How Can I Respond to this SCAR (Supplier Corrective Action Request)?

NikkiQSM

Quite Involved in Discussions
#1
Background -

A product was sent out containing an ingredient that was not specified in the specification. The R&D technician did not properly update the file, therefore, leaving the old formulation which was used to make a lot of material.

Sales asked the R&D Tech to make the change to the file orginally, and did not complete a Specification Review Document. This was all done through email instead. If a Spec Rev Doc would have been completed, the R&D Technicians work would have been reviewed and the error would have been noticed.

The Specification for this formulation was also in the file. The QC Technicians and QC Managers are suppose to review this document when the product is running and immediately prior to shipment. It was not reviewed closely enough. If so, they would have seen that the wrong ingredient was used and stopped the shipment.

Now I have a SCAR to complete. I am at a loss of what to document because the customer has listed the following:

Root Causes to be avoided
The following are commonly identified as root causes, but are only symptoms to the true root cause and should be avoided in the SCAR response:
? Human error
? Procedures not followed
? Equipment malfunction
? Improper performance
? Method not validated
? Multiple batches in process at the same time
? Equipment with expired calibration
? Out of trend point



Corrective Actions to be avoided
The following are commonly identified as Corrective Actions to attack the root cause, but are only simple spot fixes and should be avoided in the SCAR response:
? Train a non-trained operator
? Reject and destroy a failing product
? Rework nonconforming material
? Repair broken piece of equipment
? Properly connect alarm to machine
? “Use-as-is” nonconforming product



A lot of bad things happened in this situation - but how am I to respond? I will of course want to retrain everyone.

Thoughts?
 
Elsmar Forum Sponsor

Golfman25

Trusted Information Resource
#2
Re: How Can I Respond to this SCAR?

Seems to me that a procedure wasn't followed. So while they don't want that listed as the root cause, you need to go further and figure out why it wasn't followed? My guess is either they didn't know or forgot because it isn't an everyday occurrence. Good luck.
 
S

Sean Kelley

#3
Re: How Can I Respond to this SCAR?

Looks like they want you to dig deeper than a procedure not being followed. How can you error proof out that a different procedure won't have the same type of problem at some point in the future. This would be a good 5 why with a team to determine the real root cause and action to solve it.
 
Q

qualityfox

#4
Re: How Can I Respond to this SCAR?

From your description of the CAR, your system was ineffective in four separate instances.
-Sales did not submit the proper paperwork
-R&D did not insist on properly completed paperwork and did not route for review
-QC did not catch the error when the product was running
-QC did not catch the error prior to shipment.
Another area you didn't mention is operator responsibility.
IMHO, you have a systemic problem. People throughout your organization have become lax in following procedure. Your Corrective Action needs to address this systemic problem and simply retraining may not be the answer. Good Luck!
 
#5
All good responses.

May I add that your customer's response points out some typical root cause responses are not really root cause, just causes along the way.

It also points out that some common corrective actions are inappropriate since they probably were part of the correction/containment. Most importantly, they don't speak to the cause.

A little explanation may help. ISO 9000 defines correction as the action taken to overcome a nonconformance. It needs to include containment. It is unfortunate that the word action is in the definition, as it tends to muddy things up, but follow along and it should get cleared up.

ISO 9000 defines corrective action as the action taken to overcome the CAUSE of the nonconformance. It should be clear then that the corrective action needs to speak to the root cause. It is NOT a continuation of the correction!
 
Q

qualityfox

#6
This will also give you a great opportunity to communicate to all employees the effectiveness of your QMS (ISO 9001 clause 5.5.3) and the importance of their activities and contribution to quality objectives (6.2.2d).
 

NikkiQSM

Quite Involved in Discussions
#7
Re: How Can I Respond to this SCAR?

-R&D did not insist on properly completed paperwork and did not route for review
Here is why the need for the paperwork was not pushed. The R&D Technician IMHO should not have been doing the update in the first place. She was only with our company with a total of four months, and I don't believe her manager properly trained her.

Secondly, the Spec Rev Doc was implemented only a short time before this, and the process of who reviews it was still being discussed. We were basically working with it and trying to hammer out the bugs that we came across.

