CAMO.A.150 Findings

GENERAL The action plan defined by the organisation should address the effects of the non-compliance, as well as its root cause(s) and contributing factor(s). Depending on the issues, the action plan should address correction/containment of the issue, corrective action and preventive action.

FINDINGS RELATED TO THE CAMO’S MANAGEMENT SYSTEM THAT IS HARMONISED WITH THE MANAGEMENT SYSTEM OF ANOTHER APPROVED ORGANISATION If a finding that is raised by the competent authority (or non-compliance that is detected by the compliance monitoring function) affects the harmonisation of the management system of the CAMO with the management system of the contracting operator(s), which is required by point M.A.201(ea), the CAMO should inform the operator(s) to ensure that proper actions are taken within the group. The CAMO and operator(s) should agree on the appropriate channel for such communication. If the group use common standards to facilitate the harmonisation of the organisations’ management systems, the CAMO should inform the group management board or similar group governance body.

CAUSAL ANALYSIS

(a)It is important that the analysis does not primarily focus on establishing who or what caused the non-compliance, but on why it was caused. Establishing the root cause or causes of a non-compliance often requires an overarching view of the events and circumstances that led to it, to identify all the possible systemic and contributing factors (regulatory, human factors (HF), organisational factors, technical, etc.) in addition to the direct factors.

(b)A narrow focus on single events or failures, or the use of a simple, linear model, such as a fault tree, to identify the chain of events that led to the non-compliance, may not properly reflect the complexity of the issue, and therefore there is a risk that important factors that must be addressed in order to prevent a reoccurrence will be ignored. Such an inappropriate or partial causal analysis often leads to defining ‘quick fixes’ that only address the symptoms of the non-conformity. A peer review of the results of the causal analysis may increase its reliability and objectivity.

(c)A system description of the organisation that considers the organisational structures, processes and their interfaces, procedures, staff, equipment, facilities and the environment in which the organisation operates, will support both effective causal (reactive) and hazard (proactive) analyses.