Informal Corrective Actions - AS9100DCl. 10.2.1 A-H

[Michael_M]

I am looking to put into a corrective action procedure the ability to do an 'informal corrective action' (I cannot think of a better term). The concept behind this is not every problem that arises needs a formal documented corrective action and someone can fix the problem without spending time documenting everything.

I understand the need for corrective actions, but I also understand that not every problem needs a hammer (corrective action system). Sometimes a mistake occurs and get fixed by reasonable actions.

Per the AS9100D, 10.2.1 A-H there is nothing I see that requires documenting every corrective action, however, it is strongly implied. I want to be able to write something into the documented procedure that says not every problem requires a documented corrective action. However, any 'actual' corrective action needs to be documented, investigated, and what actions are taken.

1. Is this possible?
2. How can it be written (any suggestions)?

 

[Sidney Vianna]

It would be easier to provide feedback if you give examples of what you mean by "informal" corrective actions. I suspect that you are referring to corrections and not corrective actions.

 

[Michael_M]

I guess a better way of asking the question would be: "what defines the need for a corrective action?" and what exactly is a 'non-conformance'?.

We are trying to improve the filling out of the 'job cards'. Most (but not all) of the mistakes are the employee not paying attention, wanting to go home, or some other reason (probably 10+ reasons, each different). I don't want to put this in as a formal corrective action as the time to document does not really assist the solution, and the ability to repeat the mistake really violates the standard.

Example:
Person A does not fully record the job number correctly on card, then a week later person B does the same thing. This really is human mistakes and yes, there are ways to remove the humans from the activity but that really is not desired and the incorrect information is typically caught at the entry point. We want to correct this to reduce entry time.

I suppose I could say this example does not violate

"10.1 The organization shall determine and select opportunities for improvement and implement any necessary actions to meet customer requirements and enhance customer satisfaction"

but I would rather have something written that defines requirements of corrective actions or simple fixes.

 

[Sidney Vianna]

I guess a better way of asking the question would be: "what defines the need for a corrective action?" and what exactly is a 'non-conformance'?

We've had many similar discussions here, over the years.

The key thing to remember is the sentence in the standard that reads:

b) evaluate the need for action to eliminate the cause(s) of the nonconformity, in order that it does not recur or occur elsewhere,

As for what determines the need for action, it is a risk-based thinking determination. How critical, repetitive, serious, cost-inducing, etc is the problem?

Trying to procedurelize this determination can be very tricky as the scenarios and potential consequences can vary tremendously. In my experience, you want to leave some things to discretion of authorized/responsible personnel.

 

[Mike S.]

I agree that both AS9100 and common sense suggest that not every NC requires formal RCCA, and we say that in our procedures and training. For example, if it is truly an isolated incident, or of a minor nature, and/or the cause is known and resolution can be implemented quickly, we don't require formal use of the formal, documented RCCA process. And we have 2 levels of documented, formal RCCA process.

However, I will warn you, this "power" (to not do a formal RCCA) can be (and often is) abused to the detriment of the organization. It can be used as a license to ignore ongoing, systematic, and often expensive problems.

Maybe I am inferring what you did not imply, but it sounds to me like this problem is recurring relatively frequently, and you would like to fix it, but don't.

Could you reasonably justify your decision to not do a formal RCCA to yourself, your boss, and your customers? If so, carry on....

 

[mattador78]

This isn't on our AS9100 lines we do CAR on everything there at the moment as we move towards accreditation, what we do just on our commercial lines is have an internal use only incident report filled out. Our production manager logs these and if an incident is frequent we then escalate the issue filling out CARs and examine the root cause. Obviously these are similar to CARs but we use them for in principle isolated incidents if its repeated its not isolated so therefore we have determined a need for action

 

[Eredhel]

I can imagine if an organization required every NC to have a corrective action you would see a significant drop in NCs . Well, documented NCs .

 

[AndyN]

This is one of those areas of the standard that the CB process has badly influenced. The idea that NCs NEED CA is bizarre, instead of adding the step of "analysis" and looking for trends etc.

 

[Coury Ferguson]

"Example:
Person A does not fully record the job number correctly on card, then a week later person B does the same thing. This really is human mistakes and yes, there are ways to remove the humans from the activity but that really is not desired and the incorrect information is typically caught at the entry point. We want to correct this to reduce entry time."

Based upon your example, I would guess that there is an underlying issue. Could it be that maybe the organization doesn't allow the time before end of shift to complete their paperwork? Could it be, that the person or persons making these mistakes is not properly trained? Could it be that Management does not hold the people accountable for their actions? Their are so many scenarios for this type of mistake.

I would suggest, even though you may consider a formalized documented procedure/process, that you stay away from that. I am not saying not to document corrective actions. I am saying document each one via a log (ones that only need correction) or an "official" form based upon needing RCA when necessary. Many times, even though you have issued a formal CA requiring RCA the issue sometimes get down to the response time and missing the dates (late). Which would open your organization to a finding based upon an ineffective CA System and escalation process.

This is just my opinion on this.

 

[Michael_M]

When I used the job cards as my example, a true corrective action would remove the job cards as a means of recording time and go with something a bit more robust. However, this is not going to happen no matter how many 'mistakes' happen. The specific process:

1: Grab a blank job card first thing in the morning. and fill out the top portion (name, date, shift, etc.)
2: At start time, record the start time, fill in job number, step number, good qty, scrap parts, machine number, and end time.
....2a if running multiple machines, fill this out for each machine run and times
3: At the end of the day, record the stop time and put the card in a box.
4: Card is then manually entered by a human into our system.

Where the issues come up is things like recording good qty in the scrap section or leaving specific areas blank or the person who is entering the cards has no knowledge of machining practices so does not understand that a specific part cannot have 300 made in a single shift (this shows up during a report that shows efficiency).

I want to make sure I think of employees as human and can make human mistakes. One of the things that I don't want is a 'failure' of the corrective action system because the same basic types of mistakes keep happening.

Like I said, the fix is beyond what I am allowed to do so I have to work within the system I am given.