simplifying process development-final-printversion-2 developmentvideo.pdf · simplifying process...
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Encari, As Part Of The PowerSecure Family, Provides The Consulting Services That Generation And Transmission Utilities, Municipalities, And Cooperatives Need In Order To Attain And Maintain Compliance With The NERC CIP Reliability Standards
PowerSecure Provides Energy Technologies And Services To Electric Utilities And Their Large Industrial, Commercial, Institutional And Municipal Customers
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• Senior NERC CIP Compliance Consultant with Encari, after working with a variety of clients on NERC CIP compliance since 2006.
• Qualified Nuclear Operator in the U.S. Navy serving on a fast attack submarine.
• Worked in civilian nuclear power industry in regulatory compliance dealing with both NRC and DOE at several nuclear facilities.
• Director of Strategic Quality and Director of HR Information Systems for an international IT company.
• Managed the technical writing staff in preparing the license application submittal for DOE’s Yucca Mountain Project. NERC CIP activities include initial gap analysis, staff training, critical asset identification, developing policies and procedures to achieve compliance, audit preparation, and audit support.
• Captain, US Navy (retired)
JACK KUTZERSENIOR NERC CIP COMPLIANCE CONSULTANT
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GREATTOBEPRESENTINGTODAY
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Objectives• Nostalgia• ‘Melt the ICE’• Procedures – the ‘Large Mosaic’• Simplifying Process Chart & Procedure Development• Procedure Lore• Before & After• Tools Discussion• 5 Key Success Factors
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WHAT’SITALLABOUT?
Audience• New to Compliance – It all still sounds like ‘alphabet soup’• Doing compliance for 2 years or less – Somewhere in your ‘elephant meal’• Old Hand at Compliance – You remember CIP Version 1, or even 1200
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PROCESSCHART– CIRCA1980
PROCEDURE PROCEDUREI. Procedure – Revision ScopingII. Procedure ScopingIII. Procedure DevelopmentIV. Technical ReviewV. Procedure Comment PeriodVI. Procedure ApprovalVII. Approved Procedure Handling
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MELTTHEICE!
Internal Controls Evaluation (ICE)
• Evaluate registered entity controls for identified risks and associated Reliability Standards and Requirements identified in an IRA
• Entity‐Level Controls: controls which are pervasive across an organization and include culture, values and ethics, governance, transparency and accountability
• Activity‐Level Controls: controls specific to a process or a function; may be manual or automated
• Identify important or key internal controls (such as business processes, practices, policies, and procedures)
• Level of Internal Control Implementation Table – “Documented processes” & “Evidence”
Source: ERO Enterprise Internal Control Evaluation Guide| October 2014
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CURRENTPROCEDURESTATUS?
You Don’t Need Procedures For Everything!
Every Single One Of Your Companies Have Procedures!
Procedures Minimize ‘Random Activity’
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THE‘LARGEMOSAIC’
Relationship Diagram“Big Boxes”
Process Hierarchy
Process ChartsBusiness Logical Software & Tool Independent
R‐01
P‐03‐01 P‐03‐02
P‐03‐04
Process P‐03
b
V‐01‐001
P‐03‐03
Process P‐02
BP‐02‐01
P‐02‐02 P‐02‐03
a
b
a
E‐01 P‐01‐01A
P‐01‐02aa
P‐01‐04
bb
B
Swimlane 1
Swimlane 2
Process P‐01 Swimlane 1
Swimlane 2
Swimlane 1
Organization
E‐01
R‐03
P‐01
P‐02
P‐03
P‐04
P‐05
E‐02
E‐03
R‐02
R‐01A B
B
V‐03‐00 2V‐03‐00 1
P‐05
V‐01‐001
C‐03‐00 2C‐03‐00 1
C‐01‐00 1
Implementing DocumentsHow To Use Software & Tools
a
E‐01 P‐01‐01A
P‐01‐02aa
P‐01‐04
bb
B
Swimlane 1
Swimlane 2
Process P‐01
Checklists Job Aids
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THE‘LARGEMOSAIC’
Relationship Diagram“Big Boxes”
Process Hierarchy
Process ChartsBusiness Logical Software & Tool Independent
R‐01
P‐03‐01 P‐03‐02
P‐03‐04
Process P‐03
b
V‐01‐001
P‐03‐03
Process P‐02
BP‐02‐01
P‐02‐02 P‐02‐03
a
b
a
E‐01 P‐01‐01A
P‐01‐02aa
P‐01‐04
bb
B
Swimlane 1
Swimlane 2
Process P‐01 Swimlane 1
Swimlane 2
Swimlane 1
Organization
E‐01
R‐03
P‐01
P‐02
P‐03
P‐04
P‐05
E‐02
E‐03
R‐02
R‐01A B
B
V‐03‐00 2V‐03‐00 1
P‐05
V‐01‐001
C‐03‐00 2C‐03‐00 1
C‐01‐00 1
Implementing DocumentsHow To Use Software & Tools
a
E‐01 P‐01‐01A
P‐01‐02aa
P‐01‐04
bb
B
Swimlane 1
Swimlane 2
Process P‐01
Checklists Job Aids
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PROCESSCHARTVS.PROCEDURE
What Does a Process Chart Accomplish• Management Review Tool• Easy To Evaluate Flow From Triggers To Results• Easy To ‘See’ Roles Of Stakeholders• Shows Where Control Points Could Be Established• Training Tool To Show Overview Of Procedure• Generally, Insufficient Detail To Perform ProcedureWhat Does a Procedure Accomplish• Provides Implementation Details To Perform Procedure• Establishes Specific Control Points• Specifies Records And Documentation To Demonstrate Procedure Completion• Lesson Learned – Don’t Put Process Charts In Procedures
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STEP1– “BIGBOX”PROCESS
Procedure Procedure Process
Change Control Process
Employee Hiring Process
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STEP2A– IDENTIFYSTAKEHOLDERS <Process Name>
Particip
ant 2
Particip
ant 1
Identify Individuals Or Organizational Units With ‘Roles’ In Procedure• These Become The ‘Swimlanes’
