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Lean Government Working Smarter and Faster for Environmental Protection July 2010.

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Presentation on theme: "Lean Government Working Smarter and Faster for Environmental Protection July 2010."— Presentation transcript:

1 Lean Government Working Smarter and Faster for Environmental Protection July 2010

2 What is Lean? Why use Lean? Who is using Lean? State, EPA, and other federal Lean efforts EPAs Lean Government Initiative Supplementary Information: What does it take to do Lean? Linking Lean to EPA priorities Lean deployment Potential future directions for Lean at EPA Outline 1

3 What Is Lean? 2

4 3 Lean: Lean is a set of principles and tools that help people learn to see and eliminate waste Six Sigma is a collection of tools that identify sources of variation in any process to improve quality Lean government: Enables environmental agencies to work more effectively and efficiently to protect human health and the environment by identifying and eliminating waste in government processes Methods include: Value stream mapping and kaizen events Kaizen = change for the good of all What Is Lean?

5 Typical Wastes Targeted by Lean 4 WastesExamples InventoryBacklog of Work (permits, plan approvals), Excess Materials/ Info DefectsData Errors, Missing Info OverproductionUnneeded Reports and Copies, Doing Work Not Requested ComplexityUnnecessary Process Steps, Confusing Instructions/Requirements WaitingApproval Cycles, Incomplete Applications or Plans Excess MotionTrips to Printer, Copier & Files, Unnecessary Meetings & Travel Moving ItemsReport Routing, Document Storage

6 3-5 day event with cross- functional team Strong leader commitment w/ experienced facilitator Training on Lean methods Mapping the current process Identifying improvement opportunities Mapping a new, improved process Rapid implementation of new process and measurement of results What Is a Kaizen Event? 5

7 House of Lean Methods 6 1 Point of Use Storage Continuous Improvement Kaizen Just-in-Time/KanbanCellular Design Mistake- Proofing Quality at SourcePOUS 1 Quick Changeover Standardized WorkBatch ReductionTeams Visual Controls5S (or 6S)Flow/Layout Value Stream Mapping 3P (Production Preparation Process)/ Design for Lean Six Sigma

8 7 Facilitated by Lean professional / trainer Problem Identification/Planning Identify key people Develop a charter – problem definition, metrics, goals Identify and gather data required 3-5 Day Event Day 1 - Just-in-time training in Lean for participants Value Stream Map or Kaizen event Day 3 (or 5): Develop Implementation Plan Follow-up and Implement May take a few days or several months Document Additional events if needed Review progress at 30/60/90 day intervals Communicate successes How Does Lean Work?

9 Why Use Lean? 8

10 Achieves environmental results Ensures better customer service Reduces process complexity Enhances process speed Produces quality products and services Improves staff morale Lean is common sense uncommonly applied Why Use Lean? 9

11 Example Results AgencyProcessAnticipated Results EPA Region 7 & 4 States NPDES Wastewater Program Decreased time for EPA review of a state wastewater program by 75-68% (from 4-19 months to 1-6 months) Eliminated 67% of the process steps (39 to13 steps) Connecticut DEP Coastal Permit Program Reduced review period from 500 days to <120 days Delaware DNREC Air Construction Permits Cut backlog of permits from 199 to 25 Reduced average permit processing time to <76 days Nebraska DEQ Ethanol Plant Air Construction Permits Reduced permit review time 50% Cut permitting backlog by 55% Minnesota PCA Wastewater Permitting Process Increased percent of permits issued within 180 days from 9% to 75% (Six Sigma project) 10

12 Is Lean another flavor of the month? How does it differ from TQM and other improvement efforts? Why Lean is different: Focuses on rapid, immediate, real-time change Delivers fast results to build momentum Emphasizes doing over planning Keeps all eyes on what matters thru metrics/visual systems Builds continuous improvement culture by empowering workforce to own the process and its effectiveness What Makes Lean Different? 11

13 Backlog of review and approval actions (e.g., SIPs, permits, standards) Slow and inefficient human resource and hiring processes Inefficient grant and contract management processes What Problems Can Lean Solve? 12

14 Results Accountability Empowerment Action Excellence What Is Powerful About Lean? 13

15 Who Is Using Lean? State, EPA, and Other Federal Lean Efforts 14

16 Origins: Lean Six Sigma 70% of U.S. manufacturing firms report using Lean (Industry Week 2008) Rapidly expanding use of Lean in government and service sectors Who Is Using Lean and Six Sigma? 15

17 Lean at State Environmental Agencies 16 - State Lean Events Completed* - States Interested in Lean - State Lean Events Completed - States Interested in Lean 28 States have completed Lean events 8 States are interested in Lean *Events EPA is aware of as of June 2010.

