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More than 75% of companies never measure the effectiveness of their risk & compliance programs. As a result they don't now if their efforts are helping or hurting the achievement of mission objectives or the protection of value and reputation. We created the Proactive Certainty Scorecard™ (Version 3) to help organizations quickly assess how well their risk & compliance programs are doing. This evaluation can be completed in 20 minutes and will provide you with valuable insights on how you can: better meet your all obligations, reduce risk, and build greater stakeholder trust. After you complete this scorecard we will schedule a free orientation session with one of our risk & compliance experts to help you quickly identify areas of improvement. You don't need to be part of the 75% that are uncertain. Join the 25% that are by completing the Proactive Certainty Scorecard™ today. The Proactive Certainty Scorecard™ is applicable to all risk & compliance domains including: Quality, Occupational Health and Safety, Environmental, Security, Process & Pipeline Safety, Regulatory, Data Privacy, Ethics and Legal, Financial, Corporate Risk, Supply Chain Risk, and overall Risk and Compliance.

The documented organization is at best a rough facsimile for the actual organization. There is always a gap between what is expressed in job descriptions, policies, and procedures; and the actual organization performing the work. A significant cause for this gap can be attributed to the level of accountability and autonomy given to workers to achieve their objectives. In fact, these are required to enable proactive behaviours that anticipate, plan, and advance objectives and goals. Creating the balance between adherence to standard practices and having adequate room to be proactive is precisely the balance between management systems and programs. Systems achieve consistency by adhering to procedures, resisting change and reacting to variation. While programs anticipate conditions, introduce change, and advance outcomes. Effective compliance (ex. quality, safety, environmental, and regulatory) requires that existing conditions are maintained, and that progress is made towards compliance goals (ex. zero defects, zero fatalities, zero emissions, zero violations). This requires that companies implement appropriate programs to advance these goals along with their management systems to keep the ground they already have.

There might be some who read my posts who are also Doctor Who fans and get the reference to bow ties being cool. However, even if you don't watch Doctor Who, you can still appreciate the benefits from using a bow-tie analysis to help improve the certainty of achieving your goals. Risk management has changed over the years and in many ways has now become an optimization process to increase the certainty of achieving outcomes. And nothing demonstrates this more than using a bow-tie analysis.The first thing that people notice when using a bow-tie analysis is that it looks like an actual bow tie particularly in its simpler form: This provides a great visual when considering how to address risks. However, what makes it so powerful is that it incorporates causal and consequence trees along with control analysis all in one tool. To illustrate how the bow-tie analysis can be used let's consider risks associated with achieving a relatively simple objective of getting to work. We can simplify this even further by only considering a risk scenario that involves getting from the parking lot to the office building. The path has a significant hole in the pavement that developed over the winter and is now a meter wide wide and several meters deep. This hole is referred to as a hazard which threatens the ability to achieve the objective of getting to work. However, it should be noted that not all holes represent threats only the ones that are in the way between us and our objective. As in the words of, Dr. David Hillson (The Risk Doctor), that's how you know which risks really matter. The goal of a bow-tie analysis is to optimize controls addressing both prevention and recovery to reduce the treated risk to below a given risk tolerance. For each cause an evaluation is made of the prevention controls effects on the likelihood of the risk event occurring, which in our example is falling in the hole. In a similar fashion, an evaluation is made of the effects of the recovery controls to reduce the impact of not achieving the objective. The following list contains brief definitions for key elements of our bow-tie example : Objective : This is what is being aimed or sought after (i.e. getting to work) Causes : these are conditions that may result in falling in the hole. In our example, three causes have been identified: walking down the path, running down the path, and walking while being distracted. Each one will have their own likelihood of falling in the hole. Consequences : these are the results of falling in the hole which affect whether or not we get to work. They are uncertain as they depend on the whether or not a person falls in the hole. Three consequences have been identified: cuts and bruises, broken bones, and fatalities. Prevention : these are controls to prevent falling in the hole. Each one has their own level of effectiveness Recovery : these are controls that mitigate the effects of falling in the hole should they happen. Each one has their own level of effectiveness. After optimizing the prevention and recovery controls to reduce residual risk below the risk tolerance, a risk plan can be developed by creating risk statements for the cross product of causes and consequences. Here I am using the risk meta-language proposed by Dr. Hillson and others: A bow-tie analysis is effective not only with qualitative considerations but can be (an often is) extended to include quantitative measures on both causal and prevention logic trees. In addition, by considering both prevention and recovery efficacy in isolation and in relationship with other controls, a preliminary assessment (LOPA) of the layers of defense can be obtained to gauge overall coverage. A bow-tie analysis can also be applied to opportunities where instead of prevention and recovery the focus is on enabling opportunity events and exploiting them should they materialize. By considering both threats and opportunities a holistic approach to addressing uncertainty in the achievement of objectives is possible. Download our free PowerPoint Bow-Tie / ISO 31000 Template here

