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Struggling Against Nature Preventing Human Error in the ISO 9001:2015 Standard Copyright © 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com

Struggling Against Nature - Preventing Human Error in the new ISO 9001 2015 Standard

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Process Based Internal Audit Course

Struggling Against NaturePreventing Human Error in the ISO 9001:2015 StandardCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com1

ISO 9001:2015 now includes a requirement in 8.5.1g stating, The organization shall implement production and service provision under controlled conditions. Controlled conditions shall include, as applicable: g) the implementation of actions to prevent human error.

This new requirement has caused much concern among ISO 9001 implementers, due to the difficulty involved with eradicating human error. Quality professionals have been attempting to prevent human error since the invention of the wheel, with mediocre success (based on the fact that human error still exists).

This presentation will discuss the nature of human error, present some tools that can be used to address one cause of human error, and point out how the requirements of ISO 9001:2015 contain many clauses that assist in the effort of preventing human error. While it is important to learn new techniques for preventing human error, ISO 9001:2015 already provides many tools to assist in the effort.

One popular theory regarding human error is the Swiss Cheese Model, developed by James Reason in the 1990s. The Swiss Cheess model categorizes human error as caused by either Active Failures, or Latent Conditions. Active Failures are the typical, Someone screwed up, basis for human error, while Latent Conditions reflect the overarching management system weaknesses that may create conditions where the active failure could become present.

The error prevention tools I will present are aligned with the active failures portion of the Swiss Cheese model. The sections of ISO 9001:2015 cited in this presentation address the latent conditions within the management system that could lead to errors if weak controls are present.

Error management has two components: limiting the incidence of dangerous errors andsince this will never be wholly effectivecreating systems that are better able to tolerate the occurrence of errors and contain their damaging effects. I have a few tools to limit the incidence. Think of management systems like ISO9001:2015 as methods of creating systems to better tolerate occurrence an contain damaging effects.

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The Nature of Human ErrorWhy do humans screw up?TrapsToolsCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com2

Our brains process a lot of information, but we are not innately capable of discerning the long-term important from the short-term urgent. Its easy to see a tiger leaping at you, and you probably would not make the mistake of inaction. You d do something, and probably make no mistake while doing it. In the absence of a short-term obvious threat, we could focus on some concern from the past (the fight with a spouse or parents), or future (that big presentation and the accompanying worry), or get distracted by something that is present but is not important (TV, conversation, shiny objects).

When we are not present, not focused on the critical aspects of a task, we can make mistakes. There are patterns in human error called traps.

Depending on the trap involved, different tools can be used as a remedy to the trap.

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Human Error TrapsInterpersonal How we interact with othersCopilot SyndromeAttitude Mental approach to life and our jobsProximity RuleStress Response to differing workloadsDistractionsRisk Awareness of and response to risksAccommodation to RiskAttention Level of concentration and awarenessStrength of an IdeaLoss of Situational AwarenessTask Response to unanticipated challengesError/Accident ChainCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com3

The human error traps presented here and the tools to avoid situational awareness traps are based on materials developed by the Human Error Prevention Institute. Look them up and take one of their excellent courses.

Several categories of human error are presented here, along with one or more examples of specific traps within that category.

Copilot Syndrome The comforting premise that one or more other people or systems have the situation under control, resulting in someone just being along for the ride.Proximity Rule The chance of a conservative decision is directly proportional to the distance to the destination or time remaining to project completion. In other words, the closer you are to where you are going, the harder it is to decide to turn around or stop.Distractions Inability to maintain focus of attention. Accommodation to Risk Not being aware of risks involved in an activity or decision, or tendency to minimize risks, especially risks the deal with every day.Strength of an Idea An unconscious attempt to make available evidence fit a preconceived idea. Once a person or group of people get a certain idea, it can be difficult or impossible for them to alter that idea no matter how much conflicting information is received.Loss of Situational Awareness Failure to notice and react to information present in the environment, leading to inappropriate action or failing to take action, leading to a mistake. This presentation will discuss specific tools to avoid this trap (which is why the font is red on this slide).Error/Accident Chain A chain of risk factors and poor judgements, sometimes stretching back days, weeks, months, or even years before the actual incident. Each risk factor brings that person or team closer to the mistake or accident. Each poor judgement increases the availability of false information, which may then negatively influence decisions that follow. As the chain grows, situational awareness becomes impaired and the alternatives for getting the project back on track decrease.3

Loss of Situational AwarenessDanger ZonesNew situationsEmergency or high stress situationsRelaxed situationsWarning SignsFixationAmbiguityComplacencyEuphoriaGut FeelingOverload/UnderloadCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com4

Loss of situational awareness is more likely when someone has entered a danger zone. It is easier to keep situational awareness if one is aware a danger zone has been entered.