18 Iowa Department of Natural Resources Air Quality New Source Construction Permits Kaizen Event Before Lean: Issue ~2,000 permits per year Average lead time: 62 days After Lean Implementation: Lead time reduced to 12 days (down to 6 after 6 months) Process steps cut by 70% Internal agency handoffs cut from 18 to permit application backlog eliminated in 6 months More customer friendly process and improved staff morale Compelling State Lean Results 17

19 Compelling State Lean Results 18 Old Process Future Process Percent Decrease Permit Issuance Time 542 Days34 Days94% Steps % Decisions31584% Handoffs18667% Delays39392% Vermont Department of Environmental Conservation NPDES Water Quality Permitting Kaizen Event Note: Results reflect anticipated improvements after implementation is complete.

20 Compelling State Lean Results 19 State Agency Permitting Process Time Before (days) Time After (days) Percent Decrease Idaho DEQ Permit to construct % Indiana DEM Title V permit modifications % Iowa DNR Standard air construction permits 62690% Iowa DNR Air quality complex permits % Michigan DEQ Major air construction permits % Michigan DEQ Minor air construction permits % Air Permitting Process Improvements with Lean Note: Results reflect anticipated improvements after implementation is complete.

21 AO Federal Government Lean Activity 20 Over 20 federal agencies have used Lean to improve the speed & effectiveness of their processes

22 Nuclear Regulatory Commission (NRC) Target Process: Hiring Results: Cut hiring time by 50% Federal Bureau of Investigation (FBI) Target Process: Multiple processes Results: 36% reduction in work process steps; $3M+ in savings Pension Benefits Guaranty Corporation (PBGC) Target Process: Human Resources Results: 60% average efficiency gain from Lean U.S. Department of Housing and Urban Development (HUD) Target Processes: Procurement and Hiring Results: Loan application approval time reduced 22-30% Compelling Federal Lean Results 21

23 Federal Improvement Team (FIT) Community of Practice (CoP) Sharing intellectual capital and collaborating, including best practices, training, and lessons learned on Lean, Six Sigma, & other agency improvement efforts Performance Improvement Council (PIC) Executive Order, Improving Government Program Performance, 11/07 Assist President, through OMB in making recommendations to Congress Performance Improvement Officer (PIO) – SES from each agency Working Group on Process Improvement (WG-PI) for PIC Members include subset of FIT CoP Cross-Agency Federal Organizations & Activities 22

24 Federal Improvement Team Agencies 23 Defense Agencies: Defense Logistics Agency Office of Under Secretary of Defense for Acquisition, Technology, and Logistics U.S. Air Force U.S. Army U.S. Coast Guard U.S. Joint Forces Command U.S. Marine Corps U.S. Navy Environmental Protection Agency Federal Aviation Administration Federal Bureau of Investigation Internal Revenue Service National Archives and Records Administration National Institutes of Health National Oceanic and Atmospheric Administration Office of Management and Budget Pension Benefit Guaranty Corporation U.S. Dept. of Agriculture U.S. Dept. of Homeland Security U.S. Dept. of Housing and Urban Development U.S. Dept. of Labor U.S. Dept. of the Treasury, Comptroller of the Currency U.S. Dept. of Veterans Affairs U.S. Forest Service U.S. General Services Administration U.S. Geological Survey U.S. House of Representatives U.S. International Trade Commission U.S. Nuclear Regulatory Commission U.S. Postal Service

25 Goal - Improve the performance of Federal functions Provide advice (analyses, options, & recommendations) to help: Increase capacity and capabilities to improve performance through process improvement (e.g., BPA) Improve the performance of targeted operational functions (e.g., hiring) Link and promote the development and use of effective improvement practices throughout the Government. (e.g., FIT, PIC, other councils) Working Group on Process Improvement (WG-PI ) 24