Types Of Roles:• Generic Roles
• Initiator, Employee, Contractor, Supervisor, etc.• Identify With Generic Role Name
• Organizational Units• Information Technology, Operations, Transmission Support, etc.• Identify With Organizational Unit Name
• Specific Individuals• Operations Manager, Plant Manager, Compliance Manager, etc.• Identify With Specific Individual’s Title
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STEP2B– ESTABLISHTHEPROCESSBOUNDARIES
Identify Procedure Triggers• Event Based Triggers – Something Happens – Unplanned Outage, Planned Outage,
Hardware Upgrade, Software Update, Predecessor Procedure Ends, etc.• Time Based Triggers – Daily, Weekly, Monthly, Quarterly, Annual, etc.
Identify Procedure Inputs• Information Necessary To Complete A Process, But Is Not Generated By The Procedure
• Hiring Procedure Requires Company Salary Structure• Inputs Are Not Required For A Process
Identify Procedure Outputs Or Results (Pick Your Terminology)• A Deliverable That Ends The Subject Process Flow• May Be An Internal Or External Deliverable• Typically Indicates Collection Or Storage Of Documentation Or Records
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STEP3 – IDENTIFYFLOWFROMTRIGGERSTORESULTS
Identify Process Activities• Data Transformation ‐ Source Data Manipulated To An Output Or Deliverable• Value Added – Design, Develop, Install, Replace, etc.• Review And Approve – Review Deliverable From A Predecessor Step
Identify ‘Mid‐Procedure Deliverables ’• Lines Between Process Activities Indicate A ‘Mid‐Procedure Deliverable’• Should ‘Name’ Deliverable Lines Crossing Swimlane Boundaries• Obtain Agreement For Both Sides Of The Deliverable Line
Identify Decisions• Branch On ‘Condition’ In Deliverable• Branch Based On ‘Review And Approval’ Activity• Show All Paths (Happy & Unhappy)
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PROCESSCHARTELEMENTS
Process Chart Element Description Typical Symbol1. Triggering Event 2. Input
1. Event that initiates the subject process flow ‐ external stimulus, an output from another process, or a timed‐based event.
2. Information that is necessary to perform or complete activities
1. Output 2. Result
1. A deliverables that ends the subject process flow. 2. Indicates the collection or storage of documentation or
records.
Process Activity Value‐added action or data transformation that is performed by a Stakeholder.
Deliverable Information or document that results from a process activity
Decision Conditional branching step based on the characteristics of a deliverable.
Swimlane (Stakeholder) ‐ An indication of some degree of participation in the process flow.
<Process Name>
Particip
ant 2
Particip
ant 1
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METHODOLOGY
Post Meeting Activities• Produce A ‘Clean’ Process Chart For Stakeholder Review• Depending On Review Comment Scope:
• Produce A Final Version Of The Process Chart, Or• Schedule A ‘Review Meeting’ For The Revised Process Chart
Facilitated Stakeholder Meeting• About 1 Hour Per Procedure• Limit To 3 Procedures Per Day, Or Less• Participants Need To Be Able To Make Decisions And Commitments
Use The ‘Final Process Chart’ To Write The Procedure• Write What the ‘Picture’ Shows• Add Details for Activities
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PROCEDURECONTENT
Title Page• Table Of Contents1. Purpose – What It Does2. Scope – Where It Applies, Or Doesn’t Apply3. [Overview – Summarizes Regulatory Requirement Implementation]4. Roles & Responsibilities – From Process Chart5. Procedure – From Process Chart6. Definitions 7. References – Internal And External To Organization8. Revision History9. Approval
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RULES(“MOREWHATYOU’DCALLGUIDELINES)
Process Chart ‘Rules’• Label Process Chart Elements – Including ‘Deliverable’ Lines Crossing
Boundaries• Process Chart Symbols Should Have 3 To 5 Words – Not Sentences• Process Chart Terminology Should Be ‘Verb‐Noun‐Qualifier’ • Process Chart ‘Flows’ From Left to Right And Top To Bottom• Change Swimlane Order To Get Better ‘Flow Picture’• Eliminate ‘Non‐actions’ – Notify, Email, And Similar (Process Activity Definition)• Process Charts Should Fit On Letter Size Paper• It’s Nice To Have A Large Format Printer• ‘White‐wall’ Rooms Are Nice To Have Available
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Generate – Report – Monthly SalesGenerate – Sales Report – Monthly
Generate – Monthly Report – SalesGenerate – Monthly Sales Report
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RULES(“MOREWHATYOU’DCALLGUIDELINES)
VERB – NOUN – [QUALIFIER]
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RULES(“MOREWHATYOU’DCALLGUIDELINES)
Procedure Development ‘Rules’• Process Charts Are A Key Tool In Procedure Development• DO NOT Put Process Charts In The Procedure – Insufficient Detail Causes Problems• One Action Per Procedure Step
• ‘Review & Approve’ Is OK As ‘One Action’• Procedure Statements Are Directive, And Terse – It’s Not Literature• Procedure Statements Start With Action Verb, With Conditionals At The End• Procedure Statement Identify Role Performing Step• Don’t Forget ‘Unhappy’ Paths• Create A ‘New’ Process Chart From The Procedure – Does It Match The Initial Chart?• MEGA TIP – Read It Aloud
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LEVELOFDETAILINPROCEDURES
Establish An ‘Assumed Level Of Knowledge’• Too Much Detail…• Too Little Detail…• Just Right Detail…
Most Qualified Person Is Not Always The Best Procedure Writer
“The Least Qualified Person That WillUse The Procedure Unsupervised!”
