole and never close an investigation or come up with totally out of the question corrections.  However, it seems to me that we’ve ingrained these steps into routine habit, that our root cause investigation meetings have also become check the boxes to get the CAPA closed on time!  Hence, our industry is still getting “inadequate investigation” observations.  Could there be a causal relationship?

So, if you seek something else, I am proposing a problem-solving model below that mirrors very closely with CAPA.  The following problem-solving steps give us the freedom to consider new ideas and new possibilities for solving the same repeated problems without violating our Deviation and CAPA procedures.

DEFINING THE PROBLEM

It sounds simple enough to do.  Collect the event details.  Answer the universal questions.  And lo behold, the problem should be evident.  SMEs unwittingly suffer from the curse of too much knowledge and as they learn more about the event, they tend to form early hypothesis about the problem especially if they’ve seen a similar event.  They tend to collect evidence about problems they are familiar with and understand.  Unfortunately for most, they seldom go beyond their current knowledge base. 

In the Qualifying SMEs as Investigators Program, nominees are asked to discuss and prepare their response to the following question: Is the problem different from the cause?  Initially, everyone nods his or her head yes with a baffled look as to why further discussion is needed.  In their break out groups, I ask them to prepare their group rationale. And then it happens, a few will inadvertently slip in the cause with the problem explanation and to their amazement they are stunned at hearing these words.  Alas, that’s the point.  Before you can assign the root cause, you need to know what the problem really is.

WHAT DO I ASK TO FIND THE CAUSES?

“To find the answer, ask a lot of questions first”.  The discovery of a non-conformance, deviation or discrepancy is usually triggered by an event and thus the investigation begins here.  In the event stage, not only are investigators collecting details they also interview the individual performers who are involved.  However, there are three levels of interaction that can influence performance:

  • The individual performer level
  • The process level
  • The systems level.

To identify the possible causes not just the obvious one, the investigation team needs to move beyond just the event triggers.

Moving from Events to Patterns and Systems Influences

If we keep the scope limited to the event and performers involved “as an isolated incident”, we often find that the easy way out (aka the fastest way to close the investigation) will often lead back in with more repeat deviations.  So, we need to expand the investigation to include other individuals and /or other similar incidents to look for a pattern or a reoccurring theme.

(c) HPIS Consulting, Inc.

As investigators, we need to keep asking questions that enable information sharing to drive a deeper understanding of what the individuals were/are experiencing when performing their part of the tasks within the process. 

Mapping the task/process helps SMEs to re-trace the steps or sub-tasks rather then rely on their memory (their expertise reservoir).  Many SMEs think they know the procedure and will often state a step from an older version of the SOP or will be surprised to see new changes in the most current version of the procedure.  In this group review, SMEs can look for weaknesses and offer their insights about the point of discovery. 

Within this process analysis/review, ask are there other procedures that have been implicated in other deviations?  What about the hand offs; the linkages between the procedures and other quality systems?  Are these clearly defined and understood or are these the basis of “miscommunication” causes between other groups?  The big question to ask is what would happen if we left it alone? What other systems would be impacted?  When investigation teams are given the time to explore (investigate) enough, they often find these system glitches just waiting to contribute to another deviation.

Problem Solving ala Systems Thinking

Peter Senge in his 1990 ground breaking book, The Fifth Discipline: The Art and Practice of the Learning Organization, describes a system as being perceived whole whose elements “hang together” because they continually affect each other over time and operate toward a common purpose.  There’s a pattern of interrelationships among the key components of the system, including the ways decisions are made.  Often invisible until someone points them out.

Systems thinking allows problem solvers to see the event in the context of the whole system not just individual performers or procedure.  They see patterns of recurring problems that deepen their understanding of the situation and leads them to reframe the problem, thus providing a new framework from which to generate an additional set of possible causes.

The next blog will continue describing the problem-solving model and explore other quality tools investigation teams can use. – VB

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(c) HPIS Consulting, Inc.

Investigations 101: Welcome Newbies

So the event description is clarified and updated. The assigned investigator is up to speed on the details of “the story”.  What happens next? What is supposed to happen?  In most organizations, there is rush to find the root cause and get on with the investigation.  A novice investigator will be anxious to conduct the root cause analysis (RCA).  S/he can easily make early root cause mistakes like grabbing the first contributing factor as the root cause without being disciplined to explore all possible causes first.

Thus it makes sense to get the Investigators trained in root cause analysis. Unfortunately for many, this is the ONLY training they receive and it is not nearly enough. RCA is a subset of the investigation process and the training agenda is heavy on the tools, which is perfectly appropriate.  But when do they receive training on the rest of the investigation stages like determining CAPA significance and writing the report?  Given the amount of FD-483 observations and warning letter citations for inadequate investigations that continue to be captured, I’d say we need more training beyond RCA tools.  As a result, we are starting to see FDA “recommendations” for trained and QUALIFIED Investigators.  This means not only in how to conduct a root cause analysis, but also the Deviation and CAPA Process. 

