Recently, we’ve been coaching and training organisations on RCA practices & methodology to implement effective ‘preventative actions’, with the aim to prevent reoccurrence of non-conformities identified by an organisations own internal Quality Management System (QMS) or by the aviation regulator or other accredited bodies.
Over the period of our auditing and training, there appears to be a common trend why the ‘corrective & preventative actions’ are ineffective.
ISSUE 1 – Firstly, the initial problem (non-conformity) has been incorrectly identified. Meaning: the specific regulation or clause does relate to the applicable reference quoted in the non-conformity and / or is too generic.
Therefore, the person responsible for the closeout actions cannot effectively address the problem or even understand what the issue is. So, it’s going to fail from the start 🙁
But why does this happen? There are many reasons but here are just two:
(1) There can be a fear of pushing back on the auditors identified non-conformity because it’s the path of least resistance if the auditee believes the non-conformity is unjustified i.e. open to interpretation. So, who’s interpretation is correct? Therefore, it’s just accepted.
(2) Commonly, the auditee does not confirm the applicable requirement by reviewing the regulation or standard in order to understand the context of the non-conformity. Resulting in failing to understand the problem from the beginning.
ISSUE 2 – Secondly, does the non-conformity cover more than one regulation approval (EASA Part 145 etc..), and / or certification (ISO / AS91xx)?
Remember, if you have more than one approval, the regulatory approval always supersedes the requirement of the applicable standard. The RCA must cover both or all your approvals and certifications. Otherwise, the implemented change will contradict one approval over another.
ISSUE 3 – Thirdly, depending on the complexity of the non-conformity, it may need more than one person to action it.
Working in teams brings greater collaboration between all stake holders and includes the sharing of knowledge, experience, expertise etc…. which reinforces an effective working culture. This creates greater depth of understanding for everyone, enabling everyone to appreciate what is not working within their organisation and finally, understand the potential business risks. The ‘silo effect’ (on your own approach) does not seem to work.
SUMMARY: (1) Correctly identify the problem? (2) Is it applicable to more than one approval or standard? (3) Be effective & get collaborating – teamwork. Happy RCA!!