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ISO9001: Why Your Corrective Actions Aren’t Working
I am in 50 businesses a year, and the most common and serious problem I see is lack of an effective corrective action program. The corrective action program is the most important thing in ISO. Without it, you don’t change anything. Nothing improves. Zombie problems rise from the dead and come back year after year. Your corrective actions aren’t working for a reason.
I have noticed a few patterns in this, as well. For another public service, I am going to give you abundant reasons why your corrective actions aren’t working. Whether or not you can do anything about this is a different matter.
Your corrective actions aren’t working because you don’t know what a Corrective Action is
A lot of the people I work with are from the military. In the Military, a “corrective action” is a euphemism for “butt chewing.” So a “corrective action” even though partly documented assumes that the employee is at fault. In ISO terminology this is better known as a “correction”.
Now, it is quite true that sometimes, the employee really is at fault.
But in some organizations, a fault by an employee is a failure of supervision. The employee was wrongly selected, undertrained, impaired, or otherwise unable to do the job no matter how many “corrective actions” are issued.
Knowing the difference between a corrective action and a correction is an important first step.
You don’t know when to issue one.
There is no requirement in the ISO standard that requires a corrective action (in the ISO sense) to be implemented. The only requirement is for “necessary” corrective actions. So if the rules for when to issue a corrective action are vague, it diminishes the effectiveness.
Sometimes a “correction” is all you need.
What I advise my clients is based on a process that is well established, and known to “work”. If one employee has problems, maybe it is about the one employee. If multiple employees are having the same problem, then there is a systemic issue and an analysis of the conditions is in order. Then an effective corrective action can be implemented.
You can’t rely on your process owners
Is it not clear that if there is an issue in a process that is causing problems, the process owner needs to be involved in the solution? There are still some organizations around where the “process owners” do not own the quality issues of the process. We can go into a dozen reasons for this to have developed historically.
I keep thinking this mentality has gone the way of the Passenger Pigeon but I then stumble into a place where it is alive and strong.
In the production-oriented operations of the 60’s it was more important to be fast than right. Some of this is still the prevailing attitude. The process owner is sometimes slow to embrace change. He or she may actually resist putting a stop to the problem to protect the workers. He or she may under or over-estimate how long, and what resources it will take to study and fix a problem.
The process owners need to be embarrassed enough in a process failure that they aggressively root out the problem. This is probably the number one failure more of a corrective action. Management indifference.
You can’t keep to a schedule
What I see so often is that companies put time limits on the investigation and solution to a corrective action problem. “Corrective Actions will be investigated and an action plan initiated within 10 days.”
The overall intent of this is to keep the process owners from sitting on problems hoping they will go away.
The reality of this is, some problems take a long time to investigate and fix. In the case of customer complaints, it may be a long time before the suspect material or part come back.
The people that do a good job of this have the process owners estimate a time frame for completion. Then, if changes need to be made later on depending on circumstances, they do so. This assumes the process owners are cooperative, of course.
Having a restrictive time frame on corrective actions is a way to paint yourself into a corner. It is also better known as audit bait because I, as an auditor, will target late corrective actions if I see that in a procedure.
But, the thing worse than that is a corrective action owner that says “sometime in a year or two I will get to that.”
You don’t properly determine the root cause
This is probably a topic for a book. In cases where the process owners lack training on root cause analysis this is a significant problem. Training can and should be done on this.
The number one problem on this is the failure to ask the “last question”. Example: The problem statement is “product did not meet the requirements.” The first why (of the 5-why model) is “human error” i.e. “someone didn’t do their job” and that is accepted as the root cause in some cases. Or the cause may be “the employee is untrained.”
There is almost always one more question can be asked: Why did that happen? Why did that employee not do his or her job? How was an untrained employee allowed on the line?
When you ask that question a whole world of potential underlying causes for employees not doing their jobs surfaces.
An Example of a Successful Corrective Action
I was in a manufacturing place the other day that had a tedious manual assembly operation. There was a customer complaint on a few products that should have been rejected at the line.
The knee-jerk reaction was to blame “human error” but this company did some analysis. They figured out that the order size was 2000 units. When they started to break the order down into 500-unit lots, the problem went away.
So what was the “real” root cause? The employee was being overwhelmed by 2000 sub-assemblies being in his area all the time. There was an ergonomic and work environment problem. There was an employee anxiety problem. When the client changed the order size to make the area more manageable, it solved the problem permanently.
The problem would have reoccurred if they had stopped at “human error” and just retrained the employee.
Your fix does not match up with your cause
There is an old saying, “When the only tool you have is a hammer, everything looks like a nail.” In many cases, no matter what the problem is, the solution is “train the employee.”
The better questions to ask is: What is it about that job that makes training so difficult? Or, “will any amount of training solve this problem?”
If your standard fix for anything is “train the employee” and the problem doesn’t go away, the problem is not training.
Your corrective actions aren’t working because you won’t change.
You’re supposed to be producing goods and services under “controlled conditions.” What that means is that someone established the processes and work instructions for the job. That someone, quite often, is an entrepreneur or bright engineer.
If this person is unwilling to embrace change, you won’t change.
This is also the place where the mentality is “that’s the way we’ve always done it.” But often, you find out that entropy has snuck into the system. A once-good procedure has a half-life.
So if you have change resistance, particularly on the part of the process owner, you have a problem.
You’re corrective actions aren’t working because no one follows up.
In a way this is the worst. You identify a problem. Analysis is done to determine the cause. You get everyone to agree to a change. When observed, the change works. But, when you turn your back the problem comes back, and/or there is reversion back to the original process. Your corrective actions aren’t working anymore.
The reason for this is that the corrective action owner did not properly follow up for effectiveness.
A second failure mode is that the change actually doesn’t work, but your follow up period is too short and it comes back as a zombie.
When the ISO standard states “the corrective action shall be reviewed for effectiveness” it is for a good reason. It is to keep zombie problems from coming back over and over.
Summary
Determining the real, real root cause, and then getting people to change is hard. It is all the more hard in cases where you don’t ask the right questions. It is practically impossible in cases where the process owners, and management, are not committed to making things better.
I would love to hear your experience on this topic. Feel free to comment.