An Operational Compliance Program is the means used to steer organizations towards meeting all their obligations and keeping all their promises associated with safety, security, sustainability, quality, and other stakeholder outcomes. Operational Compliance Programs are the vehicles to deliver compliance value – better compliance outcomes and increased stakeholder trust in presence of uncertainty. To ensure their effectiveness, Operational Compliance Programs must actively engage in three critical on-going activities: enhancing capabilities, introducing change, and regulating systems. By prioritizing these imperatives, organizations can provide greater assurance that they are able to stay between the lines and ahead of risk today, tomorrow, and everyday into the future. 1. Enhancing Capabilities: Driving Progress Towards Compliance Outcomes The first key imperative for operational compliance programs is to continuously enhance organizational capabilities (people, process, and technology) to meet all their obligations and effectively contend with risk. This involves developing and nurturing a knowledgeable and skilled workforce, equipped to tackle the challenges posed by evolving regulations, industry standards, and promised organizational performance and outcomes. By providing comprehensive training and educational resources, compliance programs empower management and staff to make informed decisions and take appropriate actions within the boundaries of organizational values. Moreover, enhancing capabilities requires establishing robust communication channels and fostering a collaborative environment. This enables the compliance team to proactively engage with other departments, identify potential compliance risks, and devise effective strategies to mitigate them. By strengthening cross-functional collaboration, compliance programs can align business objectives with compliance outcomes, fostering a culture where compliance is not seen as a hindrance but as an enabler of success. Here is a list of essential operational compliance program functions where capabilities need to be continuously enhanced: Managed Obligations Managed Promises Managed Assurance Managed Culture Managed Accountability and Responsibility Managed Organizational Alignment Managed Operations Managed Risk Managed Capabilities Managed Data & Monitoring Managed Improvements Managed Technology 2. Introducing Change: Staying Ahead of Risks The second imperative for operational compliance programs is to embrace change and remain ahead of emerging risks. Regulatory landscapes are constantly evolving, necessitating agility and adaptability from compliance professionals. It is crucial for compliance programs to proactively monitor regulatory developments and assess their impact on the organization's operations. By adopting a forward-thinking approach, operational compliance programs can identify potential gaps in their existing policies and procedures, and implement necessary changes to ensure ongoing compliance. Regular risk assessments and audits become invaluable tools in detecting vulnerabilities and implementing effective controls. Embracing change allows compliance programs to anticipate potential disruptions, minimize compliance breaches, and maintain a competitive edge in an ever-changing business environment. 3. Regulating Systems: Achieving Performance Targets The third imperative for operational compliance programs is to regulate compliance systems and processes to achieve risk and compliance performance targets. This involves implementing robust monitoring mechanisms and utilizing technology to enhance compliance oversight. By leveraging data analytics and automation tools, compliance programs can efficiently monitor compliance-related activities, identify patterns, and detect any anomalies that require immediate attention. Furthermore, compliance programs must establish clear performance targets and key performance indicators (KPIs) to gauge the effectiveness of their initiatives. Regular assessments and reporting enable organizations to measure progress, identify areas for improvement, and make data-driven decisions to optimize compliance efforts. Summary: Operational Compliance Programs steer organizations towards compliance outcomes as well as the vehicles to deliver value – better compliance outcomes and greater stakeholder trust in an ever-evolving business landscape. By prioritizing three imperatives — enhancing capabilities, introducing change, and regulating systems — operational compliance programs can establish a robust framework that ensures sustainable compliance outcomes in the presence of uncertainty. If you are interested in establishing an Operational Compliance program for your safety, security, sustainability, quality, ethical or regulatory compliance consider becoming a member of the – The Proactive Certainty Program™ ,

When we think about compliance we should also think about the goals we want to achieve. An important distinction we can make is between " terminal " and " instrumental " goals. Terminal goals are the highest level objective that we want to reach. They define the "ends" of our compliance programs, for example: zero defects, zero fatalities, zero violations, zero releases, zero fines, and others. Instrumental goals are intermediate outcomes or results that are critical or that must occur in order to achieve the higher-level outcome. These are often used to define measures of effectiveness (MoE) for compliance programs as they provide clear indication of progress towards terminal goals. What goals have you set for your compliance programs?