This goes beyond e-sign the Read and Understand procedures in your LMS

E-Doc systems are a great repository for storing controlled documents.   Searching for SOPs has become very efficient.  In terms of documenting “I’ve read the procedure”, very proficient and there’s no lost paperwork anymore!  But learning isn’t complete if we’ve merely read through the steps.  We also need to remember it.  At best, we remember that we read it and we know where to find it when we need to look something up.  Does that translate to understood?  Maybe for some. 

To help us remember the actual steps, we need to do something with the knowledge gained.  This is where the responsibilities section of the procedure tells us who is to do what and when.  But the LMS doesn’t include structured and guided practice as part of the assigned curricula.  Unless your equipment and complex procedures are also flagged for Structured OJT and possible Qualification Events as in most Operations groups, practice happens incidentally as part of on the job experience.  Feedback is typically provided when there’s a discrepancy or a deviation.  This is reactionary learning and not deliberate practice. 

If we want Deviation Investigators to understand and remember their tasks (procedures) so they can conduct investigations and write reports that get approved quickly, then we need to design learning experiences that build those skills and ensures accurate execution of assigned roles and responsibilities for Deviations and CAPAs. They need an interactive facilitated learner centered qualification program.

More than just studying a set of procedures and filling out related forms

It’s about putting the learners; the assigned SMEs as Investigators and QA Reviewers, at the center of the whole learning experience.  It’s about empowering them to take charge of their own learning by enabling them to experience real work deviations / CAPA investigations and to deliberately practice new skills in a safe environment with the assistance of adult learning facilitator(s) and coaches.  Thereby bridging the “R & U Only Knowledge Gap”.

The look and feel of the program follows a Learn By Doing approach with customized learning content, using interactive techniques and offering more hands-on opportunities for them to engage with real work application that ensures learners are immediately using the knowledge and tools in class and for their homework assignments thus increasing the connections for knowledge transfer.

This requires a shift from the traditional mindset of a classroom course where the emphasis is on the expertise of the instructor and the content. The learners and their learning experience becomes the priority.  The instructor’s task isn’t to deliver the content, it’s to help their learners acquire knowledge and skill.

Shifting the priority to a more engaging Learning Experience

Qualifying SMEs as Deviation Investigators Program

This unique curriculum uses a variety of teaching methods fostering more balanced and meaningful instruction over the duration of the program.  It is not a single course or 2-day training event.  It is delivered in modules, with weekly “homework” assignments consisting of active deviations and open investigations.

“Spaced learning works, in part, because the brain needs resting time to process information, create pathways to related information, and finally place the new information into long-term memory – the main objective of learning.” (Singleton, Feb 2018, p.71). 

Each module revisits the Investigation Stages and builds on the prior lessons by reviewing and debriefing the homework.  Then, expanding on that content and including new lessons with increasing intensity of the activities and assignments.

By design, the program provides time and space to interact with the content as opposed to delivering content dumps and overwhelming the newbies; short-term memory gets maxed out and learning shuts down. The collaborative participation and contributions from the Investigators and Program Facilitator(s) result in better overall engagement. Everyone is focused on accomplishing the goal of the program; not just checking the box for root cause analysis tools.

The goal of the program is to prepare subject matter experts to conduct, write and defend investigations for deviations and CAPAs.  The program also includes QA reviewers who will review, provide consistent critique and approve deviations, investigations, CAPAs. Attending together establishes relationships with peers and mutual agreement of the content.  The learning objectives describe what the learners need from the Deviation and CAPA quality system procedures while the exercises and assignments verify comprehension and appropriate application.

“Learning happens when learners fire their neurons, not when the trainer gives a presentation or shows a set of Power-Point slides.” (Halls, Feb 2019, p.71).

Qualified, really? Isn’t the training enough?

Achieving “Qualified status is the ultimate measure of the training program effectiveness.  For newly assigned Investigators, it means the company is providing support with a program that builds their skills and confidence and possible optional career paths.   Being QUALIFIED means that Investigators have undergone the rigor of an intensely focused investigations curriculum that aligns with the task and site challenges.  That after completing additional qualification activities, Investigators have experienced a range of investigations and are now deemed competent to conduct proper investigations.

For the organization, this means two things.  Yes, someone gets to check the FDA commitment box.  And it also means strategically solving the issues.  Better investigations lead to CAPAs that don’t fail their effectiveness checks.  Now that’s significant performance improvement worthy of qualifying Investigators!  -VB

References:

  • Campos,J. The Learner Centered Classroom. TD@Work, August, 2014, Issue 1408.
  • Chopra,P. “give them what they WANT”, TD, May, 2016, p.36 – 40.
  • Halls,J. “Move Beyond Words to Experience”, TD, February, 2019, p. 69 – 72 DL.
  • Parker, A. “Built to Last: Interview with Mary Slaughter”, TD, May, 2016, p. 57.
  • Singleton, K. “Incorporating a Spiral Curriculum Into L&D”, TD, February, 2018, 70 – 71.

HPISC Coaching Brief available here.

Why Do CAPAs Fail Their Effectiveness Checks?

