John,
That is a problem. If the QM and Management Team does not review these NCRs and the resulting ( CA/PA ) for:
1.) Accuracy - Internal Auditors should be well trained
2.) How and why it was found. If anyone can write a N/C ( CA/PA ), this could very well happen. Control who can write the N/C, allow anyone to issue a request to investigate the possible N/C.
If the procedure is that the QM and their (I.A.s ) Internal Auditors must investigate the NCR prior to issuance - this can prevent useless findings from being written and prevent the issue of employee bashing.
It is the QM and the Executive Management, that sets the tone and how N/Cs are written against the QMS. There are, in the majority of cases, good findings and I think it best, not to lose sight of the benfit from finding N/Cs and implementing ( CA/PA ) before the customers do. Provided they are valid.
I will agree that in some cases, there is a blame game that goes on and people use the N/C as a means of political ammo. This hurts the QMS and its' validity.
If this occurs during the Internal Audits by the internal auditors, it is up to the QM to prevent this. I have seen in somes cases where the QM didn't have the ability to prevent it and as a result, outsourced the I.A. to a third party to maintain objectivity.
Sincerely,
Tim
JFount,
My name is Tim Butler and I have 10 years of experience and have worked with 1000+ companies on their ISO programs: AS/ISO/EMS/CE/OHSAS/TL/RCMS/TS.
If you are looking for what should trigger a CAPA look to your companies' procedure and if there is a deviation in this procedure from what actually occurred, then a CAPA should be required. I would also make sure the procedure is lean - calling out only what is absolutely required to perform the specific task. Otherwise, you are requiring additional steps that could bog your QM system. If you need a checklist for any standard or anything else, please feel free to ask.
Sincerely,
Tim