Should the TC 176 Re-word the Requirements for Preventive Action?

[Helmut Jilling]

Since the topic is about preventive actions...our ISO/TS16949 auditor was not satisfied with our FMEA process and were looking for other alternatives to implement preventive action processes. Does anyone have suggestions?

The FMEA is discussed in cl 7.3.3.1 and 7.3.3.2. Preventive Action section is cl 8.5.3. Preventive Maintenance is cl 7.5.1.4.

While FMEAs and PMs are preventive, doesn't it seem logical that the standard is looking for something else for cl 8.5.3? Otherwise, why would they have made another section? If it wanted these same things, they had already covered it.

The definition for corrective and preventive actions is almost identical. The steps that MUST be addressed in 8.5.3 are identical to the steps for corrective action. Why can't we just accept it the way theywrote it? That a preventive action is like a corrective action, but done proactively, while problems are still potential?

In a word, a preventive action is a corrective action done ahead of time, before the failure occurs. FMEAs are like that too, but they are done before the product launch. FMEAs are superior to preventive action, because it is still in the development stage. After launch, we do corrective and preventive actions.

 

[dna_leri]

In a word, a preventive action is a corrective action done ahead of time, before the failure occurs. FMEAs are like that too, but they are done before the product launch. FMEAs are superior to preventive action, because it is still in the development stage. After launch, we do corrective and preventive actions.

FMEAs should be live documents, then they are effective tools for preventive action, before and after lunch

 

[Jim Wynne]

In a word, a preventive action is a corrective action done ahead of time, before the failure occurs. FMEAs are like that too, but they are done before the product launch. FMEAs are superior to preventive action, because it is still in the development stage. After launch, we do corrective and preventive actions.

I think this paragraph provides ample evidence that the standard needs attention in the area of CA and PA. I'm not sure how you can say, on the one hand, that "...preventive action is a corrective action..." and then say that there's a bright line between the two. While you maintain that the wording of the standard is clear, the degree of clarity of the requirement isn't necessarily in question; it's whether what's required makes sense or not that's the issue. I say that we have to always be aware of opportunities for defect prevention, and whether or not preventive action takes place before or after something bad happens is immaterial, so long as there is still evidence that reasonable efforts are made to preempt problems.

The first thing we need to do is acknowledge that the mistakes, missteps and minor disasters we all experience are not evil until they become repetitive. We'll never overcome human propensity for error, but we also need to recognize our ability to learn from our mistakes. We need to be able to show evidence of learning from nonconforming conditions, and applying the new knowledge in ways that result in continualous improvement. Something that's better today than it was yesterday is evidence of improvement, regardless of the source of the new knowledge, and all of this back-and-forth over the words we use to describe the process does not add value to anything. Every time I do something that results in defects being prevented, I don't want to have to stop and look at the standard and see which column to put a check mark in. When the standard gets in my way, it's no longer serving its purpose. If, as a result of something bad happening, I fix the process so it can't happen again, I've done preventive action and anyone who says I haven't needs to get his head out of the standard and find something useful to do, because there's actual work to be done.

 

[Jim Wynne]

FMEAs should be live documents, then they are effective tools for preventive action, before and after lunch

Once I received notice of a meeting, to take place midday, wherein the author of the notice made the same typo, saying that it was a "lunch" meeting rather than a "launch" meeting. As we were accustomed to lunch being provided in those instances, a lot of hungry and angry people showed up.

 

[db]

I have never liked the language of preventive actions. It almost reads like an afterthought of the corrective action. I have a friend who is a member of the TAG, and I was complaining to him about that. His response was for me to reword it the way I felt it should be and forward it to him for consideration.

I keep saying that someday, I will have to do that.

 

[Helmut Jilling]

I think this paragraph provides ample evidence that the standard needs attention in the area of CA and PA. I'm not sure how you can say, on the one hand, that "...preventive action is a corrective action..." and then say that there's a bright line between the two. While you maintain that the wording of the standard is clear, the degree of clarity of the requirement isn't necessarily in question; it's whether what's required makes sense or not that's the issue.

I have already agreed I would like them to clarify their intent because there is so much disagreement among otherwise knowledgable people.

However, my comment was "preventive action is a corrective action done ahead of time, before the failure occurs." That is what made it a "preventive action" performed upon a potential failure. If you wait until the failure occurs, it is too late to be proactive and you are consigned to reacting and doing only a regular corrective action. Preventive actions are superior because you are being proactive. Preventive actions are generally cheaper because no failure mess has occurred.

I say that we have to always be aware of opportunities for defect prevention, and whether or not preventive action takes place before or after something bad happens is immaterial, so long as there is still evidence that reasonable efforts are made to preempt problems.