When companies decide to improve their compliance they soon realize that their good intentions are often thwarted by their own organizational culture. This may take on various forms but in the end the root cause is always the same – excessive reactivity. A predominately reactive culture is one that has been reinforced by years of following an audit/fix cycle where companies wait for something bad to happen, gaps to be found, or incidents to occur before any meaningful improvement is made to their compliance. These organizations may even take on the mantra of continuous improvement in hopes of breaking free from this trap and finally get on top of all their obligations. However, just like financial debt, the higher the principal and the greater the interest rate the worse things get and the faster things get worse. No matter how many payments are made by closing gaps this strategy is far too slow and too late to keep up with the speed of risk both for financial as well as compliance debt. To escape this trap organizations need to address the root cause and change their behaviour from being predominately reactive to one that is proactive. A culture that is proactive anticipates, plans, and strives to make an impact which for compliance is the reduction of risk. For compliance to be effective it must at its core be driven by risk-based principles reinforced by proactive behaviours. This is the only way for companies to achieve greater resiliency, reduce the risks that really matter and meet all their stakeholder obligations. Effective Compliance A video recording of a webinar is available on our website dives deeper into how the compliance landscape has changed and 10 principles you can use in your organization to escape the reactive compliance trap and finally get on top of all your obligations. More articles on the topic of effective compliance can be found here .

Many of you will know how important it is to keep your promises. It's a measure of the worth of a person and of an organization.   Striving to keep your promises improves both personal and corporate integrity without which organizations cannot behave ethically. That is why building a promise culture is at the heart of effective compliance programs. This involves building habits that reinforce the act of promise keeping. A habit worth considering is to evaluate promises before they are made. The following questions will help assess a promise and improve the probability of keeping it: Is the obligation and commitment clear? Do you have a plan on how we will keep this promise? Do you understand the risks; what threats and opportunities will you encounter in keeping this promise? Do you have everything you need to keep this promise? Do you know when this promise has been met; how will you measure progress or status? How will you hold yourself accountable? Building these questions into your compliance program will improve organizational integrity and reinforce a culture of promise keeping. However, you don't need to wait for that to happen. Compliance leadership can begin with you. Establishing this habit can start today by incorporating these questions as part of the way you contend with personal obligations. Who knows what might happen when others follow your example. Wouldn't that be something.

In a recent article I introduced Promise Theory and its application with respect to compliance. At a high level, Promise Theory puts forward the idea that obligations are an imposition with a cost or penalty for non-compliance. For every obligation there must be a corresponding promise to satisfy it. A promise is more than a desire, it is a publicly declared intention. Saying this in terms of compliance, promises are requirements imposed on an organization which are met by corresponding commitments called promises. Promises are the specifications for how compliance will be delivered supported by management and technical systems and of course people and culture. In this article we explore the concept of promises as business assets similar to equipment, buildings, or even intellectual property. Organizations use assets to generate value for stakeholders by the creation of products and services. In a similar way, organizations make and keep promises to generate stakeholder value through the creation of compliance. Can viewing promises as assets help organizations create better outcomes from their compliance efforts? Let's find out. Asset/Promise Valuation The value of an organization can be determined by taking inventory of its assets and subtracting its total liabilities. This is a good indicator of a company’s net worth. In the same way, a compliance valuation can be conducted by taking an inventory of all the promises an organization has made and subtracting its total obligation debt (i.e. liabilities). This is a measure of a company’s compliance strength or in other words its ability to meet all of its obligations. Servicing obligation debt is important but just like business assets we need a return on that investment that exceeds just paying off the liability. Asset/Promise Lifecycle Promises also follow a life-cycle similar to assets simplified here as four-stages: Creation - promises are specified, designed, implemented, and made operational Utilization - promises are kept while the obligation persists Maintenance - preventive, proactive, routine, and emergency work is performed to sustain promises (ex. maintain control effectiveness). Re-commitment / Retirement - new commitments are made to meet changed obligations or promise is no longer needed. Over time assets and promises tend to grow in complexity and cost. Life-cycle Management is an important capability to ensure that underlying systems and controls perform as required to meet stakeholder obligations and create desired value. Lean and risk management practices are helpful to reduce waste and improve efficiencies not only for assets but also for systems that implement promises. Asset/Promise Principles We can adapt principles of asset management and apply them to the management of promises: Promises exist to deliver value for stakeholders. People keep promises - so an effective promise management system will rely on people’s knowledge of obligations, compliance expertise, motivation and teamwork. Promises must be managed for the life of the obligation. Promise keeping should be risk and evidence-based. Compliance should be delivered in terms of clearly defined measures of effectiveness, performance, and conformance. Promise Management is on-going and requires continuous improvement. Promise Management is multidisciplinary and cross functional. Promise Management requires significant stakeholder involvement. Asset Valuation for Promises When promises are viewed as assets different questions become available that may uncover areas of improvement that might otherwise been overlooked: Do you know the size and nature of your obligation debt - liabilities? Do you have a complete list of all your commitments associated with both mandatory and voluntary obligations - have you assessed your assets? Are your investments in programs, systems and controls generating sufficient compliance value for your organization - are your assets producing a return? Do you know what your overall compliance risk is - are your assets more than your liabilities? If you are unsure of your answers to these questions the following steps can be followed to conduct an asset valuation for compliance of your organization: Take an inventory of all active promises (compliance commitments) including supporting policies, programs, systems, and controls. Take an inventory of all compliance debt (compliance obligations) Calculate obligation exposure by matching your promises with your obligations (do promises cover all obligations?) Calculate compliance strength by evaluating the effectiveness of policies, programs and systems to meet promise objectives. This will include operational risk. Gather and analyze the voice of the stakeholder to validate value creation. Considering promises as assets may be useful in helping organizations visualize compliance as a necessary good (just like assets) rather than a necessary evil. This will bring with it all the best practices and corresponding benefits of asset management to the domain of compliance.