26 Joint Events with Other State & Federal Agencies: 4 State-EPA Region 7 Clean Air Act State Implementation Plan (January 2010) 4 State-EPA Region 7 Wastewater Permitting Review (August 2008) EPA OW Endangered Species Act Consultation with USFWS & NOAA Fisheries (May 2008) 4 State-EPA Region 7 Water Quality Standards Review (June 2007) EPA-only Events: EPA Region 6 Pesticides Enforcement Case Review (October 2009) EPA Region 4 funded five State events (August – December 2009) EPA OCFO Annual Budget Review (June 2009) EPA OCFO Corrective Action Tracking (December 2008) EPA Lean Kaizen Activity 25

27 Compelling EPA Lean Results 26 Process Time Before Lean Improvements Process Time After Lean Improvements Percent Reduction OCFO OIG Correction Action Tracking Process 324 hours104 hours68% Region 6 Pesticide Enforcement Case Resolution 455 days216 days53% Region 7 / Four State Clean Air Act SIP Process 7.4 years3.2 years56% Note: Results reflect anticipated improvements after implementation is complete.

28 State-EPA Lean Collaboration: Clean Air Act State Implementation Plan 27 EPA R7 & HQ, Iowa, Kansas, Missouri, & Nebraska Clean Air Act State Implementation Plan (SIP) Kaizen Event Approach: 5-day kaizen event in January 2010; follow-up activities Scope: Improve SIP process from time EPA promulgates a rule that requires States to prepare/modify a SIP to final EPA approval Results: Improved working relationships, collaboration, and efficiencies When fully implemented, the new SIP process is expected to: Reduce total processing time from 7.4 to 3.2 years ( 56%) Cut best case delay time from 4.7 to 1.1 years ( 77%) and worst case delay time from 8 to 1.3 years ( 84%) Decrease process steps from 165 to 134 ( 19%) Free staff time to address and prevent backlogs

29 28 EPA R7 & HQ, Iowa, Kansas, Missouri, & Nebraska Water Quality Standards Review Kaizen Event Approach: Focus on improving State-EPA collaboration 5-day kaizen event in June 2007; follow-up activities Results: Process steps reduced from 50 to 26 Cut non-value added time in the process 50% drop in number of EPA decisions needed Common understanding of and documented new improved process Clarified roles & responsibilities, built trust, change relationships State-EPA Lean Collaboration: Water Quality Standards

30 EPA R7 & HQ, Iowa, Kansas, Missouri, & Nebraska NPDES Permitting & Enforcement Process Kaizen Event Approach: Focus on Inspection Lists Submittal, Review, and Approval 5-day Kaizen Event in August 2008; follow-up meetings Goals/Objectives: Assure programs exceed acceptable level of performance Reduce number of permits that merit objection Develop common understanding of process Clarify roles & responsibilities, build/building trust Document new improved process Reduce/focus process steps and reporting where possible State-EPA Lean Collaboration: NPDES Water Pollution Discharge Elimination 29

31 EPAs Lean Government Initiative 30

32 Launched in 2005 in Office of Policy Outgrowth of EPA Lean & Environment Initiative 1.5+ FTE Partnership with ECOS: EPA grant ($150K) to ECOS for State Agency Lean efforts March 2010 ECOS-Lean Government Memorandum of Understanding Key Initiative activity areas: 1.Tool development 2.Networking and coordination 3.Communications and outreach 4.EPA Lean event support EPAs Lean Government Initiative 31

33 1.Tool Development Working Smart for Environmental Protection Lean Government Primer (2006) Lean in Air Permitting Guide (2008) Lean in Government Starter Kit, Version 2.0 (2009) Lean Government Metrics Guide (2009) Lean case studies (2006–2010) EPAs Lean Government Initiative 32

34 2.Networking and Coordination EPA-ECOS coordination and collaboration EPA Lean Practitioners Network Reps from EPA offices and regions Federal Improvement Team Community of Practice and OMB PIC Working Group on Process Improvement Participating in network of federal Lean implementers EPAs Lean Government Initiative 33

35 3.Communications and Outreach EPA Lean Government website Presentations on Lean Government within EPA Presentations/displays at meetings and conferences Inventory of State environmental agency Lean activity EPAs Lean Government Initiative 34

36 4.EPA Lean Event Support Assisting EPA offices with planning and conducting Lean events Direct participation in selected EPA Lean events Maintenance of a Lean Facilitators List Post-event case study documentation Briefings on Lean for EPA managers EPAs Lean Government Initiative 35

