The Dilution of Compliance


Dilution can be defined as "the process or action of making something less strong or valuable." Over the years I have experienced this effect at work when it comes to compliance systems in support of quality, safety, environmental, and regulatory objectives. The following are steps that many companies follow in hopes to strengthen their compliance but all too often results in the dilution of compliance instead.


Step 1: Company decides to adopt a compliance management system

As always it begins at the beginning with good intentions to adopt a management system to raise the standard for a particular set of obligations. This is often triggered by the occurrence of a significant incident, but not always. It may also be legislated, or strongly encouraged as part of membership in an industry association. An organization may also be proactive and choose to raise their standards on their own. Whatever the motivation might be resources are rallied behind the decision and implementation begins in earnest.


Step 2: System elements are mapped to existing functions and activities

The next step usually involves learning about the chosen system standard followed by a reductive analysis where each part of the system is divided up and mapped to existing functions and activities within the organization. This is a component-first approach as compared with a system-first approach. The goal of the component-first approach is to divide and conquer, utilize existing practices, identify and address procedural gaps, and realize early wins. All of these goals are good in and of themselves. However, together they seldom lead to an operational system as we soon shall see.


Step 3: Company focuses on the elements and loses sight of the system

After the elements have been incorporated into the organizational structure sight of the system is often lost. People go back to their "day jobs" and the prior management processes take on the task of managing the various parts of the compliance system. Reports and scorecards are updated to add such things as element key performance indicators, and objectives. It is here that we can start to see the "dilution of compliance."


The failure in implementation (which is to come) was not performing the "synthesis" step to work on the interactions of the elements to function as a whole. The performance of the compliance system depends on how the parts interact, not on how the parts perform separately. The parts on their own can never fulfill the purpose of the system. This lack of understanding now sets in motion the "dilution process".


Step 4: The system fades away and only the elements remain

The "dilution of compliance" process is now at work. The compliance system as a whole is now lost and perhaps was never really there since it was never implemented.


This can be observed by the lack of accountability for the system expressed in the organizational structure. There is no person who has the scope, authority, or resources to contend with ensuring that the overall system is operational and is performing at the levels needed to improve outcomes. At best silos exist for the elements, at worst, the components are fractionated, and dispersed beyond their ability to produce any real value towards system outcomes.


Step 5: With the system out of sight even the elements start to fade away as people forget why they were even there

The dilution of compliance is now complete. Companies may use internal and external audits to remind people of the elemental requirements. However, ownership for them as with the system itself is slim to none.


It is now time to start over, this time with a better process that avoids compliance dilution.


Here is a video animation that stitches all these steps together:




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