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How to do a Root Cause Failure Analysis

peter_traina

Starting to get Involved
#31
Hey Monica!!

I have the EXACT SAME Problem as you... right down to the original Auditor not being able to come and getting a "newbie" who doesn't understand our business!!
Anyway, it looks like, from reading the entire thread, that "Big Jim" sent you a link or something ( ANAB's "Heads Up" 137)?? I don't know what this is but, if you've found your solution, than you've probably found mine as well... Do you mind sharing?? I'm kinda out of ideas on how to make this Auditor happy. She just sent my whole plan back to me and stated "No Root Cause"! Well, whats the root cause for, "I forgot!"
Anyway, anything you could share would be greatly appreciated! Thanks in advance!
Pete:)
 
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Big Jim

Super Moderator
#32
Hey Monica!!

I have the EXACT SAME Problem as you... right down to the original Auditor not being able to come and getting a "newbie" who doesn't understand our business!!
Anyway, it looks like, from reading the entire thread, that "Big Jim" sent you a link or something ( ANAB's "Heads Up" 137)?? I don't know what this is but, if you've found your solution, than you've probably found mine as well... Do you mind sharing?? I'm kinda out of ideas on how to make this Auditor happy. She just sent my whole plan back to me and stated "No Root Cause"! Well, whats the root cause for, "I forgot!"
Anyway, anything you could share would be greatly appreciated! Thanks in advance!
Pete:)
Hi Peter,

Welcome to the Cove.

The ANAB "Heads Up 137" can be found on the ANAB web site. If you don't have it yet, I recommend it.

Let me try to walk through some of what you need to understand.

A proper response to an audit nonconformance (and good form for any corrective action) has three main elements, Correction, Root Cause, and Corrective Action.

Many people tangle Correction and Corrective Action so lets start with definitions. From ISO 9000, the definition of Correction is action taken to overcome a nonconformance. Don't get tangled by the fact that the word action is involved with the definition. ISO 9000 defines Corrective Action as the action taken to overcome the CAUSE of a nonconformance. Did you get that? Correction to overcome the nonconformance, and Corrective Action to overcome the CAUSE of the nonconformance.

Often, the term "containment" is used for Correction. It is the immediate action you take to resolve the nonconformance.

Once containment is out of the way, effort needs to be made to find out why it happened. Specifically, to find the root cause or final cause. There may be many contributing causes along the way, but if you don't dig the root out, it will grow back, just like a dandelion in your lawn. The most common method (usually very effective and reasonably easy to do) is known as "5 why". It is based on the concept that if you ask why enough times you will eventually get the the bottom (root) of the problem. 5 is often the magic number, but depending on the situation, it may take more or less. As long as you can reasonably still ask "why", you probably are not yet at the root.

Only after the root cause is determined, can you formulate a plan to overcome the root cause.

Some simple logic here to obey. The Correction and Corrective Action can never be the same. Correction is what you do to overcome the problem. Corrective Action is what you do to overcome the CAUSE of a problem.

The root cause can never be the same as the original problem statement. That was just the symptom, and not even a contributing cause.

Objective evidence is needed for both the Correction and the Corrective Action.

Let's try an example. This is only an example, and may not fit any particular real world experience.

A customer rejected a part because it was not manufactured to print. One of the dimensions was off.

The Correction may be to build another part, or replace it with one from stock.

Upon investigation, you determine that the part was built to the wrong print. It was made to Rev B and should have been built to Rev E. The machinist says that the drawing was missing from the traveler package, but he still had a drawing in his tool box from when he made what he thought was the same part two years ago. Further, you find that the traveler did not reference the drawing Rev as expected. On further investigation, you find the work instruction on how to create a traveler does not address drawing revision control.

This example may actually have more than one root cause, and that is OK. The most glaring one (to me) is the lack of proper instruction on creating the traveler.

Another trail to follow would be why did the machinist have an old drawing. What happened to document control to have permitted this. Perhaps there is a training issue here.

To summarize:

Correction: Replace the part.

Objective evidence: Show that a replacement part was shipped.

Root Cause 1: Inadequate work instruction on how to create a traveler and traveler package.

Corrective Action 1: Re-write the work instruction for traveler generation.

Objective evidence: The revised work instruction.

Root Cause 2: Machinist had inadequate training on document control.

Corrective Action 2: The machinist was trained.

Objective evidence: Training record showing the machinist received training.