37 Contact: Kimberly Green-Goldsborough (202) Website: For More Information 36

38 Supplementary Information 37

39 What Does It Take To Do Lean? 38

40 Successful process improvement requires organizational commitment over the long term You must DRIVE change from the top down Communication Proactive Frequent Consistent External stakeholders at the table What Does It Take to Do Lean? 39

41 Participate actively and visibly Set vision and define boundaries Remove obstacles to change State unwavering support for Lean teams work and the new process Help people shift to value-added roles – overcome resistance from the middle Display passion for pursuit of perfection Emphasize no job loss– Make a commitment that no one will lose his/her job due to continuous improvement activities Leaders Must… 40

42 Expect initial staff resistance: Weve already tried that. The focus on streamlining processes may erode environmental protections. We dont have time to focus on process improvement. Common Reactions to Change 41 C.A.V.E. People: Citizens Against Virtually Everything Proactive communication and demonstration of positive results can alleviate concerns

43 Visible leadership commitment is essential to success Scope Lean events carefully to address real needs and build momentum Know who the customer is and involve them Set realistic expectations given the process type Success blooms from sustained and effective follow-up Vision is not enough, it must be combined with venture. It is not enough to stare up the steps, we must step up with stairs. -Vaclav Havel, former President of the Czech Republic How Can You Plan a Successful Lean Initiative? 42

44 Linking Lean to EPA Priorities 43

45 How Lean Relates to EPAs Mission 44 Lean government enables environmental agencies to work more effectively and efficiently to protect human health and the environment Example Lean Applications: Wastewater discharge permitting Air construction permitting State Implementation Plan review RCRA corrective actions Grants Hiring

46 EPA Strategic Plan Goals Cutting Waste Increases Time for Mission Critical Work 45 Wasted time Unnecessary work and process steps Unnecessary approvals and handoffs Ineffective meetings Inaccurate or incomplete information Errors in documents Excess s and copies of documents Clean Air and Global Climate Change Clean and Safe Water Land Preservation and Restoration Healthy Communities and Ecosystems Compliance and Environmental Stewardship Process Wastes

47 1.Taking Action on Climate Change Lean was referenced in EPAs proposed PSD &Title V GHG tailoring rule as an important strategy for improving permitting capacity Lean concepts could be used to design new processes associated with the GHG rules for mobile sources and large stationary sources 2. Improving Air Quality Lean is an effective tool for improving core agency processes, such as those in Administrator Jacksons 1/12/10 priorities memo: Improved monitoring, permitting and enforcement will be critical building blocks for air quality improvement. Lean as a Tool for Advancing Administrator Jacksons Priorities 46

48 3.Assuring the Safety of Chemicals Lean could help improve: chemical safety review, health assessment, and chemical management plan development processes 4.Cleaning Up Our Communities Lean could help improve: Superfund cleanup process, Brownfields Program (e.g., grants process, assistance/incentive programs), and enforcement processes Lean as a Tool for Advancing Administrator Jacksons Priorities (cont.) 47

49 5.Protecting Americas Waters Lean could help improve: water quality regulatory and enforcement processes, grant processes, and new efforts such as the Urban Waters Initiative 6.Expanding the Conversation on Environmentalism and Working for Environmental Justice The kaizen methodology of Lean fits with the spirit of this priority: Lean focuses on implementation, is team based, and people with outside perspectives are included in events A Lean value stream mapping event with the Childrens Health Office could create a future state vision & implementation plan in 3-4 days Lean as a Tool for Advancing Administrator Jacksons Priorities (cont.) 48

50 7.Building Strong State and Tribal Partnerships This priority speaks to the need for environmental agencies to do more with fewer resources (Leans goal), and how EPA must do its part to support state and tribal capacity EPA and ECOS entered into a Lean government MOU in March 2011 to continue joint agency commitments and partnerships to improve federal-state processes National Program Manager guidance in FY 2011 calls on Regions to identify collaborations to improve state-EPA processes & promote continuous improvement with Lean Lean as a Tool for Advancing Administrator Jacksons Priorities (cont.) 49

