Clarence -
Been trying to figure this out for awhile now. The FDA has cited deviations being used as mechanisms to circumvent NCR's. We eliminated unplanned deviations, but even planned deviations are sketchy as just because you planned to create nonconforming product doesn't make it less nonconforming. We still do deviations, but only for development and clinical builds, where we are intentionally altering things.
I'm still stuck on minor things. For example... a PM was due on equipment Jan 1, but it was missed, or even intentionally skipped and not done til say Jan 15th. Now I've got an NC because the process wasn't followed. I get that we want to track that and see if there is a trend, but mixing it in with true product NC's seems wrong.
Did you ever come up with a good resolution?