When we start talking about deviations and CAPAs, we can’t help having a sidebar discussion about root causes and more specifically the rant about finding the true root cause.  I intentionally skipped that content in the previous blog.  It was my intention to kick off the new Deviation and CAPAs blog series by first looking at deviations by themselves.  And the learning opportunities deviations can provide us about the state of control for our quality systems.  From those deviations and ensuing CAPA investigations, I ask you this: are we improving anything for the long term (aka prevention).  Are we making any progress towards sustaining those improvements?

Corrective Actions Preventive Actions (CAPA) Steps

Let’s step back a moment and quickly review typical steps for CAPAs:

CAPA Components

The purpose of an Effectiveness Check (EC) is for verifying or validating that actions taken were effective and do not adversely affect product, device or process.  It goes beyond the statement in the investigation form to include a follow-up activity that closes the loop on the specific CAPA.  If an effectiveness check fails meaning the CA/PA was not effective or another deviation /nonconforming incident has occurred, we go back to the beginning and either start again or in most cases, we re-open the investigation.  The pressing question is why did the EC fail?  Almost instinctively, we believe that we did not find the true root cause.  Perhaps.  Was there a rush to close the investigation?  Probably.  Did the investigation team grab the first probable cause as the root cause because the “problem” felt familiar?  Maybe. Or is it a case of a fix that backfired into unintended consequences? Possibly. I will also suggest that the CA/PA may not have been aligned properly.

Ask these 3 questions about CA/PAs

  • Is the CA/PA Appropriate? The focus of this question is about the affected people.  What is the size of this audience? Is it mainly one person or groups of people?

Can the CA/PA be executed efficiently?  Is it for one site or multiple sites?

  • Is the CA/PA Economical? What budget is available?

Is it a “cheap” fix or a 3 – 6 month project? Or an expensive solution of more than 6 months and will need capital expenditure funding?

  • Is the CA/PA Feasible? The real question is about the timeline.

            Need it fast – within 3 months or

            Have time – don’t need until more than 3 months from now.

And then there is the unspoken 4th question – is the CA/PA “political”?  I experienced first hand what happens to CAPAs that are politically oriented.  Most of them failed their ECs.  Request “Can You Stay a Little While Longer”. The best CAPAs are the ones that map back to the root cause.

Introducing the HPISC CAPA Performance Chain

On the left hand side, you will recognize the 3 traditional tasks to complete.  After the EC is written, trace upwards to ensure that the EC maps back to the CA/PA and that the CA/PA maps back to the root cause; hence, the bottom up arrow.  On the right hand side are performance improvement activities that I use as a Performance Consultant (PC) to bring another dimension to the CAPA investigation, namely, Human Performance Improvement (HPI). 

Before I can write the root cause statement, I examine the “problem” also known as a Performance Discrepancy or an incident and I conduct a Cause Analysis that forces me to take a three tiered approach (the worker, the work tasks, the workplace) for the possible causes and not get bogged down in observable symptoms only.  The Performance Solution is more appropriately matched to the identified gap. In theory, this is what the corrective action(s) is supposed to do as well. During the performance solution planning, determination of success and what forms of evidence will be used happens with key stakeholders.  So that collecting the data happens as planned, not as an after thought, and the effectiveness is evaluated as discussed.    

What can we really control?

In RCA/CAPA meetings, I often hear about what management should do to fix the working conditions or how most of the operator errors are really managements’ fault for not taking the culture factor seriously enough.  While there may be some evidence to back that up, can we really control, reduce or eliminate the human factor?  Perhaps a future blog on understanding human errors will be released.

Management Can:

  • Design work situations that are compatible with human needs, capabilities and limitations
  • Carefully match employees with job requirements
  • Reward positive behaviors
  • Create conditions that optimize performance
  • Create opportunities to learn and grow professionally.

Clues for Failed Effectiveness Checks

One of the first activities to perform for a failed EC is to evaluate the effectiveness check statement.  I have read some pretty bizarre statements that challenge whether the EC was realistic to achieve at all. The conditions under which we expect people to perform must be the same as the conditions we evaluate them during an EC review.  So why would we set ourselves up to fail by writing ECs that don’t match normal workplace routines? What, because it looked good in the investigation report and it got the CAPA approved quicker?

Next, trace back each of the CAPA tasks to identify where to begin the re-investigation.  I also suggest that a different root cause analysis tool be used. And this is exactly what we did while I was coaching a cohort of Deviations Investigators.  Future blogs will discuss RCA tools in more detail. -VB

The Big Why for Deviations

As part of my #intentionsfor2019, I conducted a review of the past 10 years of HPIS Consulting.  Yes, HPISC turned 10 in August of 2018, and I was knee deep in PAI activities.  So there was no time for celebrations or any kind of reflections until January 2019, when I could realistically evaluate HPISC: vision, mission, and the big strategic stuff.  My best reflection exercise had me remembering the moment I created HPIS Consulting in my mind.

Human Performance Improvement (HPI) and Quality Systems

One of the phases for HPI work is a cause analysis for performance discrepancies.  The more I learned how the HPI methodology manages this phase the more I remarked on how similar it is to the Deviation /CAPA Quality System requirements.  And I found the first touch point between the two methodologies.  My formal education background and my current quality systems work finally united.  And HPIS Consulting (HPISC) became an INC.  

