Throughout my career I’ve faced the challenge of Manuals – the content, the expectations, and the grammar.
It’s important to ensure the content of your manual clearly and accurately states what is expected of your employees. Ambiguity in a manual system is not good. It is our responsibility to leave no doubt as to what the employees must do.
In prior interactions with FAA inspectors regarding manual content I have heard a familiar refrain, “State what you do, then do what you state.”
Once I was questioned on the use of the words “should" vs. "shall/must.” I then became obsessed with ensuring my organization’s policies, processes, and procedures were correctly worded. It is not what you “might do" or “should do" but what you “shall" or "must do". This word change is the difference between a suggestion and a direction.
At Baldwin, we review a lot of manuals for our clients. During each review, with the words of those previous FAA Inspectors ringing in my ears, I purposely look for where and how the words should, shall, and must are used. I often find instances of the word “should” where “shall/must” is more appropriate.
For instance, the FAA states in 14 CFR Part 5.21(c) “The safety policy must be documented and communicated throughout the certificate holder's organization.” In this case, the FAA does not give an operator the choice about documenting and communicating their safety policy.
One of our clients makes the following statement within their SMS manual regarding this regulation “The Safety Policy shall be posted throughout the organization and at all operating locations using the appropriate media.” Good use of the word “shall” and in line with the FAA regulations.
Another client makes the statement, “Flight regulations, procedures and manuals should be in accordance with this Safety Policy.” This is an example of using “should” when “shall” is more appropriate. Must the flight regulations, procedures and manuals be in accordance with the company safety policy or not? The use of "shall" would take away any ambiguity here.
It is important to take the time to review the content of your manuals on a regular basis. A good use of the search feature is looking for the word “should” and then read the context in which it is being used. You may be surprised how often the word needs to be changed.
Remember, create unambiguous policies, processes, and procedures in your manual. Use the proper wording throughout. Leave no doubt as to what the employees must do. As the FAA says, “state what you do, then do what you state.”
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Manual- A Critical SMS element