Corrective Action - AS9100 Approved Supplier List Audit Nonconformance

[dbaca0903]

We just went through our AS9100C transition/reassessment. Everything went ok for the most part. We had 4 minors and 0 majors, and when we close out the NCRs, we'll get our certificate.

Now the issue. One of our NCRs was not having our calibration lab on our approved supplier list. This was totally my fault, I forgot to add them to the list when I was updating the it. They where on previous lists, but the auditor gave the response "Are they on the CURRENT list? NO... thats a finding". So we got dinged for that. Whats the appropriate response?? whats an acceptable "root cause"? I don't want to put "operator error", but it was an oversight.

Has anyone else gone through something similar? How did you handle it?

[Big Jim]

Error proofing comes mind.

Root cause, inadequate error proofing when compiling a new approved supplier list.

Corrective action, proof read old list to new list with an assistant or by ticking off the names on the old one when confirmed on the new one.

I agree with you that this is an awkward one to answer. But try to expand your thinking and remove the possibility of "human error" of being one of your responses and try harder to find another route. As long as you keep thinking that "human error" is the only answer and keep it on your mind you will never find another answer.

[dbaca0903]

Thanks Jim. I like the error proofing term also. That sounds a lot better then what I was thinking about. We are also updating our computer database, it will keep track of the list for us.

[Big Jim]

Moving to a computer database could be part of your "error proofing".

[dbaca0903]

I submitted the NCRs using the root cause that jim suggested. The other 3 root causes were answered in a similar fashion.

I heard from my auditor and...... they were all rejected . so ill be revisiting the NCRs to try to get an acceptable root cause statement for each. I'm researching different 'tools' for root cause. But how far do you go? I thought the suggestion that Jim gave was reasonable enough, it is what happened! Has anyone else had experience with the 'new' review of NCRs for AS9100C? I say new because the auditor blamed his decision on a review board.

[Big Jim]

Start by talking to the auditor and see what he can tell you about the deficiency. Although he can't answer them for you, he should be able to tell you more than just that they are rejected.

One of the best guidance documents available for answering audit nonconformances is the ANAB "Heads Up" 137. It can be found on the ANAB web site:

http://www.anab.org/documents/heads-up.aspx

Be aware that the audience is slightly different. It is how ANAB wants Certification Bodies (Registrars) to answer nonconformances written by ANAB against the Certification Bodies. The principles are the same though.

Something to keep in mind is that they expect to see a good correction (action taken to overcome the nonconformance), an appropriate root cause, one that truly gets to the root, not just one of the contributing causes, and an appropriate corrective action (action taken to overcome the CAUSE of the nonconformance). If the root cause is perceived as not deep enough, it will be rejected. If the correction and corrective action are nearly the same, that shows either an inadequate root cause or a misunderstanding as to what the difference is, and will always be rejected.

Read the "Heads Up" 137 and see if it helps.

[J Allen]

This is another example that Registrars go beyond the meeting corrective action. I thought if the corrective action taken would prevent the non-conformance from happening again, it would be acceptable. In this case, it appears to heve been an over sight and by adding it to the computer database insted of a manual system as well as proofreading he list, would be an effective corrective action. If you throw enough dollars into corrective action, I suppose it could be made fail proof. But I don't believe it is always in the best interest of the company chasing pennys with dollars.