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

[JaneB]

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.

Yup, agree. I think that was pretty much what Jim suggested several posts back

I voted yes on the poll because yes, I think it could be clearer.
Yes, they are two different terms, and yes, I understand that they are different things.

But in practice, I do disagree that they are always 'crystal clear' and I sure as hell spend one heck of a lot of time attempting to educate clients a/about the difference and b/about meeting the different requirements.

I'd be very interested to see all those in favour of no change list their 5 crystal clear examples of preventive actions.

 

[Helmut Jilling]

Yup, agree. I think that was pretty much what Jim suggested several posts back

I voted yes on the poll because yes, I think it could be clearer.
Yes, they are two different terms, and yes, I understand that they are different things.

But in practice, I do disagree that they are always 'crystal clear' and I sure as hell spend one heck of a lot of time attempting to educate clients a/about the difference and b/about meeting the different requirements.

I'd be very interested to see all those in favour of no change list their 5 crystal clear examples of preventive actions.

I do plan to spend time developing 5 examples today, per Sidney's challenge. However, let's recalibrate a couple of phrases here.

First, I agreed I would like them to reclarify their INTENT, in the next revision. On this, most of us agree.

My previous comment on "crystal clear" was actually

"Of course, as a spokesperson for the camp that says it means just what it says, why can't we just accept it as written? A proactive cousin to corrective action, after launch, before failure, following the same steps as corrective action? Alas, perhaps it is just my simple mind... ...but to me it is crystal clear.

I did not suggest that preventive action, as a concept, was "crystal clear" to everyone. Quite the contrary. I, too, spend much time explaining to clients what Preventive Actions are.

What I suggested was clear to me, was, that they wrote the details of cl 8.5.3 to exactly mirror cl 8.5.2. Thus it is "crystal clear" to me they did not intend to sweep FMEAs and Preventive Maintenance and all the other examples people have given into cl 8.5.3. The reason it is clear to me is those activities are indeed preventive activities, but they are covered in other specific areas. They are not even mentioned in cl 8.5.3. Thus, it is clear to me they did not INTEND those activies to be the answer to cl 8.5.3.

What I suggested was clear, was since they wrote cl 8.5.3 to exactly mirror cl 8.5.2, and since the official ISO definitions are IDENTICAL except for the use of the words "occurance" vs. "RE-occurance," thus it is "crystal clear" to me they intended preventive actions to be just like corrective actions, on a CA form, but proactive, not reactive. BEFORE the failure occurs. Other than that, they are the same thing. Two twin problem solvng tools, one reactive, one proactive. Nothing more, nothing less. THIS is what I suggested was "crystal clear" to me.

I asked, "why can't we just accept it as they wrote it?" It is a good tool. These other things are good activities as well, but they fit better in the other clauses I have listed in earlier posts.

 

[Jim Wynne]

I do plan to spend time developing 5 examples today, per Sidney's challenge. However, let's recalibrate a couple of phrases here.

You might find this more challenging than you think. For example, if I can't use the results of a nonconforming condition as impetus for PA, then aren't you excluding everything I might have learned in the past as a result of NC conditions? Therein lies the absurdity of the dichotomy. What is the time limit? If, five years ago, something blew up in my face and resulted in some egregious nonconforming condition, and today I'm faced with a similar situation, may I claim my actions are wholly preventive? The challenge, as I see it, is not to come up with examples of PA, it's to come up with examples of PA that were not the result of experience with bad things happening in the past.

 

[Helmut Jilling]

You might find this more challenging than you think. For example, if I can't use the results of a nonconforming condition as impetus for PA, then aren't you excluding everything I might have learned in the past as a result of NC conditions? Therein lies the absurdity of the dichotomy. What is the time limit? If, five years ago, something blew up in my face and resulted in some egregious nonconforming condition, and today I'm faced with a similar situation, may I claim my actions are wholly preventive? The challenge, as I see it, is not to come up with examples of PA, it's to come up with examples of PA that were not the result of experience with bad things happening in the past.

I understand your point, but I would suggest you are overthinking it. That is why I coined the following explanation:

If the CA/PA form you commence to fill out is in REACTION to a failure event, then simply class it a Corrective Action and move on.

If the CA/PA form you commence to fill out is PROACTIVE to a POTENTIAL failure event, (no one compelled you to initiate it), then simply class it a Preventive Action and move on.

I literally do not spend more than a moment or two evaluating which label I place on it. We both agree, the label does not mean much ONCE WE HAVE COMMENCED the action. That is the main point I have been trying to make. I don't make any effort whatsoever to try to correlate it to some event in the past or a book I read or anything else.

Simple, natural, spontaneous. That is why I like this approach. My clients easily understand the concept.

 

[Jim Wynne]

I understand your point, but I would suggest you are overthinking it. That is why I coined the following explanation:

If the CA/PA form you commence to fill out is in REACTION to a failure event, then simply class it a Corrective Action and move on.