As I said...Preventive actions are superior because you are being proactive - Preventive actions are generally cheaper because no failure mess has occurred.

Interesting anecdote. I just completed an audit and had this identical discussion with the client. They went from your point of view to completely understanding the ISO definition of Preventive vs. Corrective and are eager to apply it.

 

[Helmut Jilling]

I have never liked the language of preventive actions. It almost reads like an afterthought of the corrective action. I have a friend who is a member of the TAG, and I was complaining to him about that. His response was for me to reword it the way I felt it should be and forward it to him for consideration.

I keep saying that someday, I will have to do that.

By all means, do it now...

Why would it be an "afterthought of corrective action" if you do it before a corrective action is called for?

 

[Helmut Jilling]

FMEAs should be live documents, then they are effective tools for preventive action, before and after lunch

Personally, I always liked to do them after dinner because there were less interuptions.

However, as I said, the FMEA is discussed in cl 7.3.3.1 and 7.3.3.2, Preventive Maintenance is cl 7.5.1.4, and Preventive Action section is cl 8.5.3.

While FMEAs and PMs are preventive activities, doesn't it seem logical that the standard is looking for something else for cl 8.5.3? Otherwise, why would they have made another section? And, why would they have used identical language as corrective action? If it wanted these same things, they had already covered it.

I still insist they said exactly what they meant. It seems so patently clear and obvious to me. I don't understand why so many of you resist it.

PS: Sidney, I will respond to your challenge to find 5 examples very soon.

 

[Jim Wynne]

However, my comment was "preventive action is a corrective action done ahead of time, before the failure occurs." That is what made it a "preventive action" performed upon a potential failure. If you wait until the failure occurs, it is too late to be proactive and you are consigned to reacting and doing only a regular corrective action. Preventive actions are superior because you are being proactive. Preventive actions are generally cheaper because no failure mess has occurred.

If someone is waiting until failures occur before they do anything, I agree that it's a problem. We even have a recent comment in another thread where someone complains about management being completely reaction-oriented when it comes to safety issues, so I know this sort of thing goes on. But that's not the point. Of course it's best to prevent rather than react. The problem is that s*** happens even in the best prevention-oriented systems, and in those systems, people look around after failures to find similar potential problems in similar products and processes, yet that effort (at least in TS16949) is not considered preventive. That's patently ridiculous.

My thesis is simply this: if someone makes the effort to prevent something bad from happening, futzing with the language in order to claim that nothing preventive was done makes no sense, and borders on the Orwellian. If it's possible to rewrite the standard such that it's clear that heading off problems before they happen is the expected course of action, and so that we don't deny something is preventive (using the dictionary denotation) when it clearly is, why wouldn't we want to do it? Just saying that the meaning of the language in the standard is clear doesn't mean that what's expected makes sense. Using that line of reasoning, if the standard said that all production employees must wear pink tutus, the requirement would be clear, no?

As I said...Preventive actions are superior because you are being proactive - Preventive actions are generally cheaper because no failure mess has occurred.

No one is disputing this, but it has nothing to do with the issue at hand.

Interesting anecdote. I just completed an audit and had this identical discussion with the client. They went from your point of view to completely understanding the ISO definition of Preventive vs. Corrective and are eager to apply it.

This is also irrelevant, because as you say, the requirements are clear, and if the client wasn't meeting them, it's not surprising that they were eager to be in compliance. The same could be said about the supplier being eager to outfit their production people in pink tutus if that's what was required.

 

[Helmut Jilling]

If someone is waiting until failures occur before they do anything, I agree that it's a problem. We even have a recent comment in another thread where someone complains about management being completely reaction-oriented when it comes to safety issues, so I know this sort of thing goes on. But that's not the point. Of course it's best to prevent rather than react. The problem is that s*** happens even in the best prevention-oriented systems, and in those systems, people look around after failures to find similar potential problems in similar products and processes, yet that effort (at least in TS16949) is not considered preventive. That's patently ridiculous.

My thesis is simply this: if someone makes the effort to prevent something bad from happening, futzing with the language in order to claim that nothing preventive was done makes no sense, and borders on the Orwellian. ....

At least we pretty much agree on this part. Just remember that both corrective action and preventive action, by ISO definition, prevent something - the reoccurance, or the occurance of a root cause. So, either way, they are being preventive. No need to be concerned about Orwell.

For each action, let's just select the better fit and move on. I think too much energy is spent trying to decide what label to put on an action. Let's apply that energy to identifying areas where bad things could happen, and take action to prevent them. That is the greater part of the equation.