NCR or CA? We're taking any issue we have and saying its a nonconformance

[kjoberk]

I looked through the NC and CA forum, but couldn't find anything about the exact question I have. A little background:

My company has been ISO certified for about 7 years. We are currently AS9110 certified.

During our ISO only stage (before my time at the company), any "nonconformance" was directly turned into a Corrective Action. It didn't matter what it was, it was automatically elevated to a CA. We went through the whole process...identify the issue, investigate and do a root cause analysis, develop a corrective action, implement and monitor/verify, then close the CA.

For our AS cert, we had to come up with an NCR form and follow our procedure (that admittedly, we had written but never used previous to AS).

We currently have two separate processes for our NCR and our CA.

Our (my boss's) issue and concern with the NCR is he doesn't fully understand how to separate out the two. It *feels* like when I'm doing NCR's, I'm doing a CA anyway. Our NCR form has a section for discrepancies or deviations, a section for findings/notes, and then a comments section. Which, to me, all feels very similar to a CA. Do the investigation, figure out what happened, find a solution. The only difference is that a CA will contain a root cause and a statistical analysis (if warranted on the statistical thing), but, I've written root causes in our NCRs too.

So I guess my question is, how do we make this system work for us? We're taking any issue we have an saying its a nonconformance. Some of them, depending on the severity of the issue or the risk of it continuing, get elevated instantly, while others seem kind of in limbo.

Does anyone have examples of what their criteria for an NCR vs a CA is? Or what I'm doing wrong?

I was thinking of suggesting that we use NCRs specifically for our repair/refurbishment side of our company (we are a helicopter maintenance company) and then CA's for everything else. I have no idea. I'm racking my brain....I want to give my boss something that will be more helpful than what we're currently doing.

 

[Bev D]

The fundamental premise you are missing is that not all non-conformances require or should have corrective action to prevent re-occurrence.

The 'NCR form' is intended to document and guide the control and disposition of the affected material. notably repair and rework actions. This is absolutely critical for flight safety.

Corrective action is typically taken on repeating or very severe problems. as the investigation is intended to be deep and effective in preventing re-occurrence of the cause.

this is why the two are typically kept separate.

Taking this much effort on every non-conformance is a noble thought. The caution is that too often the overwhelming number of CAs leads to shallow investigations that don't really get at the causal mechanism and don't prevent re-occurrence. Even the really important ones get shallow treatment when every NC is deemed to be CA worthy. Conversely, it can also lead to an 'audit trap' where the less important defects languish in the CA phase and you get a meaningless finding for lack of timely completion of our CAs...

 

[kjoberk]

The 'NCR form' is intended to document and guide the control and disposition of the affected material. notably repair and rework actions. This is absolutely critical for flight safety.

Corrective action is typically taken on repeating or very severe problems. as the investigation is intended to be deep and effective in preventing re-occurrence of the cause.

this is why the two are typically kept separate.

Taking this much effort on every non-conformance is a noble thought. The caution is that too often the overwhelming number of CAs leads to shallow investigations that don't really get at the causal mechanism and don't prevent re-occurrence. Even the really important ones get shallow treatment when every NC is deemed to be CA worthy. Conversely, it can also lead to an 'audit trap' where the less important defects languish in the CA phase and you get a meaningless finding for lack of timely completion of our CAs...

Let me give an example or two of what we do as far as NCRs/CAs go...

A customer we did some work for (4 years ago) found a fastener that was not installed correctly. Supervisor opened an NCR. I ended up doing some research and tracking down the aircraft, the work order, the job, who worked on it, and then we (myself and the technician) wrote up instructions for a fix to send to them (it was fairly simple, thankfully). My supervisor is recommending retraining the shop so this does not happen again.

Previously, this would have been elevated into a CA, and essentially the same things would have been done in a CA. Maybe a little bit more research and information gathering, but that's it.


An open CA that we currently have is based on a (unfounded) customer complaint. This particular person is truly a thorn in everyone's side. He has blamed our company for literally everything wrong with their aircraft, but has previously refused to pay for services rendered and has been asked to leave more than one other company. Supervisor opened up a CA to deal with the latest incident and, I believe, to make an end decision to either keep this customer or ask them to find somewhere else to go. But the actions as far as the CA goes would have been the exact same as if an NCR was opened.


Maybe my supervisor and I just aren't entirely too clear as to what can fall into an NCR, what needs to be elevated, and what can be just fixed then and there as a "one off" and dust our hands off.

All of what you said made complete sense to me, I'm just not sure how to revamp our current process to make sure it is a) beneficial to the company and employees, b) not do double duty with NCRs and CAs, c) not making us do more work than we absolutely need to do.

Is there maybe a matrix that people use that can point to which would be best to do? And since not all NCRs need to be CAs, do all CAs need to start off as NCRs?

 

[Sidney Vianna]

I'm just not sure how to revamp our current process

It is very simple. For each recorded NCR's have a determination done (by a team or otherwise) if a corrective action is necessary or not. You can even have a check box to that effect in the NCR form. For cases where a CA is NOT justified, the process stops at correction and doesn't move forward to root cause analysis and corrective action determination.

Each case will be different and a matrix would not be able to include all possible scenarios.