Follow-up: Both Corrective Actions will be re-visited at the next internal audit.

I hope this helps.
 

Moncia

Quite Involved in Discussions
#33
Hey Monica!!

I have the EXACT SAME Problem as you... right down to the original Auditor not being able to come and getting a "newbie" who doesn't understand our business!!
Anyway, it looks like, from reading the entire thread, that "Big Jim" sent you a link or something ( ANAB's "Heads Up" 137)?? I don't know what this is but, if you've found your solution, than you've probably found mine as well... Do you mind sharing?? I'm kinda out of ideas on how to make this Auditor happy. She just sent my whole plan back to me and stated "No Root Cause"! Well, whats the root cause for, "I forgot!"
Anyway, anything you could share would be greatly appreciated! Thanks in advance!
Pete:)

well, we havent sent ours yet
but I will help you any way I can
I am new to this whole QC/ISO field
 

Moncia

Quite Involved in Discussions
#34
OK
so for the updates
we just finished with our root causes
we are working on objective evidence of implementation - like training record
poster on the production floor, etc

when we send it all out to the registrar, what should we send.
is there any format type as to reply to the audit findings???
what one send with corrective actions forms back to the auditor???

Thanks again all for your help
Monika
 

Moncia

Quite Involved in Discussions
#35
Hi my fellow quality ferries

We just went through an audit and since we had to reschedule, we got different auditor. was not pretty. the guy did not understand the scope of our business.
so anyways, we got 4 minor ones- little babies easy to fix, but having trouble writing a root cause

any one is really good at those in here,
I need a help.
thanks
Made a stupid mistake
and nobody corrected me:lmao:

I do apologize my "Quality Fairies" :magic:

Had still too much of that - :beerdive:
 

ScottK

Not out of the crisis
Staff member
Super Moderator
#36
Monika -

I have worked with a couple consultants here in New Jersey who have excellent training programs on Root Cause Analysis. I can put you in touch with them. If your company has a few dollars to spend it would be worth every cent to have a few people attend a good Root Cause Analysis training class.
 

Moncia

Quite Involved in Discussions
#37
Monika -

I have worked with a couple consultants here in New Jersey who have excellent training programs on Root Cause Analysis. I can put you in touch with them. If your company has a few dollars to spend it would be worth every cent to have a few people attend a good Root Cause Analysis training class.
that's the problem
I tried convince my boss at the meeting yesterday that we need a training
but he wont do it

there simply is no training in this place -ever
 

peter_traina

Starting to get Involved
#38
Hi Peter,

Welcome to the Cove.

The ANAB "Heads Up 137" can be found on the ANAB web site. If you don't have it yet, I recommend it.

Let me try to walk through some of what you need to understand.

A proper response to an audit nonconformance (and good form for any corrective action) has three main elements, Correction, Root Cause, and Corrective Action.

Many people tangle Correction and Corrective Action so lets start with definitions. From ISO 9000, the definition of Correction is action taken to overcome a nonconformance. Don't get tangled by the fact that the word action is involved with the definition. ISO 9000 defines Corrective Action as the action taken to overcome the CAUSE of a nonconformance. Did you get that? Correction to overcome the nonconformance, and Corrective Action to overcome the CAUSE of the nonconformance.

Often, the term "containment" is used for Correction. It is the immediate action you take to resolve the nonconformance.

Once containment is out of the way, effort needs to be made to find out why it happened. Specifically, to find the root cause or final cause. There may be many contributing causes along the way, but if you don't dig the root out, it will grow back, just like a dandelion in your lawn. The most common method (usually very effective and reasonably easy to do) is known as "5 why". It is based on the concept that if you ask why enough times you will eventually get the the bottom (root) of the problem. 5 is often the magic number, but depending on the situation, it may take more or less. As long as you can reasonably still ask "why", you probably are not yet at the root.

Only after the root cause is determined, can you formulate a plan to overcome the root cause.

Some simple logic here to obey. The Correction and Corrective Action can never be the same. Correction is what you do to overcome the problem. Corrective Action is what you do to overcome the CAUSE of a problem.

The root cause can never be the same as the original problem statement. That was just the symptom, and not even a contributing cause.

Objective evidence is needed for both the Correction and the Corrective Action.

Let's try an example. This is only an example, and may not fit any particular real world experience.

A customer rejected a part because it was not manufactured to print. One of the dimensions was off.

The Correction may be to build another part, or replace it with one from stock.