Proactivity is a powerful tool that can help you achieve your desired outcomes. Proactivity is more than a mindset or an attitude. It's also a process that can be applied to any set of actions through anticipating, planning, and striving to have an impact [1]. In this article, we consider what motivates proactive behaviour and how proactivity can be applied to goals including those to meet all your obligations. Proactive Motivations There are four key factors that encourage proactivity when applied to meeting goals: the obligation, ambiguity, accountability, and autonomy [1], [2]. Obligation refers to the goals associated with an outcome that you want to advance. It is the desired result that you are working towards. Considering goals as obligations creates an impetus for proactive behaviour. Obligations can be short-term or long-term, and they can be personal or corporate. Examples of obligations include losing weight, delivering a project, or making progress towards net zero emissions. Risk refers to the uncertainty (ambiguity) with respect to reaching the goal. It is the possibility that you may not meet your obligation. Uncertainty provides a motivation to be proactive - to improve the probability of success. Risks are the effects of uncertainty on our objectives which can be controllable or uncontrollable. Examples of risks include decreased health, unrealized project benefits, or negative impacts on the environment. Incentive refers to the accountability for the results. It is another motivation that drives you to achieve your obligation. Incentives can be intrinsic or extrinsic, and they can be positive or negative. Examples of incentives include realized benefits, financial rewards, or social recognition (i.e. reputation). Promise refers to the autonomy and agency to develop and work the plan. It is the commitment that you make to yourself to achieve your obligation. Making and keeping promises provide moral motivation to satisfy the obligation. Promises can be personal or corporate, and they can be explicit or implicit. However, to be effective they need to be declared and documented. Examples of promises include meeting deadlines, targets, or following rules. Proactive Goal Setting These factors can be applied to the process of goal setting to maximize proactivity in the following way: Identify Obligations: start by setting clear and realistic goals that are aligned with your values, priorities, and commitments. Identify what you want to achieve and why it matters to you. This will help you stay focused and motivated. Evaluate Risk : these are potential obstacles and challenges that may prevent you from achieving your goals. Assess the likelihood and impact of each risk and develop contingency plans to mitigate them. This will help you stay prepared and resilient. Establish Incentives : create a system of rewards and consequences that will hold you accountable for your results. Celebrate your successes and learn from your failures. This will help you stay motivated and committed. Make and Keep Promises : develop a plan of action that is tailored to your needs and preferences. Break down your goals into smaller, manageable tasks and set deadlines for each one. This will help you stay organized and on track. Conclusion Being proactive is a strong tool that goes beyond just a mindset, evolving into a dynamic process applicable to various actions through anticipation, planning, and active impact. We explored four key motivators for proactive behaviour: obligation, risk, incentive, and promise. Obligations drive proactive behavior by linking goals to desired outcomes, whether short-term or long-term, personal or corporate. Risks, as uncertainties related to goal attainment, push for proactivity to increase the probability of success. Incentives, whether intrinsic or extrinsic, positive or negative, help make individuals accountable for results. Promises, involving autonomy and agency, provide moral motivation for meeting obligations. Combining these motivations, a proactive goal-setting process involves identifying obligations, evaluating risks, establishing incentives, and making and keeping promises. This approach ensures clarity, resilience, accountability, and structure, fostering proactive behaviours toward achieving meaningful outcomes. [1] "The dynamics of proactivity at work", Adam M. Grant, Susan J. Ashford, 2008 [2] "Promise Theory", Mark Burgess