I agree this is a systemic problem, and I also agree that the items the customer listed to be avoided are not all appropriate.

I think a HUGE communication break-down started this snow-ball. While top management was aware of the Spec Rev Doc, I dont believe it was properly filtered down to the other employees.
 
P

PaulJSmith

#8
I will of course want to retrain everyone.
Yes. But, before you even consider that, you need to address the multiple failures in the system. Otherwise, you'll just end up retraining people on a system that didn't work as intended.

I don't think this will be an easy or short response, as already noted by others. You might consider several teams, one for each area of failure. This may help alleviate some of the burden, and make it feel like less of a daunting task.
 

NikkiQSM

Quite Involved in Discussions
#9
What is everyone thoughts on this? :::

Complaint: Product contained an unspecified ingredient.
Investigation Details:
? QMF 10 – Specification Review Document – Began being used April 2014.
? Product’s file indicates that the formula was updated in Nov 2014.
[FONT=&quot]o [/FONT]Formulation was only partially updated, not completely.
[FONT=&quot]o [/FONT]Employee had only been with the company for four months.
? Why was the formula not updated correctly?
? Process was not clearly communicated to all employees / poor training
? Process was not procedularized
? No documentation was provided to R&D for the change, therefore, her work was not reviewed – which could have caught this error.
[FONT=&quot]o [/FONT]Why? – Sales requested this change all through email.
? Customer specification was not thoroughly reviewed by Quality Control
[FONT=&quot]o [/FONT]Why? – Rushing
[FONT=&quot]o [/FONT]Why? – There is nothing in place to force the review of the specification, there is no documentation that a review of the specification was actually done.

Corrective Actions:
? Procedularize the Specification Review Process and retrain all employees in R&D, Quality Control and Sales.
? Process Engineer could review the customer specification during the process / formulation review phase. This is done prior to the job being produced.
[FONT=&quot]o [/FONT]Side Note: This is actually how the issue was discovered before a complaint was given to Sales by the customer.
? Update the QMF 29 – Quality Control Information Document – to include a sign-off section of who reviewed the customer specification. This will remind the Technician and Managers to review the specification.
 
Q

qualityfox

#10
Re: How Can I Respond to this SCAR?

I think a HUGE communication break-down started this snow-ball. While top management was aware of the Spec Rev Doc, I dont believe it was properly filtered down to the other employees.

The communication breakdown may be your root cause. Writing a procedure, retraining on the process and requiring signatures are all fixing the current instance of the root cause, thus I would call all of this part of the correction.

So how are you going to make sure that the next time there is a procedural change it gets communicated to all affected employees? That is your corrective action.
 