In my role of Performance Consultant (PC), I leverage the best techniques and tools from both methodologies.  Not just for deviations but for implementing the corrective actions sometimes known as HPI solutions.  In this new HPISC blog series about deviations, CAPAs, and HPI, I will be sharing more thoughts about HPISC touch points within the Quality Systems. For now, lets get back to Big Why for deviations.

Why are so many deviations still occurring? Have our revisions to SOPs and processes brought us farther from a “State of Control”? I don’t believe that is the intention. As a Performance Consultant, I consider deviations and the ensuing investigations rich learning opportunities to find out what’s really going on with our Quality Systems.

The 4 cross functional quality systems

At the core of the “HPISC Quality Systems Integration Triangle” is the Change Control system.  It is the heartbeat of the Quality Management System providing direction, guidance and establishing the boundaries for our processes.  The Internal Auditing System is the health check similar to our annual physicals; the read outs indicate the health of the systems.  Deviations/CAPAs are analogous to a pulse check where we check in at the current moment and determine whether we are within acceptable ranges or reaching action levels requiring corrections to bring us back into “a state of control”.  And then there is the Training Quality System, which in my opinion is the most cross-functional system of all.  It interfaces with all employees; not just the Quality Management System.  And so, it functions like food nourishing our systems and fueling sustainability for corrections and new programs.

Whether you are following 21CFR211.192 (Production Record Review) or ICHQ7 Section 2 or  820.100 (Corrective and Preventive Action), thou shall investigate any unexplained discrepancy and a written record of the investigation shall be made that includes the conclusion and the follow up. Really good investigations tell the story of what happen and include a solid root cause analysis revealing the true root cause(s) for which the corrective actions map back to nicely.  Thus, making the effectiveness checks credible. In theory, all these components flow together smoothly.  However, with the continual rise of deviations and CAPAs, the application of the Deviation /CAPA Management system is a bit more challenging for all of us.  

Remember the PA in C-A-P-A?

Are we so focused on the corrective part and the looming due dates we’ve committed to, that we are losing sight of the preventive actions? Are we rushing through the process to meet imposed time intervals and due dates that we kind of “cross our fingers and hope” that the corrective actions fix the problem without really tracing the impact of the proposed corrective solutions on the other integrated systems? Allison Rossett, author of First Things Fast: a handbook for performance analysis, explains that performance occurs within organizational systems and the ability to achieve, improve and maintain excellent performance, depends on integrated components of other systems that involve people. 

Are we likewise convincing ourselves that those fixes should also prevent re-occurrence? Well, that is until a repeat deviation occurs and we’re sitting in another root cause analysis meeting searching for the real root cause.  Thomas Gilbert, in his groundbreaking book, Human Competence: engineering worthy performance tells us, that it’s about creating valuable results without using excessive cost.  In other words, “worthy performance” happens when the value of business outcomes exceeds the cost of doing the tasks.  The ROI of a 3-tiered approach to solving the problem the first time, happens when employees achieve their assigned outcomes that produce results greater than the cost of “the fix”. 

Performance occurs within three tiers

So, donning my Performance Consulting “glasses”, I cross back over to the HPI methodology and open up the HPI solutions toolbox.  One of those tools is called a Performance Analysis (PA). This tool points us in the direction of what’s not working for the employee, the job tasks a/or the workplace. The outcome of a performance analysis produces a 3 tiered picture of what’s encouraging or blocking performance for the worker, work tasks, and/or the work environment and what must be done about it at these same three levels.  

Root cause analysis (RCA) helps us understand why the issues are occurring and provides the specific gaps that need fixing.  Hence, if PA recognizes that performance occurs within a system, then performance solutions need to be developed within those same “systems” in order to ensure sustainable performance improvement.  Otherwise, you have a fragment of the solution with high expectations for solving “the problem”.  You might achieve short-term value initially, but suffer a long-term loss when performance does not change or worsens. Confused between PA, Cause Analysis and RCA? Read the blog – analysis du jour.

Thank goodness Training is not the only tool in the HPI toolbox!   With corrective actions /HPI solutions designed with input from the 3 tiered PA approach, the focus shifts away from the need to automatically re-train the individual(s), to implementing a solution targeted for workers, the work processes and the workplace environment that will ultimately allow a successful user adoption for the changes/improvements.   What a richer learning opportunity than just re-reading the SOP! -VB

  • Allison Rossett, First Things Fast: a handbook for Performance Analysis; 2nd edition 
  • Thomas F. Gilbert, Human Competence: Engineering Worthy Performance
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Did we succeed as intended? Was the training effective?

When you think about evaluating training, what comes to mind? It’s usually a “smile sheet”/ feedback survey about the course, the instructor and what you found useful. As a presenter/instructor, I find the results from these surveys very helpful, so thank you for completing them. I can make changes to the course objectives, modify content or tweak activities based on the comments. I can even pay attention to my platform skills where noted. But does this information help us evaluate if the course was successful?

Formative vs. Summative Distinction

Formative assessments provide data about the course design. Think form-ative; form-at of the course. The big question to address is whether the course as designed met the objectives. For example, the type of feedback I receive from surveys gives me comments and suggestions about the course.

