Friday, June 24, 2005

Compliance: 'Getting it'

Letter to the Editor from the Los Alamos "Monitor", posted by request.

Compliance: 'Getting it'


Dear Editor,

Who must take responsibility for the stresses at the lab resulting from the Wen Ho Lee incidents, misplaced disk drive investigation, procurement fraud scandal, lost CREM investigation, workplace accidents, etc.?

We make daily decisions based on personal risk analysis. How fast do I drive? How do I word a critical comment? Should I take the time to get a ladder? That analysis changes when the consequence increases, like with our children's safety, or the survival of the lab.

Some of us at LANL may not have noticed the dramatic increase in the ante for risky behavior in the work place. This awareness is the "it" that we are supposed to "get." I will admit to being disgruntled when, in the early 1990s, Tiger Teams from DOE Secretary Adm. Watkins shut down a large facility during an important experimental campaign.

The crane used in that facility had operated under previous standards for 40 years without a serious accident. However, the consequence of a life-threatening accident became too high to accept.

[...]

Full Story

Comments:
Before everyone jumps on this, I want to come on and agree with what Gary has written here. As is obvious by the national attention and continued coverage lavished on LANL every time a real or suspected incident (safety, security, fraud, etc) occurs here, we operate under a level of scrutiny that demands significant attention to safety and security. The ‘ante’ has been raised for risky and careless behavior here.

Of course this is unfair, but that is irrelevant. Much is made on this blog of how other DOE Labs (Sandia, LLNL, Y-12) have worse safety and security records than we do, but don’t receive the abuse that we do from Congress and the media. This largely appears to be true, but just because this is unfair doesn’t mean that it can’t hurt us. Until the time that POGO, LASG, and anti-LANL elements in Congress and the media come over to our side (i.e.: never), we will be held up to a higher and more exacting standard than other labs, and we will stand to lose much more when we screw up. That’s the environment in which we operate, and it’s not about to change. Regardless of what’s fair, this new environment – with its new compliance demands and its new implications for the future of the laboratory – is the ‘it’ that we have been supposed to have been getting. We need to recognize that arrogance and risky behavior (the “I’m an expert” syndrome) can have dangerous implications for the continued mission and existence of the lab.

This isn’t to say that everything that has been done in the name of compliance has been good and right. Nanos may have been the right person to ‘call the problem’, but he wasn’t the right person to implement a solution. His emphasis (perceived or real) on punishing staff has led to an environment where personal security and covering one’s backside have taken precedence over protecting and preserving the Lab. I heard the other day that Kuckuck was startled to see the level of fear among those involved in the recent DX mishap. Whatever Nanos’ intentions were, the creation of this sort of environment was wrong, and needs to be repaired as soon as possible. Hopefully Kuckuck will be able to make UC aware of the damage done here, and allow us to get back to dealing with “getting” compliance. Whatever our problems may be, fixing this issue needs to be at the top of UC’s list.

In spite of UC’s problems, Nanos’ poor management, and the opposition of POGO and the rest, we need to stop whining about what others are doing to us and start dealing with it. This means learning to live with increased scrutiny. This also means presenting the Lab as a capable and effective entity. The environment live in is not about to change, and if ‘getting’ compliance is what we need to do to survive, then we need to stop whining and get it.
 
Well written comments, 09:49:57.

I still object to what seems to be an overwhelming need for Gary to continue to attempt to ingratiate himself with LANL management. If it appears that way to me, it must appear that way to others. In the end, does his "contribution" buy us anything?
 
Thanks 10:01:00.

In response to your comments on Gary, I've had the chance to work around him and have gotten to know him somewhat. I know that he comes off as ingratiating in some of his posts, but in the time I've known him he's been a startlingly honest person. He also has almost no fear of ridicule or criticism, which often leads him to say things without considering how they will be taken. I feel confident that he believes what he writes and believes that laying that perspective out is best for the lab. I sincerely doubt that he would post the way he has in order to climb the ladder (plus, judging from the abuse he often gets in reply, the career benefits you ascribe to his postings woud appear to be highly overrated)

-9:49:57
 
10:16 -- It's nice to hear from someone who knows Gary that he is not the sycophant he sometimes appears to be. Gary sure could stand to learn (from the feedback he consistantly gets on this blog, if from no other source) that he often leaves a bad impression.
 
I agree that he needs to pay more attention to how others percieve him - it might help him in getting his message across clearly. Maybe LANL ought to do the same.
 
If it looks like a sycophant, smells like a sycophant, and tastes like
a sycophant, isn't it a sycophant? I remember the posts and letters
to the editor that Gary wrote defending Nanos. He has a clear history.
 