Upon investigation, you determine that the part was built to the wrong print. It was made to Rev B and should have been built to Rev E. The machinist says that the drawing was missing from the traveler package, but he still had a drawing in his tool box from when he made what he thought was the same part two years ago. Further, you find that the traveler did not reference the drawing Rev as expected. On further investigation, you find the work instruction on how to create a traveler does not address drawing revision control.

This example may actually have more than one root cause, and that is OK. The most glaring one (to me) is the lack of proper instruction on creating the traveler.

Another trail to follow would be why did the machinist have an old drawing. What happened to document control to have permitted this. Perhaps there is a training issue here.

To summarize:

Correction: Replace the part.

Objective evidence: Show that a replacement part was shipped.

Root Cause 1: Inadequate work instruction on how to create a traveler and traveler package.

Corrective Action 1: Re-write the work instruction for traveler generation.

Objective evidence: The revised work instruction.

Root Cause 2: Machinist had inadequate training on document control.

Corrective Action 2: The machinist was trained.

Objective evidence: Training record showing the machinist received training.

Follow-up: Both Corrective Actions will be re-visited at the next internal audit.

I hope this helps.

Hi Big Jim!

First, let me thank you publicly! Sounds as if you've literally written the book on this stuff!
Secondly, I should have explained myself more clearly when I started this ...sorry.
I am 25 yrs. into this business... know all about 5 Whys, 8D, Fishbone diagrams, Fault Tree, pareto, PFMEA etc., etc.
So, let me re-explain my question/problem...
The Auditor has given us minor nc's for documentation issues only... for example:


Description
Clause/
Annex
Root Cause
Planned Actions
Due Date
Responsibility
NON-CONFORMITY
The process to ensure that devices are correctly classified is not effective.
REQUIREMENT [Annex IX, Section II]
Application of the classification rules shall be governed by the intended purpose of the devices.

If the device is intended to be used in combination with another device, the classification rules shall apply separately to each of the devices. Accessories are classified in their own right separately from the device with which they are used.
OBJECTIVE EVIDENCE
The Generator and associated accessories were not classified in their own right.
Annex IX, Section II
Omission:
.
Review and revise Essential Require :mg:ments (ER) documents for our products currently being sold in the EU and those pending approval for sale in the EU to reflect product and accessory classification (ER-1004; ER-1005; ER-1006; ER-1007; ER-1008).
Review and revise SOP-1010 titled ‘Essential Requirements and Technical Documentation’ procedure to include the requirements of Annex IX, Section II.
Review and revise SOP-1019 titled “Procedure for Compliance with the Regulatory Aspects of the MDD” to include the requirements of Annex IX, Section II.
Establish training record for appropriate personnel for document changes.
9/18/11
Regulatory/Quality
NON-CONFORMITY
The solutions adopted to fulfill the essential requirements are incomplete.
2.1 REQUIREMENT [Annex I, ER 4]
ER 4 states that the characteristics and performances are not affected during the lifetime of the device as indicated by the manufacturer. The product lifetime must be declared along with the rationale for its calculation.
OBJECTIVE EVIDENCE
The product lifetime was not defined, nor was any supporting documentation provided.

Article 3 Annex I



2.1 Contact contract manufacturer, and determine lifetime of RF Generator based on components/materials within the generator. Document lifetime and rationale within ‘product specification’ documents and reference lifetime in applicable ‘essential requirements’ (ER) documents.

