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"Demonstrating" Risk Based Thinking

Discussion in 'ISO 9001:2015 - Quality Management Systems' started by QMSmaster, Feb 8, 2016.

  1. Leonid

    Leonid Well-Known Member

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    It is the organization, not auditor, who shall evaluate the effectiveness of actions taken to address risks and opportunities (9.1.3 e) and retain documented information.
    Possibility of incomplete effectiveness is embedded in the standard via 10.2: the detected nonconformity implies that the risk for this particular NC was not either determined or/and addressed.
     
  2. Eric Twiname

    Eric Twiname Well-Known Member

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    I keep reading this line over and over again...it is 100% true and on point...but inherently flawed all the same. That's why I keep coming back to it trying to find a better way.

    The difference between
    "it simply verifies that someone is steering." and "it simply verifies that someone competent, with the necessary resources, is steering." is, of course, the red part (which is why it's red).

    But the ones steering are also the ones who have the final say on the definition of "Competent" and also the ones who have the final say on what resources are "necessary"....that's the flaw.
    Don't know how to get around it...but keep coming back to it all the same...like a nagging toothache.
    I just can't picture Top Management saying they themselves aren't competent...and the final decision on competence (in the purview of ISO) lies with Top Management.
    There seems a systemic failure here. Please feel free to set me straight.
     
  3. Sidney Vianna

    Sidney Vianna Well-Known Member

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    Sorry, but in the case of ship steering, you are incorrect. The crew of vessels sailing around the World are subject to the Standards of Training, Certification & Watchkeeping Convention, and the Flag States will actually endorse the crew's certificates (assuming they are competent). So, differently than what you are suggesting, a shipping company can not simply assign any person to man the bridge on a ship, just like an airline can not assign any person to be in charge of the cockpit and pilot an aircraft. As for the example of resources, if the ship is using paper-based navigation aids as navigation charts, they must have all the relevant charts available at the bridge.

    This is an example of personnel competence to operate, regulated by international laws. It is NOT do what you say, say what you do....it has never been that, actually.
     
    Last edited: Feb 25, 2016
  4. QMSmaster

    QMSmaster Active Member

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    I guess this spirited conversations proves that it is totally up in the air what you need to do to demonstrate objective evidence in audit. Sounds like it will completely be a judgement call by the auditor. Yes, we are all constantlly weighing the risks if our businesses are succesful. We would have had to do that in order to not fail.
     
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  5. Andy Nichols

    Andy Nichols Moderator Staff Member

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    In many cases, this default will remain, until such times as management take control, by understanding what's required and demonstrating it! The fact is that we need to stop looking to (CB) auditors for the answers. While some are in a good position (through industry affiliations) to show some direction, it has always been the organization's responsibility to demonstrate compliance. If we were debating new product design, we wouldn't be asking the QC people what they thought was the answer. Sure, we'd solicit advice on QC matters, but the designers would still "own" the design and be able to describe how their solution(s) met the brief.

    We have returned to the dark days of inspecting quality into products after the fact if we continue to look to auditors for all the answers...
     
  6. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Eric: I guess you're struggling at least in part, that the "context of the organization" is key to answering many of these (seemingly) imponderable questions. You are totally correct that leadership isn't going to find itself to be incompetent, however, in understanding the needs and expectations of interested parties, and hence the context, the writing will be on the wall. If I might tell of some experience:

    I used to be responsible for supplier quality of bare pcbs (among others). We used 5 suppliers who, typically, delivered out of spec boards. They complained that they did this or that to make them right, but were failing. Replacements were no better. One owner ripped into me over the phone about my demands - which were simply to make ALL the holes the same size - citing how he had no problem making boards for others. He invited us to visit his "state of the art" production line.

    The long story short is that he invested heavily on process (which I'd not encountered anywhere else) except on the right one! He had failed to recognize that the review of customer specifications (artworks in this case) was fundamental in avoiding problems. Our artworks caused him the problems, but he (and his way of doing business) wasn't smart enough to catch that. I had learned from experience of another pcb house, that it was necessary to work with them to avoid problems in manufacturing.

    The moral of the story is that we eventually employed one pcb house, who helped us develop in house pcb design standards and we migrated to "dock-to-stock" pcb supply. The one guy didn't get it. Sure he was proud of his achievements, but in the end, his context wasn't what we wanted from a pcb supplier. He may well have been successful with customers with low grade specs etc, but that wasn't us.
     
  7. Sidney Vianna

    Sidney Vianna Well-Known Member

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    If you believe that, remember that auditors change and being at the mercy of the "auditor du jour" is a terrible way to manage a system.
     
  8. Jennifer Kirley

    Jennifer Kirley Moderator Staff Member

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    If you are constantly weighing the risks of your business, then you should not feel too worried. But I can understand your concern because the standard is not listing a bunch of shalls like before. What to do?

    1) When the auditor asks who are your relevant interested parties/stakeholders, tell him or her; be ready to describe why they were selected and the basis of decide why they are relevant, or not.
    2) Be ready to discuss your customers, both internal and external, their needs and wants and how you know and how you keep current. Internal and external customers can also be considered stakeholders.
    3) Describe what you have identified as that which can constrain success (risk) and how you go about making sure things go right.