Summative assessments are less about the course design and more about the results and impact. Think summative; think summary. It’s more focused on the learner; not the instructional design. But when the performance expectations are not met or the “test” scores are marginal, then the focus shifts back to the course, instructor/trainer and instructional designer with the intent to find out what happened? What went wrong? When root cause analysis fails to find the cause, it’s time to look a little deeper at the objectives.

Objectives drive the design and the assessment

Instructional Design 101 begins with well-developed objective statements for the course, event, or program. These statements aka objectives determine the content and they also drive the assessment. For example, a written test or knowledge check is typically used for classroom sessions that ask questions about the content. In order for learners to be successful, the course must include the content whether delivered in class or as pre-work. But what are the assessments really measuring? How much of the content they remember and maybe how much of the content they can apply when they return to work?

Training effectiveness on the other hand is really an evaluation of whether we achieved the desired outcome. So I ask you, what is the desired outcome for your training: to gain knowledge (new content) or to use the content correctly back in the workplace? The objectives need to reflect the desired outcome in order to determine the effectiveness of training.

What is your desired outcome from training?

Levels of objectives, who knew?

Many training professionals have become familiar with Kirkpatrick’s 4 Levels of Evaluation over the course of their careers, but less are acquainted with Bloom’s Taxonomy of Objectives. Yes, objectives have levels of increasing complexity resulting in higher levels of performance. Revised in 2001, the levels were renamed for better description of what’s required of the learner to be successful in meeting the objective. Take note, remembering and understanding are the lowest levels of cognitive load while applying and analyzing are mid range. Evaluating and creating are at the highest levels.

If your end in mind is knowledge gained ONLY, continue to use the lower level objectives. If however, your desired outcome is to improve performance or apply a compliant workaround in the heat of a GMP moment, your objectives need to shift to a higher level of reasoning in order to be effective with the training design and meet performance expectations. They need to become more performance based. Fortunately, much has been written about writing effective objective statements and resources are available to help today’s trainers.

Accuracy of the assessment tools

The tools associated with the 4 levels of evaluation can be effective when used for the right type of assessment. For example, Level 1 (Reaction) surveys are very helpful for Formative Assessments. Level 2 (Learning) are effective in measuring retention and minimum comprehension and go hand in hand with learning based objectives. But when the desired outcomes are actually performance based, Level 2 knowledge checks need to shift up to become more application oriented such as “what if situations” and scenarios requiring analysis, evaluating, and even problem solving. Or shift altogether to Level 3 (Behavior) and develop a new level of assessments such as demonstrations and samples of finished work products.

Trainers are left out of the loop

But, today’s trainers don’t always have the instructional design skill set developed. They do the best they can with the resources given including reading books and scouring the Internet. For the most part, their training courses are decent and the assessments reflect passing scores. But when it comes to Level 4 (Results) impact questions from leadership, it becomes evident that trainers are left out of the business analysis loop and therefore are missing the performance expectations. This is where the gap exists. Trainers build courses based on knowledge / content instead and develop learning objectives that determine what learners should learn. They create assessments to determine whether attendees have learned the content; but this does not automatically confirm learners can apply the content back on the job in various situations under authentic conditions.

Performance objectives drive a higher level of course design

When you begin with the end in mind namely, the desired performance outcomes, the objective statements truly describe what the learners are expected to accomplish. While the content may be the same or very similar, how we determine whether employees are able to execute post training requires more thought about the accuracy of the assessment. It must be developed from the performance objectives in order for it to be a valid “instrument”. The learner must perform (do something observable) so that it is evident s/he can carry out the task according to the real work place conditions.

To ensure learner success with the assessment, the training activities must also be aligned with the level of the objectives. This requires the design of the training event to shift from passive lecture to active engagement intended to prepare learners to transfer back in their workspace what they experienced in the event.   This includes making mistakes and how to recognize a deviation is occurring. Michael Allen refers to this as “building an authentic performance environment”. Thus, trainers and subject matter experts will need to upgrade their instructional design skills if you really want to succeed with training as intended. Are you willing to step up and do what it takes to ensure training is truly effective? – VB

 

Allen,M. Design Better Design Backward, Training Industry Quarterly, Content Development, Special Issue, 2017, p.17.

I’m in love with my own content!

Many QA /HR Training Managers have the responsibility for providing a train-the-trainer course for their designated trainers.  While some companies send their folks to public workshop offerings, many chose to keep the program in-house.   And then an interesting phenomenon occurs.  The course content grows with an exciting and overwhelming list of learning objectives.

The supervisors of the SMEs struggle with the loss of productivity for the 2 – 3 day duration and quickly develop a “one and done” mindset.   Given the opening to “train” newly identified SMEs as Trainers, the instructional designer gets one opportunity to teach them how to be trainers.  So s/he tends to add “a lot of really cool stuff” to the course in the genuine spirit of sharing, all justifiable in the eyes of the designer.  However, there is no hope in breaking this adversarial cycle if the Training Manager doesn’t know how to cut content.