51 7.Building Strong State and Tribal Partnerships, continued EPAs Lean Government Initiative supports EPA, State, and other government agency Lean efforts through: o Tool development o Networking and coordination o Communications and outreach o EPA-State Lean events Lean as a Tool for Advancing Administrator Jacksons Priorities (cont.) 50

52 Lean Deployment 51

53 Lean Deployment Models 52 Model TypeCharacteristics Agency-Wide Model Top down driven Comprehensive Rapid, highly visible deployment Major culture change Department/ Division Model Department leadership but agency management support Department pilot for agency Comprehensive at the department level Culture change Targeted Model Top management leadership Focused on a few specific agency problems Driven by a desire for strategic impact Culture change is not a deployment objective Grass Roots Model Originates at the bottom of the agency Project or problem specific Highly motivated individuals lead the effort Culture change is not an objective

54 Lean Deployment Models – Considerations 53 Model TypeDeployment Considerations Agency-Wide Model Requires significant, sustained investment and solid leadership from top management Large infrastructure and full-time staff Significant planning and management, including integration with other management systems Need for common language and methodology Need to address cross-agency processes 5+ years to achieve lasting culture change Department/ Division Model Similar to agency-wide model but on a smaller scale Easier to start due to smaller scale Slower pace is possible; scale up after initial success Greater use of consultants and outside training Less integration with management systems Risk of not getting beyond the department level

55 Lean Deployment Models – Considerations (cont.) 54 Model TypeDeployment Considerations Targeted Model Easy to get started Can work in smaller agencies Infrastructure needs are small; generally use contracted resources Little systematic integration with management systems Quick results because problems identified ahead of time Risk of not sustaining the gains Grass Roots Model Relatively easy to do but difficult to sustain over time Very vulnerable to changes affecting staffing Few if any initial infrastructure needs; no integration with management systems Often rely on external Lean consultants Lean implementation approach may vary across agency Can generate good results from individual projects Track record for sustainable improvement is not good

56 Deployment Model Selection Factors 55 Desired ImpactDeployment Model Business Transformation Agency-wide deployment Major culture change Agency-wide Model Department/Division Model Strategic Improvement Targeted deployment on critical problems Projects necessary for success or survival Targeted Model Problem-solving Specific operational problems Incremental improvements in agency performance Grass-Roots Model

57 Department of Defense (Agency-Wide Deployment Model) Services began using Lean over 10 years ago as individual agencies, now it is systematically deployed across multiple agencies DoD launched Continuous Process Improvement and Lean Six Sigma (CPI/LSS) initiative in April 2007 to accelerate LSS implementation in DoD and to make deployment more consistent Extensive use of Lean consultants and in-house Lean expertise Nuclear Regulatory Commission (Agency-Wide Deployment Model) Launched a Lean Six Sigma initiative in 2007, creating a program, training staff and managers, and executing several Lean projects Significant internal resources dedicated to Lean capacity building, training, and execution throughout the agency Lean DeploymentExamples from Other Federal Agencies 56

58 Nuclear Regulatory Commission, Early Lean Implementation (Targeted Model) NRCs Commissioner launched a Lean initiative in 2007 targeted initially on improving the agencys hiring process Add anything on reliance on external consultants? After this initial success, NRC has established support infrastructure for Lean and expanded implementation across the agency (agency-wide deployment) Housing and Urban Development (Department/Division Deployment Model) HUD started using Lean in January 2008 in the Office of Housing, focusing initially on loan application processes HUD has used outside consultant support and is working on building internal capacity HUD is in the early stages of Department/Division Deployment Model deployment Lean DeploymentExamples from Other Federal Agencies (cont.) 57

59 Federal Bureau of Investigation (Grassroots Deployment Model) FBI began implementing Lean in Ten staff members conduct events internally Conducted ~10 lean events in the 1 st year without outside support Very limited reliance on consultant support for staff training Pension Benefit Guaranty Corporation (Grass Roots Deployment Model) PBGC started a Lean office in 2007 and has 3 FTEs Lean implementation has focused on addressing specific individual problems through kaizen events Lean DeploymentExamples from Other Federal Agencies (cont.) 58