9/18/11
Regulatory/Quality

2.2 REQUIREMENT [Annex I, ER 12.1a]
For devices which incorporate software…, the software must be validated according to the state of the art taking into account the principles of development lifecycle, risk management, validation and verification.
OBJECTIVE EVIDENCE
The manufacturer has not referenced any standards or procedures relating to software life-cycle processes.
Article 3 Annex I
Omission:
Did not reference an appropriate state of the art standard relating to software life-cycle processes established during the design process for the RF Generator.
2.2 Review standard ISO 62304:2006. Determine if existing RF Generator documentation requires additional action based on gap analysis. Review and revise as required the product specification PS-1002 titled ‘RF Generator Software Requirement’ specification to indicate reference to ISO 62304. Add reference that includes ISO 62304 to applicable ‘essential requirements’ (ER) documents. Review and revise existing document DOP-1024 titled ‘Software Development Life Cycle’ to indicate requirements of ISO 62304.
Establish training record for appropriate personnel as required.
9/18/11
Regulatory/Quality
The clinical data did not fully meet the requirements of Annex X in the following aspects:
NONCONFORMITY
The clinical evaluation process is inadequate
REQUIREMENT [Annex X, Section 1.1] ‘clinical evaluation’, where appropriate taking account of any relevant harmonized standards, must follow a defined and methodologically sound procedure based on:
Either a critical evaluation of the relevant scientific literature currently available relating to the safety, performance, design characteristics and intended purpose of the device, where: -there is demonstration of equivalence of the device to the device to which the data relates, and – the data adequately demonstrate compliance with the relevant essential requirements…
OBJECTIVE EVIDENCE: The manufacturer has not provided evidence to demonstrate equivalence of the device to the device to which the data relates.
Annex I, 6a Annex X
Omission: Comparative device information was not summarized within established clinical evaluations performed.
Clinical Evaluation has been performed and documented most recently through nContact documents EXD-1171 and EXD-1175. Action is to add a table to one of these evaluations summarizing the design comparison information between nContact devices and competitor’s devices.
9/20/11
Regulatory/Quality

NONCONFORMITY
The user documentation does not fully support the claimed compliance with EN 60601-1-2
REQUIREMENT [EN 60601-1-2:2001 (clause 6.8.3.201)]
For all EQUIPMENT and SYSTEMS, the ACCOMPANYING DOCUMENTS shall include the following information: Table 201, Table 202, the applicable tables 203/205 or 204/206.
OBJECTIVE EVIDENCE
The accompanying documents did not include the tables of guidance and manufacturer’s declaration regarding electromagnetic emissions and immunity.

Annex I, ER2
Omission:
Some of the 60601-1-2 requirements for statements of electromagnetic emissions and immunity were incomplete in the RF Generator’s Operator’s Manual.
Review the requirements of EN60601-1-2:2001, Clause 6.8.3.201. Revise RF Generator Operator’s Manual LBL-1095 as required to include table of guidance and statements regarding electromagnetic emissions and immunity.

9/20/11
R&D and Quality

NONCONFORMITY
The labeling requirements have not been fully met
5.1 REQUIREMENT [Annex I, ER 13.3(a)] The device label must bear the name and address of the manufacturer.
OBJECTIVE EVIDENCE
The RF Generator Label does not include the address of the manufacturer.

5.2 REQUIREMENT [Annex I, ER13.6(p)] The Instructions for Use must contain…(the) degree of accuracy claimed for devices with measuring function.
OBJECTIVE EVIDENCE
The RF Generator IFU does not include the degree of accuracy of the power.

Article 3
Annex I, ER 13
Omission:
A separate label with address was not applied directly to RF Generator.









Omission:
The degree of accuracy stated in the product definition was not included in the IFU.
5.1 Add a label to the RF Generator indicating the nContact address. Revise internal build documents as required to reflect new label.









5.2 Revise the RF Generator Operator’s Manual LBL-1095 to indicate the degree of accuracy of the power output.

9/20/11
Quality and Regulatory


So, this is my Corrective Action Plan...and as you can see, most of the "Root Causes" are "Omission", as in, I Missed It! What do they want me to say or do?? Root Cause... pay more attention?? or Make certain that I have read the latest Rev.? Not always reasonable for a very small company (<30, with all mfg. contracted)
 

peter_traina

Starting to get Involved
#39
Ok, sorry about that... I tried to copy over a table and it obviously didn't come over...
Monika, if you look at my attachment, it has the Format you are looking for...I think.
Easy, Pete

P.S. Can someone / anyone with some expertise, please review my Root Causes and comment? It would be most helpful...thank you!!
 

Attachments

Moncia

Quite Involved in Discussions
#40
Ok, sorry about that... I tried to copy over a table and it obviously didn't come over...
Monika, if you look at my attachment, it has the Format you are looking for...I think.
Easy, Pete

P.S. Can someone / anyone with some expertise, please review my Root Causes and comment? It would be most helpful...thank you!!
Hi Peter

I am looking at the Corrective action plan you were so kind to show us

One question, - I will sound super stupid here, but what is omission??

isnt the description the same??


again , I am new to it, and even though we got registered 3 years ago, we never got any NC so I never had to deal with it before

In my understanding was- we get NC
next step is - containment - if there is any - to stop the bleeding
then it is corrective action that includes - root cause and corrective action
plan

Never heard of omission????
 
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