Although Mark Zuckerberg is testifying to Congress this week, the real message should be heard by manufacturers. No matter how well your company is humming along, making record profits, real danger may lurk beneath the surface. For manufacturers, the true lesson from Facebook/Cambridge Analytica debacle is that you cannot simply assume that all is well when profits are up. Hard times and soft product sales often bring sober assessment to uncover and address operational issues. But the time to critically asses your SOPs and practices is when things appear to be going well. Once any significant product problems inevitably arise, it’s too late. Even the most aggressive post-accident investigation and remedial action—or remorseful, take-responsibility statement by the company president—is no longer enough. Any prior failure to adequately discover and address the underlying causes of the problem will likely be viewed by investigators or the public (or, alas, future jurors) as callous and willful blindness meant to sacrifice safety for profit. In addition, the follow-up Congressional scrutiny may lead to a slew of hasty, stringent regulations meant to address the perceived corporate bad actions.
Even the most aggressive post-accident investigation and remedial action—or remorseful, take-responsibility statement by the company president—is no longer enough.
The answer: make regular, systemic risk assessments part of your company’s standard operating procedure. Thorough risk assessments can help your teams identify and evaluate critical areas to address, including regulatory compliance, industry standards, product packaging/labeling/warnings, quality control systems, product recall preparedness, and customer service practices. Proper systemic assessment of these diverse company functions and departments requires participation of diverse areas of your manufacturing team. For example, as part of your product recall preparedness assessment, ask your customer service department whether someone is keeping track of and adequately documenting customer complaints, press reports, and agency actions to identify potential problems from either your own or your competitors’ comparable products? More importantly, the management group overseeing the assessment, with help from legal counsel, must hear the input from the constituent departments and team members. Using this information and assessment exercise to identify and correct deficiencies in your SOPs will keep your company better prepared to discover and fix developing problems before disaster strikes—and hearings are called.