Another way to detect a danger zone has been entered is detecting the following warning signs. If one or more of these symptoms is present, operations may be happening with a danger zone, and human error may soon follow:Fixation Focused on only one problemAmbiguity Known facts do not make senseComplacency The Ive done this a hundred times trapEuphoria Feeling like everything is just perfectGut Feeling Indicates the subconscious is putting out a warning. Also called a, Pinch.Overload/Underload Too busy or too bored

(There are others not listed here, these are what I believe to be the most common)4

Tools for Situational AwarenessRegaining Situational AwarenessRecognize warning signsVerbalize concernsMaintaining Situational AwarenessIM SAFEAESOPCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com5

After entering a danger zone, and if loss of situational awareness is a risk, it is important to regain situational awareness as soon as possible. Two key tools is to first recognize the warning signs, and verbalize concerns about the possibility of situational awareness loss. Verbalizing concerns may sound like a simpletons approach, but it is an effective method of snapping oneself (and everyone around) back into awareness of the tasks underway and the associated risks.

We will now discuss two specific tools to help maintain situational awareness. IM SAFE is a tool for personal situational awareness. The AESOP huddle approach can be used by individuals or teams to maintain situational awareness.5

IM SAFEI IllnessAre you sick?M MedicationAre you taking medication? Dosage right? Side effects under control? Skip/Need a dose?S StressIs stress affecting you? Is it good or bad stress?A Alcohol (and/or Narcotics)Under the influence now? Still reeling from last night?F FatigueTired? Worn out? Sleepy?E EatingHave you eaten enough? Have you eaten too much?

Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com6

People dont come to work planning to make mistakes. Often the seeds of a mistake are sown outside work, only to blossom at the worst possible time for an organization. IM SAFE can help personnel identify if they have the seeds of a mistake growing (without their knowledge). This is loss of personal situational awareness, which can lead to human error.6

AESOPAssignment Is the assignment clear? Any problems foreseen? Time and resources adequate?Equipment What equipment is available? Is it appropriate? Is it working properly?Obstacles Are there any obstacles to completing the assignment with the equipment available?Personnel What personnel are necessary to completed the assignment? Are they available? What is their competence and experience? (IM SAFE)Situation Assess the overall situation and determine best course of action in light of risks identified.Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com7

Even when every person has their individual situational awareness under control, work teams must have a collective understanding of their current situation to avoid mistakes. The AESOP huddle model helps all team members assess the overall situation, and provide indicators for what needs to be done to get a situation back under control. This can be done at set points throughout a work day, at predefined times based on events, and/or when called for based on a team members assessment of the teams situation and performance.7

AESOP Links in ISO 9001Assignment 8.1, 8.5.1a, 8.5.6, 7.1.6Equipment 7.1.1, 7.1.3, 7.1.4, 8.5.1dObstacles 6.1Personnel 7.1.2, 7.1.6, 7.2, 7.3, 8.5.1eSituation Based on the situation, use 6.1, 6.3, 7.3 8.5.1, 8.5.6, 9.1 to prevent human error based on the AESOP evaluation.Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com8

ISO 9001:2015 clauses supporting each of the AESOP categories Assignment:8.1 Operational Planning and Control8.5.1a Control of Production and Service Provision (availability of documented information)8.5.6 Control of Changes7.1.6 Organizational Knowledge

Equipment: 7.1.1 Resources, General7.1.3 Infrastructure7.1.4 Environment for the Operation of Processes8.5.1d Control of Production and Service Provision (use of suitable infrastructure and environment)

Obstacles:6.1 Actions to Address Risks and Opportunities

Personnel:7.1.2 People7.1.6 Organizational Knowledge7.2 Competence7.3 Awareness8.5.1e Control of Production and Service Provision (appointment of competent/qualified persons)

Situation:6.1 Actions to Address Risks and Opportunities6.3 Planning of Changes7.3 Awareness8.5.1 Control of Production and Service Provision8.5.6 Control of Changes9.1 Monitoring, Measurement, Analysis, and Evaluation8

Hierarchy of ControlsEliminate the hazard (Remove the risk source)Substitute with less hazardous materials, processes, operations or equipment (Reduce consequences and/or likelihood)Use engineering controls (Reduce likelihood)Use safety signs, markings and warning devices and administrative controls (Reduce likelihood)Use personal protective equipment (Reduce consequences)Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com9

Another approach for preventing human error is reflected in Hierarchy of Control approach. Ranked from one to five, with one being the most effective, and five the least effective, management systems can focus actions to change latent conditions and remove opportunities for human error.