I used to deliver a two-day (16 hour) workshop for OJT Trainers. I included all my favorite topics.  Yes, the workshop was long.  Yes, I loved teaching these concepts.  I honestly believed that knowing these “extra” learning theory concepts would make my OJT Trainers better trainers.  Yes, I was in love with own my content.  And then one day, that all changed.

 

Do they really need to know Maslow’s Hierarchy of Needs?

During a rapid design session I was leading, I got questioned on the need to know Maslow’s Hierarchy of Needs.  As I began to deliver my auto-explanation, I stopped mid-sentence.  I had an epiphany.  My challenger was right.  Before I continued with my response, I feverishly racked my brain thinking about the training Standard Operating Procedures (SOPs) we revised, the forms we created, and reminded myself of the overall goal of the OJT Program.  I was searching for that one moment during an OJT session when Maslow was really needed.  When would an OJT Qualified Trainer use this information back on the job, if ever I asked myself?

It belongs in the Intermediate Qualified Trainers Workshop, I said out loud.  In that moment, that one question exercise was like a laser beam cutting out all nice-to-know content.  I eventually removed up to 50% of the content from the workshop.

 

Oh, but what content do we keep?

Begin with the overall goal of the training program: a defendable and reproducible methodology for OJT.  The process is captured in the redesigned SOPs and does not need to be repeated in the workshop.  See Have you flipped your OJT TTT Classroom yet?

Seek agreement with key stakeholders on what the OJT QTs are expected to do after the workshop is completed.  If these responsibilities are not strategic or high priority, then the course will not add any business value.  Participation remains simply a means to check the compliance box.  Capture these expectations as performance objectives.

How to align purpose of a course to business goals

Once there is agreement with the stated performance objectives, align the content to match these. Yes, there is still ample room in the course for learning theory, but it is tailored for the need to know only topics.

In essence, the learning objectives become evident.  When challenged to add certain topics, the instructional designer now refers to the performance objectives and ranks the consequences of not including the content in the workshop against the objectives and business goal for the overall program.

 

What is the value of the written assessment?

With the growing demand for training effectiveness, the addition of a written test was supposed to illustrate the commitment for compliance expectations around effectiveness and evaluation.  To meet this client need, I put on my former teacher hat and created a 10 question open book written assessment.  This proved to need additional time to execute and hence, more content was cut to accommodate the classroom duration.

My second epiphany occurred during the same rapid design project, albeit a few weeks later.   What is the purpose of the classroom written assessment when back on the job the OJT QTs are expected to deliver (perform) OJT; not just know it from memory? The true measure of effectiveness for the workshop is whether they can deliver OJT according to the methodology, not whether they retained 100% of the course content!   So I removed the knowledge test and created a qualification activity for the OJT QTs to demonstrate their retained knowledge in a simulated demonstration using their newly redesigned OJT checklist.  Now the OJT QT Workshop is value added and management keeps asking for another round of the workshop to be scheduled.  -VB

Are you ready to update your OJT TTT Course?

 

 

 

I’ve fired my [TTT] Vendor!  

Sustaining Qualified Trainer’s Momentum Post Launch

The Silver Bullet for Performance Problems Doesn’t Exist

Oh but if it did, life for a supervisor would be easier, right? Let’s face it, “people” problems are a big deal for management. Working with humans does present its challenges, such as miscommunications between staff, data entry errors, or rushing verification checks. Sometimes, the task at hand is so repetitive that the result is assumed to be okay and gets “a pass”.  Add constant interruptions to the list and it becomes even harder not to get distracted and lose focus or attention to the detail.

Actual behavior vs. performing as expected

In their book, Performance Consulting: Moving Beyond Training, Dana Gaines Robinson and James C. Robinson describe performance as what the performer should be able to do. A performance problem occurs when the actual behavior does not meet expectation (as in should have been able to do).   Why don’t employees perform as expected? Root cause analysis helps problem solvers and investigators uncover a myriad of possible reasons.   For Life Sciences companies, correcting mistakes and preventing them from occurring again is at the heart of CAPA systems (Corrective Actions Preventive Actions).

A closer look at performance gaps

Dana and James Robinson conducted research regarding performer actions and sorted their results into three categories of obstacles:

  • Conditions of performers
  • Conditions of the immediate managers
  • Conditions of the organization

A checklist for common Performance Causes  – scroll down for the Tool.

But, weren’t they trained and qualified?

Hopefully, employees are trained using an approved OJT (On the Job Training) Methodology in which they are shown how to execute the task and then given opportunities to practice multiple times to become proficient. During these sessions, they are coached by Qualified Trainers and given feedback on what’s right (as expected) and given specific instructions to correct what’s not right with suggestions for tweaking their performance so that their final performance demonstration is on par with their peer group. At the conclusion of the qualification event, employees must accept that they now own their deviations (mistakes) from this point forward. So what gets in the way of performing “as they should” or in compliance speak – according to the procedure?

Is it a lack of knowledge, skill or is it something else?

The Robinson’s explain that performance is more than the training event. It’s combination of the overall learning experience and the workplace environment that yields performance results. Breaking that down into a formula per se, they suggest the following: learning experience x workplace environment = performance results.