Process and pipeline safety programs that manage change will include steps where engineering is required. To various degrees, these activities will include: engineering design, oversight, and technical support. Engineering, like any other function, can be susceptible to producing non-value added work that contribute to waste in engineering projects including design changes during management of change (MOC) processes. The book published by the Joint MIT-PMI-INCOSE Community of Practice on Lean in Program Management entitled, " The Guide to Lean Enablers for Managing Engineering Programs" calls out seven (7) sources of waste found in engineering processes: Each of these can be present during an MOC and can add up to a sizeable amount across hundreds of design changes. Reducing or eliminating these sources of waste will create more time for engineers to work on the changes that are most critical to achieving program outcomes. Plan -Do-Check-Act Questions: Which of these sources of waste is present in your engineering program? What impact would reducing or eliminating them have in achieving your engineering outcomes? Which source of waste can you start eliminating today and what step can you take towards achieving that goal?

Collecting evidence is an important aspect in providing assurance of compliance. This evidence often comes in the form of data and plenty of it. Companies measure, gather and store data of all kinds and in increasing amounts. In fact, as companies continue their digital transformation, the amount of data is expected to balloon creating even more opportunities for data mining. All this data will be analyzed and patterns will be discovered. This will help in updating our system models and processes to make them more efficient. Recent advancements in machine learning will take this to even higher levels and discover patterns that we currently cannot see, and this is good. However, even with these advancements, what this data will never be able to tell us is how things "ought" to be. There is an ethical chasm between the world of facts and the world of values (or ideas). This chasm divides the world of what "is" from the world of what "ought to be" and is known as the "Is-Ought Problem" or more commonly "Hume's Guillotine" named after the Scottish philosopher David Hume. Why is this important to compliance? There is always a tension between the world of ideas and the objective reality we observe. We are always making judgements as we update our understanding of how the world works. The question is, "which direction do these updates occur?" In a fashion, we construct a "model" for how we understand the world and then validate that model using our observations. This is the concept introduced by Immanuel Kant's (German philosopher) contribution to Hume's analysis called, "synthetic–a posteriori". In other words, we can deduce cause-and-effect relationships from the real world and use them to update our construction of how the world works that are based on statements of ideas. However, observations are not used to derive the ideas in a logical sense, they only describe them. And this is where the rub is. In the world of facts, we have statements like: Dogs bark. Apples taste good. These are things we can only know by observation. These do not directly add knowledge to our ideas of how the world works. They are facts that are true because we observed them. In the world of ideas, we have other statements like: All triangles have three sides. All bachelors are unmarried males. These are things we know by definition without observation. These are called tautological statements and are true because of reason not based on empirical facts. However, when we consider things like mathematics we have both. There are things we consider universally true like, 7 + 5 = 12, without observation based totally on our ideas of mathematics. However, at the same time we don't know for sure that it is true until we actually count and discover that it is true in reality. This is the foundation for scientific inquiry which as we know is always preceded by a hypothesis – an idea looking for a descriptive account. [ As an aside, this is how we think about management systems and validating outcomes. Management systems are based on models for how things get done. These are designed based on ideas, concepts, and categorizations of things in the real world that we are concerned about. How true a model is depends on several factors that include: resolution, fidelity, and effectiveness. This is why we need to apply the scientific method to update our models so that they become "truer" in the sense that they are more universally true. Validating outcomes is the act of proving our hypotheses. As an example, we can posit a hypothesis that increasing people's awareness of hazards reduces safety incidents. According to our models this is true and have evidence that has been true in the past under certain conditions for specific companies. However, what we don't know for certain is that this is true for all cases under all conditions. Verification on the other hand is the act of confirming that we followed the correct process for our experiment (so to speak). Many companies only spend time verifying procedures when they also need to prove (perhaps, continually) their hypotheses and update their models accordingly. ] Here's the point, the models we use to better understand the world are based on value judgments. Humans have the capacity or as Kant calls them, ontological categories, to understand our observations of the world. Now back to Hume, you cannot deduce these categories based on the world of facts; you cannot create an "ought" out of an "is". This may seem surprising particularly to those that believe that you can look at nature and derive moral imperatives. This thinking suffers from the "Naturalistic Fallacy" which argues that just because something is found in nature doesn't mean that it is good. No matter how much data analysis we do, we can never discover from data how things ought to be. In the words of Gandalf, from the Lord of the Rings, when it comes to crossing the ethical chasm between what is and what ought to be, "You shall not pass!" This is exactly why compliance needs to be careful. You can use data to verify that actions were taken to support moral values. However, you cannot do the opposite, and use data to determine what these moral values should be. Bridging the gap - some have tried John Searle (an American philosopher) argues that one way to cross the ethical gap is through promises. The act of promising by definition places the promiser under obligation. By speaking forth the words, "I promise to pay Mary 5 dollars" one creates an ought (moral action) from an "is". The most predominate argument given on how to cross the gap is to appeal to a goal or purpose (telos). The argument follows that If you have a goal A, then you should do B, which has been observed to lead to A. The should is created from the goal which is an "is". One problem. You first need to come up with the goal which requires an "ought." Also, if you have not yet observed a path that leads to your goal you never know what you "could" let alone "should" do. Neither of these approaches seem to be sufficient to cross the is-ought chasm as they both require ethical decisions either to make a promise or to set a goal. Take caution with how you use your data Big data, machine learning, and artificial intelligence will no doubt be applied in earnest to discover patterns and ways to improve, exploit, or even just understand what we observe. However, we need to take caution in using these insights to create normative statements on how things ought or should be. The latter belongs to the realm of values which is entirely reserved to humans not machines. Data can help us to achieve our goals but cannot tell us what these goals ought to be. That is why it is so important that the first step to improve compliance begin with taking ownership of obligations. This step involves deciding what your goals ought to be and from there everything else follows.