"I heard the other day that Kuckuck was startled to see the level of fear among those involved in the recent DX mishap. Whatever Nanos’ intentions were, the creation of this sort of environment was wrong, and needs to be repaired as soon as possible."

Nanos didn't create this environment, although he did take it to unprecedented extremes. It was initiated by the Tiger Teams and has developed inexorably over the past 15 yeras. I remember the phrase "work free safety zone" being used as far back as 1995 when we were shut down following the CMR explosion and tasked with developing HCP's.
 
Time for a reality check here. (Geez, am I always the one that has to do this?) Gary, and his fellow travelers, always love to fret about the pesky gnats that bother LANL (Greg Mello, POGO, and the like), while ignoring the Republican alligators in Congress and the Administration who have chomped off one LANL leg and are eyeing the other. And Domenici stands by, with a bemused look on his face...or is it just drool?
Who has really hurt the Lab since Wen Ho Lee, and why? Does Gary have any constructive suggestions for calling off the alligators?
 
Gary said in his letter to the editor:

"To the extent that we individually have chosen not to take seriously the elevated risk to Los Alamos of non-compliance with safety and security regulations, we must shoulder the blame for the consequences, which we all must endure."

I know many people at LANL who have always taken safety and security seriously. Compliance with regulations is another issue. Regulations are not clearly written and open to interpretation by users and auditors. Lab management does not help when they rewrite the regulations in their own words. You can be safe and secure and still be non-compliant with someone else's understanding of the regulation. You can also follow all requirements and be unsafe or not as secure as you had hoped.

I don't think we must shoulder the blame and accept the consequences. It is our responsibility to point out when something we are ordered to do is unclear, incomplete, or wrong. Management's position over the past few years is to not make waves.

Larry Creamer
DX-1, Retired
 
Larry-

Gary does have a very good point, though, in that compliance with all regulations is critical for the safety of LANL, whether or not they actually benefit lab operations. An incident of regulatory noncompliance, regardless of how safe and secure our individual actions are, opens an opportunity for our enemies to drag LANL into the media and before Congress and set us on the defensive. This is what I believe he meant in noting that the elevated risk of non-compliance is something which inflicts its consequences on all of us. As I’m sure you’ll agree, ‘blame’ was a bad word for him to use – I would rephrase that comment to say that “we must shoulder the responsibility for the consequences, which we must all endure.”

I agree that we shouldn’t have to shoulder the blame for noncompliance – a mistake that Nanos made and paid for. We also shouldn’t sit back and not make waves – bad regulations harm LANL’s mission and overhead, and make the lab a miserable place to work. We should, however, work hard to be compliant with everything DOE throws at us if only to prevent the ‘gnats’ from finding some new story of arrogance and non-compliance to bring before Congress. As you note, it is our responsibility to point out that something we've been ordered to do is unclear, incomplete, or wrong, but it is also our responsibility to comply as best we can with what we have so as to prevent furhter damage to LANL.
 
I'm always amazed how easy it is for the 4th-floor suit-and-tie types to "get it" when it comes to work practices. If they actually had to run a crane, use a forklift, operate high-voltage equipment, account for radioactive material, deal with CREM etc., I think they would sing a different tune. Sure, Gary is right, we should all be perfect (like he apparently is). Unfortunately, "it" is not a real world entity. Until the regulations and regulators get in phase with the actual work and workers, we will continue to waste taxpayer monies on phony compliance treasure hunts. Compliance is not a mission and never will be. "It" is doing something worthwhile for the country with the huge sums of money we are entrusted with. I do "it" everyday despite the ridiculous 4th-floor nonsense that Gary continues to preach - not because of him or his ilk. I am amazed that the new Director didn't realize the level of fear that has been instilled at the working level. Paul Robinson certainly has no problem understanding the situation...
 
Anonymous : 6/24/2005 04:31:36 PM said:

[I would rephrase that comment to say that “we must shoulder the responsibility for the consequences, which we must all endure.”]

That sounds much better, and I agree with your comment that we should do our best to comply.

Larry Creamer
DX-1, Retired
 
I agree that while we should improve the awareness of the risks, both within the Lab in its operations and those outside of the Lab, and the effort must be made to identify and deal with the operational risks before the work is done, trying to accomplish the preparatory process and then the work is or can be impeded by the CYA or political posturing done by managers who often seem more concerned with safeguarding their jobs, paychecks or prestidge rather than being of service to those whom they supposedly lead. I hope to see that has changed, even in some small ways, in the interim period and with the contract change. I fear that the changes may be for the worse and come at greater costs for those trying to accomplish work though I hope the negative possibilities are offset by the Lab's ability to return to meaningful work.
 
