I'm updating our non-conformance procedure and struggling with the completion date for the corrective action. Should this be the date the action is actually completed, or the date the effectiveness has been verified.
Its easy to plan a date for completing the action, for example updating a procedure, but planning a date for verifying that change has been effective is harder. Is it enough to say that the verifier is happy that the action will be sufficient to prevent reocurrence?
Good day
@iso_is_fun!
Consider the following...
Corrective action is not the same as managing the
non-conformance.
A- non-conformance:
At the time of notification/awareness your organization should...
a) have a series of steps to locate (lot/product traceability) any suspect product (in order, if necessary, to contain/recall, etc...)...
and the conditions that may be making MORE suspect product.
b) stop the production of suspect product (cease production and/or take action to prevent the situation.) ...or (not ideal but sometimes necessary) verify/sort product to prevent outflow of nonconformance.
The aforementioned action can take place "immediately" (i.e. production can be stopped until an initial "fix" or verification can be established. Product sold/produced/in WIP can be contained until the required verification/scrap/rework/repair can be done).
B- Corrective action:
Using the appropriate discipline(s)...
a) identify the root cause,
b) correct/remedy the problem,
c) verify the effectiveness
d) ensure the "fix" is established systemically in order to prevent recurrence.
It is impossible to "proceduralize" (i.e. determine ahead of time) a date/time frame for corrective action. Some problems can be easily identified and corrected nearly immediately. Other problems require extensive research (possible re-creation testing, etc..etc..) to identify the root cause and may take even LONGER (order parts, change equipment design, etc..etc..) to correct. While the isolation/containment/verification of product may be needed/possible "immediately" in order to keep good/verified product flowing to the customer, the necessary time for actual root cause analysis and correction is impossible to predict considering the infinite amount of scenarios.
I would highly recommend your procedures do not attempt to predict or require a specific time frame for corrective actions.
Hope this helps.
Be well.
