EASA Audit Considerations - Assessment of Remedial Action follow up and Measures of Effectiveness
What are we Trying to Verify?
An Audit will typically generate a number of findings, and whilst the first step is usually to take an immediate “short term” action, the important business is ensuring the fundamental cause or “root cause” is addressed – the challenge is that this is far from easy!
Essentially, we are seeking evidence that the cause or “causes” of the problem have either been removed or mitigated in an acceptable way. (It is not always possible to completely fix the issue and sometimes the best outcome we can hope for is a reduction of the causes.)
Essential Evidence for Verification
The key to effective verification is objective & factual evidence. Evidence may be visual observations or documentary based. How much evidence to close a finding depends on the nature and magnitude of the problem. The important note here is to focus on a scalable response which ensures the verification matches the significance of the actions taken.
Sampling Examples (Size appropriate to the nature of the initial event)
a) Records of completion - post change implementation
b) Client or customer feedback following rectifications or amendments
c) Walk the procedure following the change to test for effectiveness
d) Interview employees to test the knowledge following change in the training process program or procedure
e) Review the contents of the amended Training Program - How is it measured for effectiveness
f) Review Training records to ensure that the modified training has been received
Dealing with the Challenges
Mutually agree the verification audit visit and ensure that you keep the auditee “onside” - means to provide an open verification with clear objectives, factually and always remain professional and independent.
Consider the possibility that corrective actions fail to deliver!
The most common reasons for this are:
a) The proposed mitigations didn't work
b) Lack of full implementation of proposed solution
c) Corrective action focused on the problem's symptoms instead of its causes
Meeting Root Cause Objectives of a Finding
The single biggest reason for corrective action lack of success is caused when the auditee only focuses on symptoms instead of true causes.
Actions taken must address the root as well as the contributory causes, this includes modification to process and procedures documentation to ensure the correct reflection of all elements of the fundamental cause of the finding.
The effectiveness of some corrective actions may require a measurement or monitoring of the audited process. In this case closure will take place following analysis of the data.
Sofema Aviation Services www.sassofia.com (SAS) and our partner SofemaOnline www.sofemaonline.com (SOL) offer both classroom based and online regulatory training course compliant with EASA Regulations. For additional details please see the websites or email office@sassofia.com or online@sassofia.com
