AS9100 Rev D Clause 10.2 - Is Cause always required?

Big Jim

Admin
Howste,

I believe the weasel words you are looking for is right in front of you.

10.2.1b "evaluate the need for action . . . "

If you determine there is no need, why would you believe you need to go further?

It may help to check the ISO 9000:2015 definitions for correction and corrective actions. If memory serves me correctly, both definitions use the term "action".
 

Mike S.

Happy to be Alive
Trusted Information Resource
As few others have indicated, I think the intent was never to determine the cause of every minor NC, i.e. an isolated incident resulting in a bent 5 cent washer, etc.

There are still a lot of “weasel words” indicating intent, IMO (bolding emphasis mine):


10.2.1
a. react to the nonconformity and, as applicable:
1. take action to control and correct it;

(You see no need to control or correct it, so it is not applicable.)

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

(You evaluated and you see no need for action.)


c. implement any action needed;

(You evaluated and you see no need for action.)




e. update risks and opportunities determined during planning, if necessary;

(Deemed not necessary.)

f. make changes to the quality management system, if necessary;

(Deemed not necessary.)


Corrective actions shall be appropriate to the effects of the nonconformities encountered.

(This is an important one. What is “appropriate” RCCA activity for an isolated incident resulting in a bent 5 cent washer? You say – wisely – none.)
 

howste

Thaumaturge
Trusted Information Resource
I believe the weasel words you are looking for is right in front of you.

10.2.1b "evaluate the need for action . . . "

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

(You evaluated and you see no need for action.)

Thanks for the inputs. We tried that route already. Their argument is that it says to evaluate the need for action by determining the causes. The way it's worded, the evaluation itself includes cause determination. They are not asking for corrective action on every nonconformity, they are asking for cause determination on every nonconformity. :frust:
 

Mike S.

Happy to be Alive
Trusted Information Resource
Wow. Okay. :rolleyes:

"Cause: Investigated and unable to be determined within reasonable resource constraints."

That is a decision "appropriate to the effects of the nonconformities encountered."

And yeah, I woulda asked for a formal interpretation, too.
 

howste

Thaumaturge
Trusted Information Resource
Are they requiring that each cause be documented?

They haven't said that, and the standard doesn't explicitly require each cause to be documented. We hope to never have to get to that point. But if we do end up going down that path and they ask us to tell them causes and we say "uhhhhh..." it wouldn't go well. :eek:
 

Marc

Fully vaccinated are you?
Leader
I come back to saying "Yes, we thought about and discussed the issue, the cause and determined it was not of significance" or words to that effect.

It's been quite a few years since I worked with what I think at the time was called DCAS. They had their own office and a permanent staff. There were a couple of prickly ones, but all in all they were pretty good and sometimes even quite helpful. I don't remember any that were terrible except for, now that I think back, one we reported and eventually got removed from the facility. I can't remember his name but I remember he was a nightmare and it had to do with a small rubber gasket made for replacements for an aircraft from the early 1950's where the original manufacturer had long gone out of business so their "proprietary formula" was lost. His gripe was that the company used a rubber that didn't meet the print which called out the original manufacturer's "special sauce". Since the original manufacturer was out of business it was an impossible situation.

Sorry to hear you're going through this.
 

Eredhel

Quality Manager
I'm still looking forward to an official response but I think Mike nailed it. The standard doesn't require what the customer is demanding.
 

Marc

Fully vaccinated are you?
Leader
I think you're right. Too many times a person reads too much into a phrase in a standard. Pissing matches over interpretations has long been a problem with many standards.
 

Big Jim

Admin
This is a can you most certainly need to kick upstairs and keep kicking upstairs until you find someone that is reasonable in their interpretation.

Sometimes it is not easy.

You bring to mind an incident that occurred during the 9001:2000 and 9001:2008 transition where the CB auditor rejected the internal audit because the forms indicated it was made to the 2000 version and that the standard said that the internal audit needed to be made against the requirements standard. The auditor claimed that since it was done to 2000 it didn't count for 2008. Both the auditor and the CB needed to be reminded that TC-176 had stated that there were no new requirements with the 2008 version.
 
Top Bottom