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HAVEYOUHEARDTHIS…
Bad Procedure Programs• We have to do it ‘that way’ ‐We can’t do ‘that’ It’s in (not in) our procedure• You have to ask [insert old dog name here] to find out how to do ‘it’• You haven’t been here long enough to understand how we do ‘it’• We’ve always done it ‘this’ way ‐We’ve never done it ‘that’ way• I do ‘this’ when I get it, and send it to [someone] – I don’t know what they do with it• Why can’t [someone] give me what I need the ‘first time’• Is there something documented where I can find out how to do ‘it’?• How did this procedure get ‘stuff’ for me to do when I never saw it before now?
Procedure Roadblocks• I know how to do my job – why do I have to write it down?• I’m the only one that does this – why do I need a procedure?• Don’t you trust me?• Procedures are too ‘limiting’• What I do won’t work as a procedure ‐ I do different things, depending on the situation• I don’t have time to document what I do – I’m too busy doing it…
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GOODPROCEDURE PROGRAMS
Benefits• Results Are Consistent ‐ Products And Services• Right Information Comes In – Right Information Goes Out (Anti‐GIGO)• Short Learning Curve – New People Become Effective Team Members Faster• Balanced Workloads – Tasks Can Be Completed By Any Team Member• Personnel Gain Experience – Don’t Get Stuck Because Nobody Else Can Do A Task• Controls, Quality, Evidence, & Documentation Is Built In – NOT AN ‘ADD‐ON’!• Life Is Good & Everyone Lives Happily Ever After!Attributes• Key Activities & Regulatory Activities Are Documented With Procedures• Clear Procedure Hierarchy In Place• Changes And Updates To Procedures Are ‘Easy’• Team Talks About Activities By Referencing Procedures• ‘Event Analysis’ Includes Procedure Questions
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PROCESSCHARTINGTOOLS
Stand Alone Process Charting Tool• Specific Process Charting Functionality – Makes Charts ‘Pretty’• A Reasonably Cost Effective Solution• Can Have Expandable Capabilities
IT Enterprise Architecture Tool• Typically Has A Process Charting Module Available• Generally Not A Good Process Charting Solution – Correct, But Not ‘Pretty’• May Be A Wide Price Variation• May Have ‘Access’ Issues Internally
Microsoft Visio• Most Companies Have It Available• Basic Functionality – Good Starting Point• Limited Expansion Of Capabilities• WARNING – Installing Visio Does NOT Make You A Process Charting Expert!
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PROCEDURETOOLS
MS Word• Readily available in most companies• Issues when developing ‘complex documents’
Adobe InDesign• Handles ‘complex documents’• Likely requires additional cost and approvals
Lotus Word Pro• If you have it, then use it
Bottom line ‐ generally ‐ use what your company has in house.
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EATTHEELEPHANT
Next Steps• Take Action!• Create A “Procedure Procedure”• Evaluate What You Have ‐ Critically• Pick A Priority
• Improve Existing ‘Stuff’• Fill In Gaps
Smaller Bites Are Easier To Digest• Don’t Try To Write A ‘Gigantuous’ Procedure• Break It Into Smaller ‘Complete Procedures’• If The Process Chart Is Readable On Letter Size Paper, The Procedure Is About The
Right Size• When You Have Some ‘Procedure Maturity’ You Can Combine The Smaller Bites
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5KEYSUCCESSFACTORS
Celebrate Victories
Get Professional Help
Limit Initial Scope To Most Painful Issue
Involve Stakeholders
Senior Manager Sponsorship
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QUESTIONSANDANSWERS
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469‐955‐5763
Jack Kutzer – Senior NERC CIP Consultant, Encari
205‐960‐8832
Wes Stewart – Vice President, Encari