The Hierarchy of Controls concept also appears in OHSAS 18001:2007 section 4.3.1, addressing health and safety management systems. In this context, Hierarchy of Controls is used to address human error.

For each control discussed, the risk treatment equivalent from ISO 31000:2009 is identified in parenthesis.

(Definitions below from Wikipedia)Elimination - Eliminating the hazardphysically removing itis the most effective hazard control. For example, if employees must work high above the ground, the hazard can be eliminated by moving the piece they are working on to ground level to eliminate the need to work at heights.Substitution - Substitution, the second most effective hazard control, involves replacing something that produces a hazard (similar to elimination) with something that does not produce a hazardfor example, replacing lead based paint with acrylic paint. To be an effective control, the new material, process, etc. must not produce another hazard. Engineering controls - The third most effective means of controlling hazards is engineered controls. These do not eliminate hazards, but rather isolate people from hazards. Administrative controls - Administrative controls are changes to the way people work. Examples of administrative controls include procedure changes, employee training, and installation of signs and warning labels. Administrative controls do not remove hazards, but limit or prevent people's exposure to the hazards, such as completing road construction at night when fewer people are driving.Personal protective equipment - Personal protective equipment (PPE) is the least effective means of controlling hazards.9

HoC in ISO 9001:2015Eliminate 6.1, 8.1, 8.3.5, 8.5.1, 10.1Substitute 6.1, 8.1, 8.3.5, 8.5.1, 10.1Engineering Controls 7.1.3, 7.1.4, 8.5.1Administrative Controls 7.2, 7.5, 8.1, 8.5.1PPE 7.1.3, 7.1.4, 7.2, 8.1, 8.5.1

All actions to change processes to prevent human error supported by 6.3, 8.5.6, 9.1Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com10

ISO 9001:2015 Clauses that Support Each Hierarchy of Controls:

Eliminate and Substitute:6.1 Actions to Address Risks and Opportunities8.1 Operational Planning and Control8.3.5 Design and Development Outputs8.5.1 Control of Production and Service Provision10.1 Improvement, General

Engineering Controls:7.1.3 Infrastructure7.1.4 Environment for the Operation of Processes8.5.1 Control of Production and Service Provision

Administrative Controls:7.2 Competence7.5 Documented Information8.1 Operational Planning and Control8.5.1 Control of Production and Service Provision

Personal Protective Equipment (PPE):7.1.3 Infrastructure7.1.4 Environment for the Operation of Processes7.2 Competence8.1 Operational Planning and Control8.5.1 Control of Production and Service Provision

All Actions to Change Processes:6.3 Planning of Changes8.5.6 Control of Changes8.5.6 Control of Changes9.1 Monitoring, Measurement, Analysis, and Evaluation

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The Path ForwardTo err is, indeed humanFind and use tools to overcome human natureLeverage other ISO 9001 requirements to support the questCopyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com11

It is true, we will never eliminate human error. It is also true we have been working diligently to eliminate human error from our processes. There are many requirements within ISO9001:2015 that assist in the quest to prevent human error. What the new requirement in ISO9001:2015 clause 8.5.1g does is hold us accountable for exactly what we are doing to prevent human error, and opens the door for auditors to ask the question and make us demonstrate what we are doing.

There are many tools that exist to help us understand human error and take steps to prevent it. The two tools presented here are the tip of a very big iceberg. It is best for all of us to research methods teach techniques to those we work with to help them avoid errors. Nobody wants to make mistakes, but we all do. Our management systems must take this into consideration, and our work practices must continue to be made more robust. The 8.5.1g requirement will help us keep this important operational aspect front and center in all our minds.

We appreciate the time you spent exploring Preventing Human Error with Cavendish Scott.11

Cavendish Scott, Inc.ISO Consulting Training, and Internal Auditing Since 1985ISO 9001, AS9100, ISO 13485, ISO 14001, ISO 17025, ISO 27001Guaranteed Success (audits and consulting)Registered Lead AuditorsThousands of successful consulting registrations Thousands of trained ISO auditorsExperience with most industries including manufacturing and service industries12Copyright 2016 Cavendish Scott, Inc. All Rights Reserved. www.CavendishScott.com

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