Corrective Action Tracking

What is a corrective action?

A corrective action is an action taken to eliminate any undesirable or adverse situation (deficiencies). The corrective action procedure within a health and safety system should be a formal documented process to ensure that corrective actions to resolve deficiencies are, identified, implemented and verified. 

What is corrective action tracking?

Corrective action tracking refers to the “cradle to grave” process that we use to make sure that required corrective actions are carried and verified. A formal documented process is used because needed improvements in our safety systems cannot be allowed to “fall through the cracks”.

We take care of problems, why do we need another system?

A failure in our health and safety system can have tragic consequences. Once a deficiency is identified, a formal process is required to ensure that the corrective action to eliminate the deficiency and prevent a recurrence, is implemented and effective. Without formal follow-up we can fall into a pattern of identifying how to fix problems without ever fully resolving them.

Consider this 2015 OSHA news release:

In a three-and-a-half year period, 4,500 employees at (a manufacturing facility), experienced more than 1,000 work-related injuries. One worker became another terrible statistic when he lost three fingers in July 2014 while operating a dangerous woodworking machine without required safety mechanisms in place. Of the injuries recorded, more than 100 were caused by similar machinery.

After the incident, …. Investigators identified 12 willful, 12 repeated and 14 serious safety violations …, OSHA previously cited the facility in 2014 after an employee suffered a partial finger amputation.

The news release paints a very troubling picture of a company being cited and recited for deficiencies that continued to result in serious injuries.  It seems likely that no one wanted to see people hurt over and over again, yet in the absence of corrective actions, they were.

What are the sources of corrective actions?

Incident investigations are an obvious source of corrective actions but there are many others.  Corrective actions come from the commitments that we make every day, when we identify a deficiency and agree upon what steps need to be taken to prevent a recurrence.

Corrective actions can result from uncovering deficiencies when:

• Conducting informal and formal workplace inspections
• Conducting safety meetings
• Conducting audits
• Preparing near miss incident reports and investigations
• Preparing hazard reports
• Analyzing safety data for trends
• Evaluating employee suggestions

When a course of action is agreed upon to resolve a deficiency, it is a corrective action. Reports generated from these activities should always identify whether a corrective action is required and include a process to capture these to a formal register for tracking.  Electronic processes are well suited for this.

What does tracking mean?

If a corrective action cannot be implemented immediately and permanently, then it must be followed, or tracked, until it’s implemented and its effectiveness has been verified.

The corrective action tracking steps are:

1. Implement interim safety measures for the deficiency
2. Agree upon the corrective action to be taken
3. Assign a unique descriptor (number, title, date, etc.) 
4. Record the corrective action on a register
5. Assign responsibilities for implementation and verification
6. Assign target dates
7. Publish the corrective action register
8. Establish a regular status review for all corrective actions 
9. Measure the effectiveness of the corrective action before closing it out 

Identify, implement and verify that your corrective actions have been effective in order to ensure that you are protecting all persons and improving your health and safety system.