Are your risk and compliance controls capable to keep you between lines? The purpose of risk and compliance is to keep companies operating between the lines so that they do not fall in a ditch on their way to mission success. To ensure that this does not happen risk and management controls are put in place to act as guardrails (protect against loss) as well as to drive processes and practices towards targeted outcomes in response to stakeholder obligations. Stakeholders include: customers, suppliers, shareholders, employees, government, and the public at large. Requirements (mandatory) and commitments (voluntary) are derived from obligations contained within internal policies, guidelines and code of conduct; regulations and standards; contracts, and product and service specifications. Obligations include: conformance, performance, achievement, and outcome based specifications. Traditional approaches (1950-1970s) to organizational design are based on the notion of (1) "Organizations as Systems" comprised of: general systems theory and contingency theory, and (2) "Hard Systems Thinking" comprised of operations research, systems analysis, systems engineering and cybernetics. In the field of cybernetics (the science of communications and automatic control systems in both machines and living things) there are two models of the organization: management cybernetics and organizational cybernetics . Management Cybernetics : treats organizations like machines and organisms congruent with the philosophy of hard systems thinking. Organizational Cybernetics is concerned with management and organizations that break from the mechanistic and organistic thinking, and is able to make full use of the concept of variety (Stafford Beer). The concept of controls comes from these theories of systems. The most common form of a control process is the feedback control loop used to apply corrective actions in response to system output deviations from target values. The control loop serves to keep the system between acceptable operating limits (ex. constraints, performance levels, etc). We can use organizational cybernetics, specifically the Law of Requisite variety developed by Ross Ashby, to help understand what is required for a control loop to be effective. When the variety or complexity of the environment exceeds the capacity of a system the environment will dominate The larger the variety of actions available to a control system, the larger the variety it is able to compensate The capacity of the control system cannot exceed the capacity as a channel of communication The response time of the control system must meet or exceed the speed of change These principles provide important insights to improving the effectiveness of feedback control loops specified by many standards and regulatory bodies and used in the majority of management systems. There is one significant weakness of the feedback control loop which is that it requires outputs to be measured first. When it comes to risk and compliance objectives measuring outputs using a feedback-management-control is often too slow and too late specifically with respect to safety. In this case it is better to eliminate the possibility of deviation before it happens. This requires the use of feed-forward cybernetic control which will be the topic of a future article.