You have to filter spurious, trivial issues so you don't overwhelm the corrective action process, which has to be used with good judgement, pretty much what Bev mentioned.

 

[Golfman25]

Don't complicate it. It's a two step process. First you have a non-conformance -- or in normal people's terms "something's not right."

So in your case, you have a non-conformance -- a screw loose, so to speak. Or a customer complaint.

Step two is you decide what to do about it. A corrective action (or an 8D as some call it) is only a tool. It provides a roadmap to do a root cause analysis, etc. But some problems can just be fixed. No real need to go thru all of that -- as Nike says -- just do it.

The problem is that people see every problem as a nail, and thus every solution is a hammer. So you're bogged down in "corrective actions" for even stupid things. And the eye rolling begins.

How do you decide how to fix? That depends. Some companies use a dollar amount -- anything less than $500 just get's fixed. In your case, you may need more discretion -- I would focus on safety type issue. The more critical to flight, the more I would be inclined to use a root cause/corrective action process.

Now in the two cases identified, it sounds like you actually did a corrective action process for the screw issue -- investigate, root cause, corrective action, training, etc.

As for the customer complaint, sounds like he is the root cause. The fix is to call him and tell him to pound sand.

 

[normzone]

The tack I'm taking these days is if there is not going to be a change made to the process, then a corrective action is not appropriate.

I know that's a sticky wicket, and not a one size fits all approach. It also entails informally conducting the root cause analysis and looking for possible process improvements before making the decision whether or not to document all that as a CA.

But a trainer I worked with once asserted that if your CA did not result in a process change it was unlikely to be effective. While that's not ALWAYS the case, over time I have come to agree based on observation.

 

[kjoberk]

Don't complicate it. It's a two step process. First you have a non-conformance -- or in normal people's terms "something's not right."

So in your case, you have a non-conformance -- a screw loose, so to speak. Or a customer complaint.

Step two is you decide what to do about it. A corrective action (or an 8D as some call it) is only a tool. It provides a roadmap to do a root cause analysis, etc. But some problems can just be fixed. No real need to go thru all of that -- as Nike says -- just do it.

The problem is that people see every problem as a nail, and thus every solution is a hammer. So you're bogged down in "corrective actions" for even stupid things. And the eye rolling begins.

How do you decide how to fix? That depends. Some companies use a dollar amount -- anything less than $500 just get's fixed. In your case, you may need more discretion -- I would focus on safety type issue. The more critical to flight, the more I would be inclined to use a root cause/corrective action process.

Now in the two cases identified, it sounds like you actually did a corrective action process for the screw issue -- investigate, root cause, corrective action, training, etc.

As for the customer complaint, sounds like he is the root cause. The fix is to call him and tell him to pound sand.

He is definitely the root cause. I believe he was indeed told to pound sand.

Thank you everyone for your assistance. Along with getting information from all of you wonderful people, I've been researching as well and am going to be bringing a plan to my supervisor next week for ways we can revamp our system to make it less cumbersome on everyone involved.

 

[Golfman25]

The tack I'm taking these days is if there is not going to be a change made to the process, then a corrective action is not appropriate.

I know that's a sticky wicket, and not a one size fits all approach. It also entails informally conducting the root cause analysis and looking for possible process improvements before making the decision whether or not to document all that as a CA.

But a trainer I worked with once asserted that if your CA did not result in a process change it was unlikely to be effective. While that's not ALWAYS the case, over time I have come to agree based on observation.

I think that's a pretty good approach. But these days everyone assumes a NC is the result of an ineffective process.

 

[Mark Meer]

I second all the advice here so far!

One thing I might add is to suggest establishing criteria as to what events warrant escalation into CA process. As Sydney points out all should be handled case-by-case, but having some established general criteria will simplify the process.

For Example: An "event" happens (complaint received, NC identified...):

1. Does the event or recurrence of such an event reasonably involve a safety concern?
2. Is there a history of similar events that constitute an unacceptable trend?
3. Do other parties (internal, customer request, certification body, etc.) request immediate investigation/CA?

Yes to any of the above triggers the CA process.
This allows you to filter out relatively minor issues easily with a few checkboxes on a form...

Just a suggestion! Good luck!
MM.

 

[Ninja]

Looks like the situation is already covered.

Just to say the other "side" out loud...

We, also, put all complaints, NC, waivers/deviations, OFIs, quality system improvements, process improvements, etc. through the CA system.
In our case, it works for us.

Without (and that is a key "without") the assumption that everything has to go full bore, having one system that funnels all inputs into one system works pretty easily in our situation.

It may be, in fact, that the product line manager says "not a good reason enough to change anything", or commercial, or customer stewardship, or, or...

Someone files an OFI suggestion that isn't worth the money...the CA is generated (takes about 4 seconds) and stamped with "No action taken per ___" and closed.
{Note that all of the "pers" are authorized to make such a call}

A customer complains that UPS dropped the package...the CA is closed within minutes.
We could do it without the open/close of a CA...but it would, in fact, take longer the way we run.

Plenty of ways to de-fur a feline...food for thought.

If we had a guy who escalates everything into a mess...our approach might be different...but we don't have 'that guy'.
If a customer complains that we mis-shipped...that goes full bore.