Thread starter Similar threads Forum Replies Date
M How to respond to 483 validation finding we disagree with? 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 33
J How to assign a Leader to respond to Corrective Actions Nonconformance and Corrective Action 7
Q What to do when a Notified Body doesn't respond? ASQ, ANAB, UKAS, IAF, IRCA, Exemplar Global and Related Organizations 8
B How would you respond in a work setting? Career and Occupation Discussions 7
J What is the time limit for an auditor to respond to NCR's and submit audit report? AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 7
K Customer NCR - How to respond to a non-applicable NCR? Nonconformance and Corrective Action 7
ScottK How NOT to respond to Customer Inquiries... Funny Stuff - Jokes and Humour 3
E How to respond to a Regulator regarding missed corrective action timelines Pharmaceuticals (21 CFR Part 210, 21 CFR Part 211 and related Regulations) 6
E How to Respond to a US FDA untitled letter - Form 483 or Warning Letter Other US Medical Device Regulations 2
D Supplier will not respond to Corrective Action Requests Nonconformance and Corrective Action 12
M Corrective Action - No action necessary - How to respond Nonconformance and Corrective Action 7
L Number of days to respond to corrective action - Standard response time frame? Nonconformance and Corrective Action 10
J 8-D for Rare Occurence - How do I respond? Nonconformance and Corrective Action 12
Marc Audit Observations - Is there a requirement to Respond to Observations? Registrars and Notified Bodies 14
H SCAR to Vendor or Manufacturer? Supplier Quality Assurance and other Supplier Issues 6
D Question on Supplier Quality (SCAR) ISO 13485:2016 - Medical Device Quality Management Systems 6
J Customer Complaint & SCAR, false data Nonconformance and Corrective Action 14
M Multiple missed POs grounds for SCAR? ISO 13485:2016 - Medical Device Quality Management Systems 32
S SCAR (Supplier Corrective Action Request) Timeliness & Issuance Supplier Quality Assurance and other Supplier Issues 4
M Help with SCAR - Not all sub-assemblies had properly received a First Article Nonconformance and Corrective Action 2
K Suppliers not responding to Supplier Corrective Action Requests (SCAR) Supplier Quality Assurance and other Supplier Issues 17
Q Global SCAR Software System Recommendations Quality Assurance and Compliance Software Tools and Solutions 2
C Using SAP for SCAR (Supplier Corrective Action Reports) Quality Assurance and Compliance Software Tools and Solutions 2
J How I should format a SCAR Cover Letter? SQE asking for advice ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 12
D Multiple Discrepancies put on one SCAR Quality Manager and Management Related Issues 5
K Customer issues invalid SCAR and Chargeback every March Customer Complaints 6
T World Class Supplier Quality Alert System CAR/SCAR By Email Quality Assurance and Compliance Software Tools and Solutions 2
A Shall we raise SCAR/CAR for every defect as per our current procedure? Nonconformance and Corrective Action 4
C SCAR (Supplier Corrective Action Request) as part of NC/CAPA? Nonconformance and Corrective Action 3
R To SCAR or not to SCAR (Supplier Corrective Action Request) Supplier Quality Assurance and other Supplier Issues 7
S Supplier Corrective Action Request (SCAR) Ignored by Supplier ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 9
R To SCAR or not to SCAR? First Article with a new supplier fails Supplier Quality Assurance and other Supplier Issues 3
Q SCAR Process SCAR that works for Class III Medical Device Supplier Management Supplier Quality Assurance and other Supplier Issues 4
S Supplier Corrective Action Request (SCAR) vs. Corrective Action Request (CAR) Food Safety - ISO 22000, HACCP (21 CFR 120) 15
B Supplier Corrective Action Request (SCAR) - criteria Supplier Quality Assurance and other Supplier Issues 2
J When should Material RMA be escalated to a SCAR? Supplier Quality Assurance and other Supplier Issues 4
L SCAR (Supplier Corrective Acton Request) Responses - How much do you tell? Nonconformance and Corrective Action 8
D Lean SCAR Process and Form needed - ISO 13485 and FDA ISO 13485:2016 - Medical Device Quality Management Systems 8
ScottK As an ISO9001 auditor what would you say about this of this (open SCAR situation): ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 3
K SCAR (Supplier Corrective Action Request) Major and Minor Classification Nonconformance and Corrective Action 4
Q SCAR Form - Does anyone have an example of a Supplier Corrective Action form? Supplier Quality Assurance and other Supplier Issues 1
G SCAR (Supplier Corrective Action request) Charge Back Supplier Quality Assurance and other Supplier Issues 44
Q Supplier Controls and Quality System Requirements Misc. Quality Assurance and Business Systems Related Topics 0
L FSVP (Foreign Supplier Verification Program) for Finish Tobacco Importers? US Food and Drug Administration (FDA) 0
G MDR critical supplier audit checklist EU Medical Device Regulations 0
G MDR/UKCA Supplier Audits EU Medical Device Regulations 3
sonflowerinwales American supplier of faulty goods into the EU After Work and Weekend Discussion Topics 6
P Product label supplier, critical or non-critical vendor ISO 13485:2016 - Medical Device Quality Management Systems 6
R 5.6.1.2 Initial Supplier Evaluation—Critical Purchases Supplier Quality Assurance and other Supplier Issues 0
A Guidance on Supplier Qualification - Phase 1 pharma manufacturing Supplier Quality Assurance and other Supplier Issues 3

Similar threads

Top Bottom