Corrective Actions identifed as Preventive Actions

O

omartinez

#1
Guys ,
I need a little of your help , I have an AS9100 audit last week and the auditor found an issue with during the process.
I explain him that we already have identify the issue and we create a Preventive Actions in our internal sistem .
He arguge that this was not a Preventive action it was a Corrective action so he wrote a fining :

The organization shall determine action to eliminate the causes of potential nonconformities in order to prevent their occurrence.
Nonconformance: The organization, in some situations, identified nonconforming processes as Preventive Actions.

12 Objective Evidence:
The site identified a Daily Machine Check List that was not being filled out daily as preventive action.
The site identified that a Traveler Sheet did not include the process procedure used in an Inspection operations

In both cases the processes were either not followed or not clearly/correctly identified, which would be considered a non-fulfillment of a requirement and should have been identified as nonconforming and addressed through the corrective action process.


He strongly say , that training as corrective action was not aceptable , due our company and staff is not knew and they should know what the differences between corrective and preventive.

Have you had any similar fining ? How do you answerer you findings ?

Thank you !
 
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Mikishots

Trusted Information Resource
#2
Guys ,
I need a little of your help , I have an AS9100 audit last week and the auditor found an issue with during the process.
I explain him that we already have identify the issue and we create a Preventive Actions in our internal sistem .
He arguge that this was not a Preventive action it was a Corrective action so he wrote a fining :

The organization shall determine action to eliminate the causes of potential nonconformities in order to prevent their occurrence.
Nonconformance: The organization, in some situations, identified nonconforming processes as Preventive Actions.

12 Objective Evidence:
The site identified a Daily Machine Check List that was not being filled out daily as preventive action.
The site identified that a Traveler Sheet did not include the process procedure used in an Inspection operations

In both cases the processes were either not followed or not clearly/correctly identified, which would be considered a non-fulfillment of a requirement and should have been identified as nonconforming and addressed through the corrective action process.


He strongly say , that training as corrective action was not aceptable , due our company and staff is not knew and they should know what the differences between corrective and preventive.

Have you had any similar fining ? How do you answerer you findings ?

Thank you !
Because the non-conformances have occurred, they clearly fall within the realm of corrective action. The task is to identify the root cause of the non-conformance and then address it directly, thus preventing future occurrences.

Training is a containment activity (or more specifically, lack of training is not considered to be an acceptable root cause).
 
O

omartinez

#3
Because the non-conformances have occurred, they clearly fall within the realm of corrective action. The task is to identify the root cause of the non-conformance and then address it directly, thus preventing future occurrences.

Training is a containment activity (or more specifically, lack of training is not considered to be an acceptable root cause).
__________________

Thank you Sr.....

lack of training was the real causes , dont know why the auditor wont acept that.
 
#4
Because the non-conformances have occurred, they clearly fall within the realm of corrective action. The task is to identify the root cause of the non-conformance and then address it directly, thus preventing future occurrences.

Training is a containment activity (or more specifically, lack of training is not considered to be an acceptable root cause).
I respectfully disagree. Lack of understanding can be a legitimate root cause.
 

Mikishots

Trusted Information Resource
#5
I respectfully disagree. Lack of understanding can be a legitimate root cause.
Sure. But that's not what I said.

But you can easily identify a level deeper - there must be a reason why the staff don't understand. Without addressing this root cause, there's no reason to expect that it won't happen again.
 
#6
Thank you Sr.....

lack of training was the real causes , dont know why the auditor wont acept that.
Why was there a lack of training ?
When you have an answer to this, we can see if we have to ask any more questions to get to the root cause.
We need root cause, not the real cause., so that when that gets addressed, such a NC situation no further occurs.
If lack of training is the root cause, training may be provided. However the competency assessment and gap analysis and actions to fill this gap prior to activity may never happen. A repeat NC can come up sooner than later.
 
O

omartinez

#7
So lack of training is not root cause but is part of the root cause , so going deeper the lack of training is because there is not a program training in those items , but this will fall into a Program Training / Lack of training issues
 
T

TShepherd

#8
Why was there a lack of training ?
When you have an answer to this, we can see if we have to ask any more questions to get to the root cause.
We need root cause, not the real cause., so that when that gets addressed, such a NC situation no further occurs.
If lack of training is the root cause, training may be provided. However the competency assessment and gap analysis and actions to fill this gap prior to activity may never happen. A repeat NC can come up sooner than later.
I agree with Somashekar completly and in addition this may be helpful to you.

Preventative Action - sometimes known as Error Proofing - means "This non-conformance can never happen again - ever" - most times through design of the product or process which eliminates the potential for a non-conformance.

Detection - also known as Mistake Proofing - means "this non- conformance will be detected before moving to the next step in the process" - However, at least 1 non-conformance will be created and there is still potential for that getting through the system.

A check list does not even rise the level of Mistake Proofing.

Operator Error or Operator Training cannot be used as a root cause or listed as Preventative Action because the root cause has not been determined yet and the last cause (Root Cause)has not yet been listed yet

If you rethink the Problem Statement from this standpont you might come up with something like this...

The operator failed to Bla, Bla, Bla or The operator did this XXXX

And if the answer to either of these two questions is "Lack of Training"
it becomes a systemic issue that must be resolved.

Some companies resolve this by requiring that operators be licenced to a specific job and that this licence is posted at the job when they are operating the job - some even tie pay incentives to the number of jobs that an operator has a licence to run.

Keep in mind, that even this does not rise to the level of Mistake or Error Proofing and still well within the Detection Arena - your issue with the Audit may be nothing more than a definition misunderstanding or Perspective misunderstanding.

Using this type of engineering thought process and a well written 3L5Y (Three Legged Five Why) may be helpful to you in your responses.

Good Luck

Tom:2cents:
 
#9
So lack of training is not root cause but is part of the root cause , so going deeper the lack of training is because there is not a program training in those items , but this will fall into a Program Training / Lack of training issues
Let it fall ...
Then question it and address that process.
Check if it ends there or leads you to an other process where the root (real) cause is present
 
P

PaulJSmith

#10
So lack of training is not root cause but is part of the root cause , so going deeper the lack of training is because there is not a program training in those items , but this will fall into a Program Training / Lack of training issues
It may very well. However, the point everyone is trying to make is that there is a deeper reason that the training failed; it may be your training process, or your personnel assessment process, or ...
Ask "Why" the training failed.

A fair percentage of the quality community (including auditors) will not accept "training" as a resolution to most Non-Cons. Once you dig deeper, you'll see why that is.
 
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