Circle Back

| February 2, 2012

One of the most commonly missed provision of OHSAS 18001 is the requirement in section 4.5.3.2 e) that the organization’s corrective action procedure define requirements for “reviewing the effectiveness of corrective actions taken.”  This requirement is consistent with similar requirements in Section 4.5.3 e) of ISO 14001:2004 and Section 8.5.2 of ISO 9001:2008 and is often missed in quality and environmental management systems as well.

What this provision requires is that an organization have processes are in place to “circle back” at some later point in time to verify that the corrective actions taken actually worked.

What does this “effectiveness review” need to include?

At a minimum, two determinations are needed –

  1. Was the proposed corrective action done?
  2. Was the action taken “effective”?

First, was it done – was some action actually taken, was the action that was completed what was proposed and has it been sustained?

It is not uncommon to find that the proposed action was never done.  Sometimes, people get “busy” and taking the specified corrective action is constantly “put off until tomorrow” as other priorities take precedence.  In other cases, the action actually undertaken is NOT the action that was initially proposed.  Perhaps the proposed action didn’t actually work when it comes to actually implementing it.  Then there are the situations where changes are made initially but the organization quickly reverts to doing things the old way.

Second, was the action taken “effective” in fixing the issue identified as the nonconformity?

It is not uncommon to find that the action actually taken as corrective action bears little, or no, relationship to “the problem” identified as the nonconformity in the first place.  In the process of evaluating what actions should be taken, it is easy to get sidetracked by other interests and priorities and end up “fixing” something else entirely.  (“Gee, this is a great opportunity to justify getting the new training software we have always wanted.”)

The other difficulty with determining the effectiveness of the action taken is that “effective” is not a defined term and is a very subjective standard.

What qualifies as “effective”?

The dictionary defines “effective” as “adequate to accomplish a purpose” – not very much help. 

The key to this effectiveness determination is deciding whether or not the action taken will prevent “the problem” identified from recurring again in the future.  This determination needs to be based on an objective (i.e. unbiased) review of factual evidence.  Click here to access an interesting article on verifying the effectiveness of corrective action – including common questions to ask about the actions taken.  As the author of this article, Craig Cochran, puts it – “Verification isn’t an act of suspicion; it’s a necessary part of problem solving.”

© ENLAR Compliance Services, Inc. (2012)

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Category: OHSMS Implementation

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