If a person is honest it does not also mean that they are not an idiot. Gary, take a long honest look at yourself. Do you really know what you are talking about or are you just a well meaning idiot?
 
[Do you really know what you are talking about or are you just a well-meaning idiot?]
I really know what I am talking about. My interventions here are to give you a perspective you apparently do not yet have.

[Gary sure could stand to learn ... that he often leaves a bad impression.]
I apologize for coming off as condescending. I do have enormous respect for my fellows. I understand that this is an unpopular message to some. Might I suggest though, that some of the inveterate complainers and finger pointers might possibly be leaving a bad impression of LANL with a large swath of the world. I have come to appreciate--mostly from years of working with outstanding leaders, who also have imperfections, at LANL, in the Pentagon, and in other parts of government--that some leadership jobs are truly daunting. Seldom does one come to them with sufficient experience, skill, insight, or intelligence—though there are some exceptions. It is tragic that some subordinates magnify the difficulty of a very difficult job by second guessing decisions based on the one percent of the puzzle that they can see. The same all-seeing staff also berate an indecisive leader for not taking chances. It is cheap and easy to blame others for our own faults or for unavoidable problems-particularly as an anonymous complainer. I would like to see more character exhibited by all LANL personnel- including the vocal few.

[sycophant -fawning flatterer: a servile or obsequious person who flatters somebody powerful for personal gain]
Hmmm- Probably not. Check with any of my previous bosses- most of whom I greatly respect. None of them would characterize me as servile, obsequious, or flattering. They would be more likely to say that I am more candid and critically minded than is good for me.

[In the end, does his "contribution" buy us anything?]
If lurkers here who have an interest in improving the situation at LANL gain an understanding that their responsible engagement in: the development of rules and procedures, the feedback process, avoiding unnecessary institutional risk, and support for good leaders who are doing their best--then something good has been accomplished. I understand and accept that some are so focused on their narrow interests that they will not be persuaded.

[Does Gary have any constructive suggestions for calling off the alligators?]
The alligators are my concern, not the gnats. The alligators are not going to go away. This letter was to you, asking you to stop drawing the Lab into the swamp. Suggestion: pay attention to the above letter, do your job well, build up LANL, be a constructive part of the next decade or two—whoever wins the contract.

Larry Creamer- I respect and appreciate the vast majority of LANL personnel who do "get it" and behave both responsibly and exceedingly carefully in potentially risky activities. I also agree that some rules can be misguided, even wrong. Also that there are cases where levels of management do not engage with the insight, courage, or decisiveness needed (see above comment about leadership qualifications). However, when BLAME is being distributed for the consequences to the Laboratory of IGNORING rules, be sure to shoulder your share if you have not done your part to fix the problem of badly constructed or conceived rules or to comply with the rules that are in place. If we only had to obey the rules we liked, wouldn't that be a fun world?

I am having a great time at LANL. I like the people I work with. I value the breadth of opportunity here, and the wealth of talent and capability we have to draw on. No, LANL is not perfect and we have many challenges to overcome.
Gary
 
Gary said:

"Larry Creamer...However, when BLAME is being distributed for the consequences to the Laboratory of IGNORING rules, be sure to shoulder your share if you have not done your part to fix the problem of badly constructed or conceived rules or to comply with the rules that are in place."

I was a safety and security officer in my group for many years. I did everything in my power to correct problems I saw and I did comply with all the rules even those I could not correct. My share of the consequences for not "getting it" was to lose a years salary because I retired early to protect my pension.

Larry Creamer
DX-1, Retired
 
Larry-
By my standard, then, you do get it.

When the ship is weathering a storm everyone on board incurs risk. You chose to retire, evaluating the risk and knowing the cost.

I think we are going to come out all right, but want us to not do anything that increases our risk.
Gary
 
Gary said on 6/26/2005 at 02:31:10 PM:

"Larry-
"By my standard, then, you do get it.

When the ship is weathering a storm everyone on board incurs risk. You chose to retire, evaluating the risk and knowing the cost.

I think we are going to come out all right, but want us to not do anything that increases our risk.
Gary"

Thank you Gary. I did not like retiring early because I had not finished what I needed to do, but I knew the cost and saw no alternative.

Clearly, you should do nothing that increases your risk of suffering the consequences of failure to comply with requirements. Do not forget that it is also your responsibility to resist being forced to do that which you believe is wrong. Be sure you are correct in your thinking, complain to management, and give up only when you are sure that you have no chance to win your argument and the issue has no serious safety or security consequences.

Win if you can; lose if you must, but always fight when you are right.

Larry Creamer
DX-1, Retired
 
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