If the CA/PA form you commence to fill out is PROACTIVE to a POTENTIAL failure event, (no one compelled you to initiate it), then simply class it a Preventive Action and move on.

I am not overthinking anything. Practically everything we do wrt PA is reaction to something that happened in the past. How long do we have to wait before we can call the reaction PA? Unless you can answer that question and provide examples that are not reactive to past experience, you have no case.

 

[Helmut Jilling]

I am not overthinking anything. Practically everything we do wrt PA is reaction to something that happened in the past. How long do we have to wait before we can call the reaction PA? Unless you can answer that question and provide examples that are not reactive to past experience, you have no case.

Jim, I don't know what you want. If you want a debate, you're not going to get it from me. I finished with the debate-for-sport aspect of this topic months ago.

Your previous post asked what sounded like a simple question, and I explained my simple approach. It works very nice, clean and simply. If that answer does not satisfy you, then nothing else I say on the topic will either. I refuse to allow this topic to be complicated, because my read of the definitions make the intent pretty darn clear to me.

I have already explained all the reasons for that viewpoint several times in previous posts in this and other threads.

If you want a "time," I would recommend you wait four months, three days, and 16.25 hours, then it can be preventive. I think that is a silly question and posture to take. A Proactive vs. Reactive position makes a lot more sense to me and explains simply why there would be any distinction between the two in the first place. I am interested in helping clients to get the results, not debate titles.

I have chosen to follow the concept that the ISO definitions present - that Preventives intend to be proactive, and Correctives focus on reactives, and both will prevent root causes.

I will not read any more into it than that. That works perfectly for me, and all the rest is idle debate without any end in sight.

You may choose to follow this path, or whichever other suits your fancy. But there is no benefit in parsing and dissecting the words. They say what they mean.

 

[CarlDaniel]

Thank you guys for the very informative discussions…some maybe too deep though. Can I seek your advice on something? On our CA/PA form, we defined the corrective action as "To prevent recurrence of the problem due to the most probable cause." and preventive action as "To prevent occurrence of the problem due to other potential causes.". Is this an accurate definition? What if during the root cause analysis exercise we can't find any other potential cause that could lead to the same failure mode. Will it be acceptable to an auditor to write "implement the above corrective action and monitor effectiveness for several weeks"?

 

[Helmut Jilling]

Thank you guys for the very informative discussions…some maybe too deep though. Can I seek your advice on something? On our CA/PA form, we defined the corrective action as "To prevent recurrence of the problem due to the most probable cause." and preventive action as "To prevent occurrence of the problem due to other potential causes.". Is this an accurate definition? What if during the root cause analysis exercise we can't find any other potential cause that could lead to the same failure mode. Will it be acceptable to an auditor to write "implement the above corrective action and monitor effectiveness for several weeks"?

From the point of view that I have been making, this would not work. The standard addresses preventive and corrective as two different activities. You use either one or the other. If you are observing a potential failure, then you execute a Preventive Action. If you observe an actual failure, you execute a Corrective Action. From that point, all the causes and actions stay on whichever form you began - preventive or corrective. There is little to be gained to filling out two forms.

 

[Helmut Jilling]

Per Sidney's challenge on the other current thread, I wrote a white paper on Preventive Action. For those of you who are interested, it may be a worthwhile read.

 

[JaneB]

Thank you guys for the very informative discussions…some maybe too deep though. Can I seek your advice on something? On our CA/PA form, we defined the corrective action as "To prevent recurrence of the problem due to the most probable cause." and preventive action as "To prevent occurrence of the problem due to other potential causes.". Is this an accurate definition? What if during the root cause analysis exercise we can't find any other potential cause that could lead to the same failure mode. Will it be acceptable to an auditor to write "implement the above corrective action and monitor effectiveness for several weeks"?

Carl,

I think you'd be better advised to stay with the ISO definitions of CA and PA. Making up your own could be unwise. I'd use the ISO 9000 (2006) definitions which I think have already been posted.

If you can't find any other potential cause - fine, stop. The Standard pushes you to consider the need and to act if you find cause. Don't go hunting about for ever. As for 'will it be acceptable to an auditor if we do x'... I just can't answer that. It's one of those 'pieces of string' questions.

Here's a sequence:
1. If a problem, correct it (if you can) - eg, rework. That's just correction (not CA)
2. If the problem could recur, then identify the cause/s and do CA to fix the causes & prevent recurrence. That is CA.
3. (Trickier) If you identify potential causes of potential NCFs, do PA to prevent them.

Sometimes CA does lead on to PA. Sometimes it doesn't. Sometimes PA comes about without CA, all by itself. Depends. Sorry - I KNOW that's not a 100% definite rule. It cannot be.

Re. 'implement the above corrective action and monitor effectiveness for several weeks" - the 'several weeks' monitoring depends on the thing at hand. How long do you need to monitor to ensure your CA has been effective? That's the real question. Might be a week, might be a month, might be several weeks. Don't just blindly pick 'several weeks'.