The root cause investigation will include a review of training and the qualification event as well as a discussion with the performer.

  • Is it a lack of frequency; not a task often performed?
  • Is it a lack of feedback or delayed feedback in which the deviation occurred without their awareness?
  • Is it task interference?

The work environment includes organizational systems and business unit processes that together enable the performer to produce the outcomes as “expected”.   These workplace factors don’t always work in perfect harmony resulting in obstacles that get in the way of “expected” performance:

  • Lack of authority – unclear roles, confusing responsibilities?
  • Lack of time – schedule conflicts; multi-tasking faux pas?
  • Lack of tools – reduced budgets?
  • Lack of poorly stored equipment/tools – lost time searching?

Isn’t it just human nature?

Once the root cause investigation takes on a human element attention, it’s easy to focus on the performer and stop there.   If it’s the first time for the performer or first instance related to the task, it’s tempting to label the event as an isolated incident. But when it comes back around again, it becomes apparent there was a “failure to conduct an in-depth investigation” to correct and prevent. Not surprisingly, a push back of “Operator Error as Root Cause” has forced organizations to look deeper into the root causes involving Humans.

Who’s human nature?

Recall that one of the categories of the researched obstacles was “conditions of the immediate managers”. This makes managers uncomfortable. With so much on their plates, managing a people performance problem is not what they want to see. A silver bullet like a re-training event is a nice activity that gets a big red check mark on their to-do list. However, Robert Mager and Peter Pipe, in their book, Analyzing Performance Problems, provide insights to managing direct reports that may lead to unintended consequences. A brief list can be found here – scroll to Tool: Performance Causes.  (It’s not always the performer’s fault.)

It takes all three to correct a performance problem

soln-people-performance-problemThe third category of researched obstacles clustered around “conditions of the organization”.  I’ve already discussed task interference above. To suggest that organizations are setting up their employees to fail is pushing it just a bit too far.   So I won’t go there, but it is painful for some leaders to come to terms with the implication. In order to prevent issues from reoccurring, an examination of the incidents and quite possibly a restructuring of systems have to occur, because automatic re-training is not the only solution to a “people performance problem”. –VB

Robinson DG, Robinson JC. Performance Consulting: Moving beyond training. San Francisco: Berrett-Koehler; 1995.

Mager R, Pipe P. Analyzing performance problems. Belmont: Lake Publishing; 1984.

What will it take to gain access to HPI/HPT Projects?

It’s more than a name change.
Adding Performance Consulting to your department name or position title sounds like a good idea at first. You know, help get the word out and ease into Performance Consulting projects, right? Well not exactly. Adding it on is exactly what happens; possible projects get added on to your workload and the “regular” training requests keep coming. It becomes a non-event. Dana Gaines Robinson and James C. Robinson, authors of Performance Consulting, strongly recommend that you create a strategic plan for your transition. And that’s exactly what I did in 1997.

Technical Training is now known as Performance Enhancement Dept.
But not without first discussing my plan with my boss and then pitching it to his staff at his weekly meeting. My plan included the need for the change and a comparison of the traditional training model and the performance model. In this comparison, I listed the percentages of training to consulting ratios and where the shift would occur. Training was never going away, but that we would do less and pick up more performance consulting work instead. I used the now familiar line – training is not always the answer. (Back then it was a very edgy statement.)

And I included in my pitch, the recommended pieces from the Robinsons’ seminal book: mission, vision, guiding principles, services, responsibilities and even who are customers were by percentages. Key to this plan and acceptance, was that we never said no to a training request, but re-framed it into why and how will we measure success. If we couldn’t design a measurement strategy from the beginning, we were obligated to turn the project down. And the General Manager agreed with that guiding principle.

NOW OPEN FOR BUSINESS!
While we waited for feedback and project requests, I invited myself to a quality meeting about a GMP concern from a Line Trainer. When no one volunteered to complete a suggested task, I raised my hand and took the assignment. Cheers, we had our first project and we were now open for business. The task was then assigned to a direct report who thought I was crazy or evil, but I described how this assignment could catapult us into the limelight and showcase exactly the kind of performance work we were capable of doing. Intrigued but still doubtful, he took on the research task and I took on the rest of the project since I had the vision and could connect the dots. We got 3 more requests after we went public with our first project.

One of my best requests that first year was a request for Peer Mentoring. Oh did I want this project. I met with the requester and listened to his case. I researched the topic (remember this was 1997) and got some ideas about a possible solution. When I pressed on about measuring the success, he was vague and said, you know, as part of organizational awareness. I was in love with the topic and what it could mean for the operators and for the new PE department, but I could not find enough support to measure the success nor justify the time and resources to make it happen. We had to scrap the project request. This was the Evaluator Role coming out loud and clear. And this news got around fast. The PE department was not a dumping ground for someone else’s yearly objectives.

Okay, that’s great, but who does GMP Training?
During our success, we still managed the Compliance Training requirements as part of our agreement. Folks got so used to us and how we managed both the compliance side and performance enhancement requests, that we no longer had to explain what PE was and who we were. So upon biennial inspection from FDA, the inspector asked, “Well then, who does GMP Training”? So, I was asked to put Training back into our department name and become known as TPE: Training and Performance Enhancement which felt like we were back to square one. But the requests kept coming and the projects got much better.

