Political
Chemistry: Tact & Diplomacy
Barbara Kanegsberg, BFK Solutions LLC
Tact? Diplomacy? Fergedaboutit! Ok, sometimes you do need tact. We are often
asked about the advisability of proactive informational exchanges with those
outside your company, particularly regulatory agencies. By regulatory groups
I am using a comprehensive definition to include:
• Regulatory and safety agencies like the EPA and the Fire Department
• FDA
• DoD, DOE
Even if you are not required to, sometimes you can save your company
money and headaches by contacting agencies proactively, with some
important provisos:
Obviously, if you are not in charge of working with such groups, your
job security is well served by reading this article with interest
and passing
it on to whoever is in charge. Also, if you are required to notify an agency
about a change or some other condition within the company, what are you
waiting for? Even if there are no formal requirements for communication,
if there
appears to be a situation where you should communicate with agencies, we
suggest doing so.
Why not let sleeping dogs lie?
Suppose you are considering a process change, perhaps a change in the
industrial cleaning process. Let’s assume that it is a change where you are pretty
nearly certain you don’t have to contact the agency. It not necessary
to ask permission when you don’t need to; however, informational updates
are often appreciated. Many agency people respond favorably to being kept
in the loop. Here are some likely responses:
Clarification that there is no problem
If you had a nagging, semi-subliminal suspicion that there might be
a problem, this response can provide invaluable reassurance, allowing
you
to move
forward.
Advice you can actually use
A surprising number of regulators, bureaucrats, and bean-counters
have actual technical smarts; and they may have a background and
an ongoing
interest
in manufacturing. In such cases, they are likely to share their ideas,
thus providing you with a bit of free consultation.
A heads-up about upcoming requirements
The sooner your company knows about required changes, the better.
You may gain an advantage over many of your more introverted
competitors in that
there will be more time to consider materials changes, process
development, engineering controls, etc. This longer lead-time tends to
save money.
An informal opinion that there might be a problem with your planned
modification
This is why you were afraid to contact the agency in the first
place, but it is not the worst thing in the world. You have
just saved the
company time, money, headaches. What next? Try to get a bit
more information. Ask
about
other options. You may learn about:
Options that are more appropriate than the ones you originally
considered
Typically, cleaning processes have more than one option.
There are many parameters to a rugged process; one of them
is that
it is acceptable
to the pertinent
regulatory agencies.
Perhaps as important, such contact builds goodwill. You and
your company are showing an honesty and forthrightness
that may help
should problems
arise at a later date or in the event that someone at the
company does make an
honest mistake.
Deciding exactly when to voluntarily contact the regulatory
agency is sort of like deciding exactly how to modify
a critical cleaning
process;
it’s
very application-specific. It depends on your relationship with the agency
group in question and on the individuals involved. If your agency contact
makes Cruella De Vil (the fictional character in ‘The One Hundred and
One Dalmatians’) seem maternal by comparison, perhaps silence
is prudent. You might also look for an alternate agency contact.
If you are undecided, and have the authority to do so,
try a bit of benign but proactive communication on
a test-case basis.
You may
be
pleasantly
surprised.