60 Potential Growth of Lean Activity Over Time 59 Source: Five Phases of the Transformation Roadmap from Flinchbaugh, Jamie and Andy Carlino, The Hitchhikers Guide to Lean: Lessons from the Road. (Dearborn, MI: Society of Manufacturing Engineers. 2006) page 67. Phase Zero: Exploration Phase 1: Building the Foundation Phase 2: Expanding with Tools and Deeper Thinking Phase 3: Integration & Reinforcement Phase 4: Building Momentum Lean Activity Level Education, Communication, Infrastructure, Application of Tools and Methodology, and Demonstrating Results are important to all of the phases

61 Another View: Potential Growth of Lean Activity Over Time 60 Five or more years to a Lean culture Transforming Optimizing Improving Grass Roots Deployment (Opportunistic) Agency-wide & Department/Division Deployment (Culture Change) Targeted Deployment (Strategic)

62 Potential Future Directions for Lean at EPA 61

63 Environmental agencies fully adopt a continuous improvement culture Environmental agencies systematically use lean methods to operate more efficiently and effectively Environmental agencies consistently achieve better environmental results with less resource investment A Vision for the Future 62

64 EPA Lean Government Logic Model 63 INPUTSOUTPUTSOUTCOMES What we invest - 1 to 2 FTEs at Office of Policy - EPA Lean Practitioners Network - Partnership with ECOS and grant - Contractor resources ACTIVITIESPARTICIPANTSSHORT TERMMEDIUM TERMLONG TERM What we do 1. Networks and Coordination 2. Communications and Outreach 3. Product Development 4. Lean Event Support for EPA and States Whom we reach - EPA managers and staff - State environmental agency managers & staff - Other government agencies implementing lean (federal, state, local) - The public (e.g., through website) Environmental agencies (and EPA Offices) can be divided into two types: (1) Agencies/Offices that are new to lean (2) Agencies/Offices at the second stage (have done at least 1 lean event) What the short term results are - Increased adoption and use of lean at EPA and state environmental agencies - Improvements to individual agency processes What the long term results are - Environmental agencies have begun adopting a continuous improvement culture (e.g., the culture has changed in parts of an agency). - Environmental agencies sustain the results from individual lean events. - Environmental agencies shift from piloting lean events to department-wide lean deployment. What the ultimate impact(s) are - Environmental agencies fully adopt a continuous improvement culture. - Environmental agencies systematically use lean methods to operate more efficiently and effectively. - Environmental agencies consistently achieve better environmental results with less resource investment. PERFORMANCE MEASURES - # of EPA lean events (total & per year) - # of state environmental agencies using lean - Results from lean events (reductions in lead time, process steps, backlogs, defects, costs, etc.) - # of EPA offices/ programs and state environmental agencies adopting lean at a department/program level - Environmental results (outputs and outcomes) - Environmental results (outputs and outcomes) per FTE and/or per total dollar investment

65 Support EPA Lean events Plan and conduct additional EPA and EPA-State Lean events Develop new tools/products Lean Leadership Guide / Executives Guide to Strategic Lean Deployment Guide to Scoping Lean Events Continue networking and communication activities Develop an EPA Lean Deployment Strategy Identify priority focus areas and sequencing for Lean activities Determine level of leadership commitment to Lean Develop EPA Lean capacity building and funding strategy Future Directions 64

66 What might a major EPA commitment to Lean look like? Administrator-level support and attention to Lean deployment Establishment of an EPA Lean Government Office and/or cross-agency Lean Steering Committee 4-6 FTE, including Lean event facilitation expertise $ K in extramural resources to support EPA Lean events, tool development, etc. Resources and contract vehicles established for supporting Lean activity in EPA offices, divisions, and regions Development of Agency-wide Lean deployment and capacity-building strategy Future Directions 65

67 Options for Supporting EPA Lean Activity: 1.Diffused Approach: EPA offices, divisions and regions fund and contract for their own Lean activity with limited technical assistance from EPAs Lean Government Initiative 2.Centralized Contract: Office of Policy establishes centralized Lean services contract and provides some matching funding to EPA offices for Lean activity 3.Coordinated Competition: Establish a competitive internal process to select EPA offices or divisions for concerted Lean activity each year (similar to Program Evaluation competition) Future Directions 66

68 Should we create a Lean Steering Committee and/or a Lean Office? Do we need a standard approach for Lean (e.g., use a centralized Lean contract, standard training program, etc.)? Should we build internal Lean competency (train our own Lean facilitators)? How will we evaluate our performance over time? Future Directions – Questions to Consider 67

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