My favorite project was the “Checking Policy”. It had everything going for it. Unfortunately for the company, a very expensive error was made by an operator and site leadership wanted him terminated. The GM who was our unofficial sponsor knew there was a better way to manage this and he needed to find the true root cause of the performance discrepancy, so he reached out to me. The rest of the story is long, so I’ll spare you the details, but three additional projects resulted from this request and all three included operators as my SME Team. This was unheard of at the time and really highlighted what an asset they were to the company despite the costly mistake. Turns out it wasn’t his fault, what a surprise!

Alas, the time came for me to leave that company and take on external consulting full time. When given the opportunity to reinvent myself once again years later, I reflected on the times when I was most engaged and excited about going to work. It was those Performance Enhancement projects that gave me such powerful examples of successfully aligning improvement projects with the business needs. But rather than do it again for one single company, I created HPIS Consulting instead so I could share the approach with more than one company.

So as this “Gaining Management Support” series concludes, I summarize all the related blogs with this final question and provide an overview as the answer.

What will it take?
Developing trust with business partners for starters. Ongoing skill development as an Analyst, a Change Manager, an Evaluator and of course, a Performance Solutions Specialist to build credibility. A good transition plan with vision for 1-3 years and tentative plans for year 4 and 5. And the courage to take projects no one else wants if you want to become a Performance Consultant bad enough. We did it and I’ve never been happier! -V

Gaining Management Series includes the following blog posts:

If the only tool in your toolbox is a hammer …
Are you worthy of your line partner’s trust?
Wanted: Seeking a business partner who has performance needs
First, make “friends” with line management

If the only tool in your toolbox is a hammer …

A hammer is the right tool to drive a nail into wood or dry wall, etc. supporting the adage “right tool for the right job”. Until the closet you installed comes off the wall and you realize that perhaps you needed screws instead or an additional widget to support the anticipated load. It isn’t until “in-use” performance feedback is collected that the realization of a different tool and additional support mediums are needed. Providing training (as in formal instruction) as the solution to a performance issue is analogous to using a hammer for every job.

Site leaders want business partners who can help them succeed with organizational goals, yearly objectives and solve those pesky performance issues. The more valuable the “trainer-now-known-as-performance-consultant is in that desire, the more access to strategic initiatives. So, the more you want to be recognized as a business partner to the site leaders, you need to continue to build your “solutions toolbox” that includes more than delivering a training event or LMS completion report.

As we begin to wrap up this series on gaining management support, we’ve been exploring how to forge relationships with line managers and earn their trust by being trustworthy. In the blog (Are you worthy of your line partner’s trust?), I asked if you were also trust worthy as a Performance Consultant (PC).

Do you have the necessary competencies to tackle the additional performance solutions? A logical next step is to review the plethora of literature that has been published on the multiple roles for a Performance Consultant. These include Analyst, Change Manager, Solutions Specialist, and Evaluator. There are more, but let’s start with an overview of these four.

A trainer with strong instructional design skill could argue that s/he has loads of experience with 3 of the 4 roles sans solution specialist. To that end, ADDIE has been the methodology and the foundation for successful training events for years. A sound training design analyzes need first and incorporates change management elements and includes evaluation activities for level 1(reaction) and level 2 (learning) of the Kirkpatrick Evaluation Model. So how hard could it be to master the role of Performance Consultant? Doesn’t every solution have a training component to it anyway?

Maybe and maybe not. As the traditional role of technical trainer evolves into Performance Consultant, the skills needed are evolving as well to keep up with management expectations for alignment with business needs.

The PC wears the hat of Analyst when working the business analysis and performance analysis portion of the HPI methodology honing in with the skill of asking the right questions and being able to analyze all of the contributing factors for performance causes. This is more than a needs analysis for designing a course.

The Solution Specialist role relies heavily upon systems thinking skills and is already way outside the power point training solution. As a problem solver working the probable causes from the Performance Cause Analysis, s/he opens the toolbox and can look past the “training design tray” into other alternative performance solutions. There is much more than a hammer in their toolbox. NOTE:  For more details on those types of solutions, navigate to paragraph “HPI Approach” within the blog link).  Implementation experience grows with each executed solution and a great PC also develops good project management skills.

During implementation, the PC may also have to wear a dual hat of Change Manager.  Process changes, culture change and more require strong facilitation skills and process consultation HPI roles for Perf Consulttechniques to manage the different phases of change depending on the nature of the solution and the size of the change impact.

And the Evaluator role surfaces at or near end of project implementation as the solution launches and goes live. Feedback collection, standards setting and re-assessing the performance gap to determine success or additional gap analysis.

The role of Performance Consultant requires more variety of skills and depth of project experiences. While training solutions are part of the PC toolkit, a training manager’s toolbox typically does not offer other performance solutions. It’s usually a hammer when a swiss army knife is what’s needed.  –VB

References: William J. Rothwell Editor, ASTD Models for Human Performance Improvement: Roles, Competencies, and Outputs. 2nd Ed, 1999.