    ...etc. etc.

    I said "discuss" and "describe" because there is no requirement for FMEAs, a formal risk management process, etc. Sure, it could be easier to help your organization's people understand all of this and keep track if you find a way to keep it for posterity; also to take the auditor through your process of identifying who cares about what you do and why, what you put in place to keep control of things, how you prepare people to do the right thing, how you know it's working, and so on.

    I find most people are doing this already, they just don't feel confident in how they can take credit for it, describe it in terms the revised standard is using.

    The standard says "demonstrate" so not everything needs to be written down; arguably not everything can be written down. A competent CB auditor will be reviewing a combination of documented information, what auditees say, and the auditors' physical observations to determine if the standard's requirements are being met. Like a three-legged stool, all should work to support the effort. That is, if splendid documentation says one thing and the place is bedlam, demonstration might not be successful. If everyone but top management says there needs to be more support to make the customer happy and top management says "Everything is wonderful, we made 80,000 widgets last quarter!" then demonstration may not be successful. If there is no documentation for things the standard does call for, the demonstration is not successful.

    Does this help?
     
  9. Somashekar

    Somashekar Well-Known Member

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    So well said Jennifer .....
    If I can talk about a plan B that I have I have demonstrated RBT
    If I can sure shot say that I have not made a plan B, for reasons that I best know based on experience and past history., I have demonstrated RBT
    If I show a blank eye or astonishment for any reasonably foreseeable situation, then I have not demonstrated RBT.
     
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  10. QMSmaster

    QMSmaster Active Member

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    Thanks for more answers. They kind of confirm that it will be up to the auditors discretion and our organizations ability to explain our approach to risk based thinking. I am not worried about our companies ability to evaluate the risks. We are a very advanced Hi-Tech company which dominates its industry and competitors. ISO certified for 20 years. Customers are extremely satisfied. Profits and growth most companies prey for. Our leadership team has deep industry, business, and customer knowledge. We could not be as succesful as we are without contunually evaluate risks. We just went through a management review and discussed risk to projects, business, processes, and customers constantly. Was the word risk ever used....no? Did we evaluate a list of "risks"....no. Would anyone on our leadership team except me understand what "Risk Based Thinking" is.....no. I see not reason to change how we do things outside of some potential improvements. I was recently telling another exec about how a major ISO9001 change was the addition of RBT. His response was "What the F^&* does that mean?". After I told him he thought it was the dumbest thing to add to ISO9001. I get RBT, but I think it is going to cause allot of hassles during audits.
     
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  11. Leonid

    Leonid Well-Known Member

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    Organization will always present to auditor various plans of various actions which are taken in the business life continuously. And then will clarify to auditor what any action ether prevents or facilitates. Prevents threat to deviate from expected; facilitates opportunity to achieve improvement. Thereby, risks are identified and explained to auditor. Context issues are readily recognized by the nature of action or risk.
     
  12. Quintus Abbott III

    Quintus Abbott III New Member

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    Sadly missed. :(
     
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  13. Jamie Lill

    Jamie Lill Member

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    Just go by what is written in the standards. If the auditor say it needs a record or more just ask him to show you in the standards. If it is not there then it can be verbal, written or telepathically transferred., there is no requirement. People are making this to complicated.
     
  14. Andy Nichols

    Andy Nichols Moderator Staff Member

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    I sincerely hope not...
     
  15. QMSmaster

    QMSmaster Active Member

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    So I attended a DNV ISO9001:2015 webinar. They explained 2015 from an auditor viewpoint. They stated that if you are doing FMEA's (process or design) you will meet the RBT requirement.
     
  16. Andy Nichols

    Andy Nichols Moderator Staff Member

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    As one of many choices? It seems a pretty obvious statement to make, really. In actual fact, the simple act of filling out an FMEA form isn't really "risk based thinking". If the RPN is derived from simply one person cutting and pasting a past example, that's all it is...

    I'd ask, from a user's perspective, just how many auditors have a clue about the (correct) use of FMEAs. Don't forget it's on TS 16949 auditors how have to have a clue about an FMEA...
     
  17. James A Shell

    James A Shell Member

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    There is no requirement in the standard for any formal risk assessment method I.e FMEA unless your customers require it. It may be a requirement in the TS or AS world. There is no requirement for "documented information" but you may wish to capture some instances of where you considered process risk to avoid a lengthy argument with your auditor.

    In my role as quality contractor I put a little check box: high/medium/low risk. Anyone who sets up a new inventory item, new customer, new supplier, or makes a document change or CA may choose to assign a risk higher than "low" in any of these cases if they feel the need to consult a higher authority. Hazmat and Safety always get a "medium" just so that it is communicated to somebody.

    The risk and opportunity is also probably also considered in the management review.

    If I were auditing I would look for any of the items above ref: insurance, disaster planning, backup suppliers, hedging...
     
  18. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Hi James, and welcome. Maybe it's a terminology thing, but "hedging"? Care to explain?
     
  19. normzone

    normzone Well-Known Member

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    It's a landscaping reference.
     
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  20. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Aha! The shrubbery from "Monty Python and the Holy Grail" comes to mind when considering risk... Is that it?
     
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