Akron OH — Smithers Quality Assessments, an ANAB-accredited ISO 9001 registrar, has rolled out a root cause analysis tool to assist clients in responding to audit nonconformities, in compliance with ANAB accreditation requirements. The company is responding to a 2009 call by ANAB for registrars to obtain better corrective action responses from certification clients.
Expanding on the traditional “5-Why” method of root cause analysis, Smithers’ proposed method (PDF) goes beyond and suggests a three-tier, 15-Why method, applying three “whys” to each of the following categories: immediate cause, detection failure, and systemic root cause.
“It’s a bit overcaffeinated,” said Oxebridge VP Operations Christopher Paris. “The 5-Why model has been criticized for being burdensome and often creating more problems than it solves. To multiply that threefold is extreme, to say the least.”
While Oxebridge maintains that proper root cause analysis is essential for effective corrective action, the 5-Why model has been challenged as it sometimes results in a false root cause, typically from “overthinking the problem.” Critics say that asking “why?” too many times can generate an overly generic, philosophical answer that is too far removed from the problem to be practical. They also say that the activity makes too many demands on already-stretched managers.
“Every problem,” Mr. Paris said, “can eventually be traced back to the Big Bang Theory, evolution, or a religious belief, if you want to take it that far. A procedure wasn’t followed, then blame it on the parents of the worker far having children. It gets crazy.”
Another criticism of the 5-Why model comes when auditors write findings on typographical errors in quality system documents, a frequent source of corrective action requests. “How do you do a 15-why analysis on a mis-typed keystroke?” Mr. Paris asks. “Would the ‘systemic solution’ be to send everyone to typing class?”
Said one industry expert:
In root cause analysis, there are more choices than just an easily understood falsehood or an incomprehensible truth. So one must find the middle ground – a system that is easy enough to use without being too easy.
Quality Digest’s Craig Cochran published an insightful argument against the 5 Whys in 2009, saying:
Asking why one time after another assumes that the problem is perfectly linear, with one cause directly related to another. If we keep asking “why?” we’ll eventually get back to the root cause. However, real problems are much more complex than this. One cause does not always lead directly to another cause. There are contributing factors and hidden variables that mess up our ingenious chain of causes. If we try to treat every problem as nothing more than the result of a single chain of causes, we’ll miss the complexity that exists in the process.
The Smithers press release on the matter is inconsistent. While couching the use of some form of root cause analysis tool as a “new requirement” with an effective date of August 22, 2011, the Smithers language nevertheless indicates that a root cause analysis tool “should” be used — the word “shall is not included, thereby making it uncertain if this is a requirement or not.
It is clear that the 15-Why tool proposed by Smithers is an optional method, not a required one. Accredited registrars are prohibited from mandating a prescriptive method for addressing requirements.
In its “Heads Up” rule clarification (PDF) dated December 2008 , ANAB alerted accredited registrars that they must obtain a suitable corrective action response from clients who have been cited for nonconformities. The rule indicates that the response must include three components: containment of the issue in the immediate time frame, a detailed root cause analysis, and a systemic solution to prevent recurrence.
The Smithers’ email to clients announced their new rule on August 18, 2011, over three years after the ANAB alert. It read:
As of August 22, 2011, any corrective actions resulting from a non-conformance identified during an audit should be accompanied by a root cause analysis tool as part of the corrective action submittal.
Even as of 2008, the rule was not new, and the ANAB Heads Up notice acknowedged it had not been properly assessing registrars on the requirement previously:
This … is nothing more than what CBs should have been providing as responses and what accreditation assessors should have been looking for in the corrective action responses from CBs.
The ANAB rule does not mandate a 5-Why root cause approach, nor any specific method to be imposed on registration clients. It does, however, provide guidance on the concept:
The Root Cause statement [must address] a fundamental issue without any obvious “why” questions remaining.
“The problem,” Mr. Paris said, “is that whether or not an ‘obvious why’ remains is wholly subjective. And introducing any more subjectivity into the auditing process is always dangerous.”