The Costa Concordia, a Carnival Cruise Line owned ship, ran
aground resulting in at least 6 deaths. This is a 4,000-passenger, 115,000
-ton cruise mega-ship, with the latest and greatest technology, as it is just 5
years old. As an Enterprise Risk Management (ERM) professional, my
forecast is that we will learn over the next six weeks that this is not the
first near miss for the Costa Cruises organization, nor the first questionable
judgment call by one of their ship's captains. My bet is that one of the
thousands of crew management have reported issues in the past and that other
Carnival ships have faced similar operational risks in the past several years.
The problem is each one of these issues in its silo is a one-off near miss and perhaps in isolation is not worth escalating to senior management that sets policy. Put them together however, and you see a grave systemic pattern that is likely to result in disaster that would have been preventable had the systemic pattern been detected and managed as a whole rather than as one-off incidents.
To be effective, Enterprise Risk Management must be pushed out to the
front-line business process activity level where decisions are made 12and
information must aggregate
up across silos and levels to be understood by senior management. Few
organizations have their ERM programs functioning at the business process
activity level. Typically, organizations interview the top management about
their "risk worries" and boil things down to the "top ten risks".
Unfortunately, these top ten risks are disconnected from the everyday operating
controls at the business process activity level, so these "top ten risks"
continue to be unresolved. GRC programs are no better, as they focus on heavily
silo'd compliance, such as SOX, IT, and Internal Audit, and also do not link
risk to operating controls and business metrics at the business process
activity level.
The fact is that operational risk is all around us, typically most prevalent in
the organization's area of core competence. In the last year, I have blogged about
oil discovery firm's failure
to manage drilling risks, leading banks' failure
to manage investment risks, power companies' failure
to manage power risks and manufacturers' failure
to manage product quality risks. I have heard risk managers say their
bosses give the same answers too many times, "It won't happen to us," or, "Although
enterprise risk management is a priority, we are not ready to take our ERM
program to the business process level." Since 89% of ERM and GRC programs fail
to adequately manage operational risk at the business process activity level,
this dangerous game of not moving their ERM and GRC programs forward to detect
and manage operational risk at the front line activity level is not only fraud,
but also a form of "Russian roulette" with real consequences.
Due to SEC
requirements passed in February 2010, the once wide-spread practice of,
"Don't write it down," is no longer viable. Boards of directors are
now liable for not having their risk management programs reach the front line
business process activity level. Now, both management and their boards of
directors are liable for what they don't know, but should have known. If you
are a publically traded company or you are a supplier to a publically traded
company, evaluate your risk management effectiveness with these five
competencies:
1) Name all your front line business processes
2) Conduct a risk assessment in each of these processes
3) Connect mitigation activities to each
of the key risks in these processes
4) Connect your metrics for each process
to these mitigation activities
5) Connect your risks to performance management strategic objectives
These are five of twenty five requirements outlined in this complimentary risk
management maturity test available on-line: www.rims.org/rmm.
If you do not score above a "managed level" of risk management maturity, it
means your organization is failing to achieve these five simple steps in a
material manner at the front line activity level, where it matters the most.
The Costa Concordia accident was preventable, and so are the risks at your
organization.












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