Enforcement and Inspection, Safety Culture and Behavioral Safety

The Three Key Parts of an EHS Corrective Action Plan

Corrective action is an important aspect of EHS management that is used to fix operational issues, keep employees safe, and reduce environmental impacts. Corrective actions can originate from a specific incident that spontaneously occurs, an internal audit that discovers something is amiss within an organization, or a regulatory agency inspection that seeks to determine if the organization is in compliance with state or federal mandates.

EHS corrective action plan

Corrective actions span the spectrum from relatively minor workplace adjustments to significant EHS concerns that could shut down operations and potentially damage a company’s bottom line. Corrective actions should not be confused with corrections, which focus on the immediate response and containment of an incident, or preventive actions, that are proactively planned to keep issues from occurring in the first place. Corrective actions take place after an occurrence and are thoughtfully designed to ensure the incident or issue is not repeated and that the remediative plan is implemented, documented, and communicated appropriately.

Corrective actions can include engineering controls, process changes, or personal protective equipment (PPE) and are usually initiated once root causes are identified. EHS and quality professionals use a variety of methods to outline their processes for implementing corrective actions. Arguably, the most popular methodology within the manufacturing space would be the 8 Disciplines of Problem Solving. Initially developed at the Ford Motor Co. in the 1980s, the so-called 8D approach was later adapted for use in multiple industries with assembly line components and now includes an initial planning stage.

Generally, the 8D approach includes the following disciplines:

D0 – Plan: Prepare for problem solving, determine the prerequisites, and create emergency response actions.

D1 – Form a Team: Establish a team of people with necessary knowledge of the product or process affected by the problem.

D2 – Describe the Problem: Specify the problem in quantifiable terms using 5W2H—the who, what, where, when, why, how, and how many.

D3 – Develop Interim Containment Plan: Create and implement interim containment actions to isolate the problem until determining a permanent solution.

D4 – Determine Root Causes and Escape Points: Identify and verify possible root causes of the problem.

D5 – Select and Verify Permanent Corrections. Using preproduction programs, quantitatively confirm that the chosen correction will resolve the problem.

D6 – Implement and Verify Corrective Actions: Define the best corrective actions, communicate them to the team, implement the plan, and confirm the issue is resolved.

D7 – Prevent Recurrence: Take necessary preventive measures by modifying management systems, operation systems, practices, and procedures to mitigate recurrence of this problem and similar issues.

D8 – Congratulate the Team: Formally recognize and thank the team members for their collective efforts.

Discipline 4 and 5 of this methodology focus on the identification of root causes and validation that the proposed actions will resolve the issue. There are also many methodologies EHS leaders use to conduct a Root Cause Analysis (RCA) including 5 Why, Fishbone, Fault Tree Analysis, and Failure Mode and Effects Analysis (FMEA). Many organizations also add RCA to their audit findings to more effectively identify the meaningful corrective actions.

Discipline 6 focuses on the corrective action plan, communication, and verification. Here is where it is crucial to follow an established plan of action. Let’s consider a hypothetical situation that displays how corrective action is properly enforced over a situation that may or may not create serious problems in the near future.

Creating an Effective Action Plan

Imagine a manufacturing facility in which employees use solvents in small squeeze bottles on the production floor. They get the bottles from a maintenance crib—the bottles are labelled by the EHS department, and the solvent originates from strategically placed drums fitted with dispensing pumps and located in appropriate flam cabinets. During an ISO 45001 audit, the auditor finds several bottles that are either damaged, do not have a label, and/or have a handwritten label that is illegible.

The auditor issues a minor finding which triggers an investigation that is proportionate to the seriousness of the issue. The investigation and analysis aspect of the finding should result in three important parts: (1) a substantive action that involves a physical change of daily operations, (2) an administrative action in updating the new procedures to ensure there is no recurrence of the original problem, and (3) a training action that makes sure that all affected employees understand what is changing and why.

Part 1 – The substantive action

In this scenario, a successfully conducted investigation into this situation would have resulted in relocating the supply of bottles to a central storage shelf so that employees can easily replace bottles while the production supervisors would check these supplies during their routine housekeeping inspections. That would fall under the heading of the substantive part of the process.

Part 2 – The administrative action

The successful investigation would also involve updating both the facility supervisor’s Housekeeping Inspection checklist and the HazCom Program so that it acknowledges the new process has been put in place. This is an example of the administrative change within the corrective action protocol.

Part 3 – The training action

Also, the training part of the process would involve employees receiving instruction on a new self-service process involving the bottles while the supervisors overseeing this new inspection expectation would receive updated guidance on how to respond when the bottle or label supplies are getting low.

The verification step may include auditing of the process and documentation that corrective action is taking place. This could involve interviews with staff to ensure training was conducted and the new processes and procedures are being implemented correctly.

Considerations

Action plans identify the goal and what people, resources, and activities are necessary to achieve that goal. By defining each resource requirement and breaking the effort into steps, a goal appears more achievable. When creating a corrective action plan, there are five steps that need to be considered:

  • Goals should be SMART (Specific, Measurable, Achievable, Relevant, and Time-bound). Vague notions of what could be achieved are, ultimately, a waste of time, whereas a clearly defined mission and results that can be recorded will prove invaluable.
  • Involve all stakeholders in the process. Corrective action is not a solitary pursuit, and the input of all parties can uncover ideas and concerns that would otherwise escape notice.
  • Maintain a realistic metric for recording results. Point A should take you to Point B and not off on a lengthy and irrelevant tangent.
  • Set a deadline for the project’s completion. After all, there is no such thing as a never-ending project.
  • Share the results of the corrective action. This will prove important in detailing why the problem required this action while setting an example that will not enable recurrence.

Closing the Loop and Learning From the Past

Corrective actions can take days, months, and in some cases, years to complete and tracking them to closure can be challenging. Having a system in place that creates visibility into the status of corrective actions helps to ensure that they are addressed. It’s also important to realize that corrective actions and the issues that they arise from are not necessarily isolated events. They happen within the larger flow of an organization’s operations, processes, and procedures and can often help to identify bigger picture issues and trends.

Corrective action management software can aid in both tracking corrective actions to closure and in analyzing them across locations. Documenting them in a knowledge base that is accessible to all of the organization’s EHS and site leaders can help make sure that the lessons learned from one happening can be shared and studied for future issues in different departments, business units, and locations.

Print