Preventive Action PA is NOT Risk Based Thinking RBT
In the transition from older versions of ISO 9001 &
14001 to the 2015 versions, users are regularly told that “you have been already doing RBT because it is just the traditional
Preventive Action”. This is a gross under-statement that does not explain
the benefits of incorporating RBT into all aspects of a QMS. The only real indicators of what people are “thinking” are observations of what people say and how they act.
Aside- Of course saying and acting are NOT always consistently the same.
Because these 2 indicators of "thinking" are also the only external indicators of "culture", then RBT is actually a risk culture descriptor. It is a characteristic of a new required way of devising, approaching, defining, describing as well as acting through the QMS processes needed to manage quality better.
YES – Both Preventive Action and RBT do have a proactive
dimension, but PA has often focussed on minimising negative effects on objectives while
RBT shifts the focus to opportunities which maximise positive effects on
objectives as well.
The new requirement for RBT emphasises the benefits of seeking out and
addressing QMS issues before they contribute to nonconformities. Preventive
Action has been, and can continue to be, focussed on taking action to improve
management processes that were revealed by nonconformities which have actually occurred.
In that sense, PA is initiated as a reaction to actual occurrences even though
the intention is correctly proactive in attempting to “prevent recurrence”.
True change of a QM culture to incorporate RBT requires considering chances /
probabilities of risks and opportunities that haven’t even occurred, and maybe not obvious nor previously considered. Black
Swans and Unknown Unknowns are expressions used in RBT to indicate these kinds
of issues.
RBT is more than just the action itself. It is also about
the how - the beliefs, visions, values, judgments, assessments, inspirations,
supposings, planning – that can lead to the actions and processes. Some RBT drivers are identifying and implementing actions and processes which are needed to increase the certainty of positive outcomes and decrease the uncertainty of negative outcomes. All of this applies to actions or processes even though their positive or negative outcomes may not have been experienced before.
The motivation for under-statements of what transitions are required to move from PA to RBT is understandable. The proponents of “there is no real difference” argument – “it has been implicit before, now it is explicit” – have intended to allay any fears of an apparently difficult concept.
Instead we should be providing the explanations and suggestions for how to make the very beneficial, consistent and unifying cultural changes towards more RBT because it is applicable to all Risk Management Systems, QMS, EMS, OHSMS and more.
RBT and PA are also fundamentally different with respect to the implied confidence in the effectiveness of the management processes and activities for managing risks and opportunities. The terms “prevent” and “preventive” are absolute not relative. As with other absolute terminology like "eliminate" and "stop", they are false confidence terms which deceive management efforts by over-estimating the effectiveness of risk control measures we devise and implement. They even falsely imply that the measures actually reduce the chances of a quality risk to zero. This is the perennial anti-RBT concept of confusing zero incidents with zero risk. Simply having no nonconformities in the past does not mean that the control measures implemented are perfect and have “prevented” the future risk or reduced it to zero. It is more meaningful to use the expression "reduce the risk of recurrence" rather than "prevent recurrence". There are numerous RBT concepts and language that better describe and help evolve better processes based on realistic thinking and hence better planning.
RBT must be embedded in every part and activity of your QMS. Not just the Clauses where it appears.
Risk Based Thinking is much more than traditional Preventive
Action
