Does Your Corrective Action Program Need Corrective Action?

Even the safest organizations frequently identify problems and opportunities for improvement. In fact, many best-in-class organizations actively seek out even minor potential problems so they can address them before they lead to accidents or incidents.   In such companies the lack of large numbers of problems and improvement opportunities identified by the workforce is often seen as a warning sign for complacency. (Loud, 2004, p.35).   Companies that recognize the need to find and fix problems, and the importance of continuous improvement, have long developed lists of corrective actions and generally track closures. This approach, often called “stack and track,” is better than nothing but is far from optimum. Effective and efficient resolution of issues requires active management like any other important organizational program. The price for poorly managed corrective action programs is high and often results in problems such as the following:

  1. Employee disillusionment – When workers feel that their suggestions and concerns are not taken seriously or addressed in a timely manner, the organization loses something critical to sustainable (not just safety) success – worker trust. Once you’ve lost that trust, regaining the active engagement of the workforce in any company initiative is extremely difficult. Poorly designed and implemented corrective action programs set you up to alienate the workforce which is something no company can afford.
  2. Duplication of effort – many companies capture corrective actions in multiple tracking systems which make it very difficult to close issues and inevitably leads to redundant, and thus needlessly expensive, actions.
  3. Overly specific fixes – many (unexamined) corrective actions do not address root causes or applicability company-wide. This is a guarantee of recurrent problems, not just where the problems were noted, but throughout the organization.
  4. Fixes that don’t fix – corrective actions are often closed without any follow-up to determine if the action was implemented as expected or if it provided the intended benefit. This represents a kind of wishful thinking that is inappropriate, if not irresponsible, when dealing with serious institutional issues.
  5. Haphazard actions – not all corrective actions are of equal significance or urgency. Failure to prioritize actions can lead to random or otherwise unexamined attention to relatively insignificant issues at the expense of timely attention to more significant and/or pressing issues.

 

Fixing the Fixes

Effective resolution of issues requires a formal process to ensure that appropriate corrective actions are developed to address problem root causes. Once corrective actions are captured they should be evaluated for scope (e.g., local or company-wide) and significance and routinely reviewed to ensure their continued relevance and timely closure. The complexity and detail of a corrective action program depends somewhat on the company size, complexity, hazards and risks. A commercial nuclear power facility, for example, will likely develop a considerably more intricate system than a company limited to warehousing and shipping non-hazardous products. Any effective corrective action program should, however, contain the following elements.

  1. Issue review – all issues, identified problems, and suggestions need review to ensure that associated corrective actions address root causes, are appropriately prioritized, are addressed throughout the organization wherever applicable, lessons learned are communicated, action owners are identified and due dates are established. There are many ways to achieve these ends but I’ve experienced considerable success by using a joint management/worker team assigned this responsibility. Having such a (well trained) team not only gives you a variety of relevant perspectives on what needs to happen and who is responsible but also helps avoid charges that some actions were not taken seriously or purposely buried by management. These teams were also typically charged with routinely communicating with the issue originators to ensure they know the status of associated corrective actions. Such communication is critical if you expect ongoing employee input.
  2. A single tracking system – any organization needs to know how it’s doing in regard to finding and fixing its problems and implementing identified improvements. It is challenging to do this if you must review numerous tracking systems to get the answer. Also, it is very difficult to get final closure on any issue if the related corrective actions redundantly reside in multiple data bases.   At times you may find you have “fixed” the same issue multiple times at a considerable and unnecessary expense. Finally, all corrective actions are in competition with each other for finite time and resources. Having all the actions visible in one place allows management to make informed budget decisions – and to prioritize.
  3. Prioritization - High consequence corrective actions require more analysis and oversight than simple fixes for low-consequence actions. Over focus on low significance issues is not cost effective and consumes resources needed for more serious problems. The following table (Loud, 2004, p.34) is provided as merely one (there are many) way to prioritize corrective actions as an aid to effective and efficient disposition.
    table-orange
  4. Follow-up – a follow-up process is necessary in order to have some degree of confidence that corrective actions are closed appropriately and actually fix problems. High priority actions should generally require such a post closure review. The rigor for lower priority actions needn’t be as stringent but the point is that you shouldn’t just assume/hope your problems are corrected without some review. A corrective action committee can provide this function but management must have reasonable assurance that important issues have been appropriately closed.
  5. Management oversight – top management must set expectations that problems will be identified and corrected and that opportunities for improvement are encouraged and handled appropriately. Goals, and associated metrics, for timeliness, number of open and overdue actions, and minimizing recurrence are effective status indicators but there are a multitude of ways to measure program effectiveness. The point is that management must establish the means to assure itself that the program is working as intended – not just as imagined.

Conclusion

Every organization should want to learn from its mistakes and improve as a result. In addition, good companies understand the value of getting their employees on board to identify improvement opportunities. This fosters engagement and ownership by the workforce that is invaluable, not only to safety, but to profitable and sustainable business operations. If the vast majority of your corrective actions were identified by the safety staff and/or outside regulators, rather than the workforce, you have problems that will require considerably more than an effective corrective action program.

Well-designed corrective action programs are essential for any organization dedicated to learning and improvement. Good intentions are not enough. Unless your company actively manages actions to correct its problems and implement improvement opportunities it will quite likely suffer needless recurrences and, at the same time, help promote a disengaged workforce. Hopefully this article will help some to avoid those pitfalls and develop corrective action programs that materially promote worker engagement and continuous improvement.

 

 

James Loud

Written by James Loud

Mr. Loud’s over 40 years of safety experience includes 15 years with the Tennessee Valley Authority (TVA) where he served as the supervisor of Safety and Loss Control for a large commercial nuclear facility and later as manager of the corporate nuclear safety oversight body for all three of TVA’s nuclear sites. At Los Alamos National Laboratory he headed the independent assessment organization responsible for safety, health, environmental protection, and security oversight of all Laboratory operations. Mr. Loud is a regular presenter at national and international safety conferences. He is the author of numerous papers and articles. Mr. Loud is a Certified Safety Professional (CSP), and a retired Certified Hazardous Materials Manager (CHMM). He holds a BBA from the University of Memphis, an MS in Environmental Science from the University of Oklahoma and an MPH in Occupational Health and Safety from the University of Tennessee.

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