Corrective and preventative actions are generated from varying sources including safety meetings, inspections, accident investigations, unsafe act and unsafe condition reporting and from audits, and are simply measures that need to be undertaken to ensure that a particular requirement is implemented.
These actions can be either corrective actions or preventative actions;
- a corrective action means a situation has been re-instated to its original state, so replacing a machine guard that was improperly removed that caused an injury is a corrective action;
- a preventative action will put into place arrangements which will prevent a re-occurrence, to stop the machine guard from being removed improperly in the first place.
An action that many think of as “common sense” and “simple” continues to appear on 3rd party audit reports and OSHA/EPA citations year after year. So why is something which is “common sense” and “simple” so difficult to comply with? Often times we make something simple too difficult for our own good. Lets examine the PSM/RMP requirements for tracking “recommendations” from process safety activities:
1910.119(e)(5) The employer shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.
1910.119(j)(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.
1910.119(m)(5) The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.
1910.119(o)(4) The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
Use of a tracking form is considered an accident prevention best practice
By using a tracking form, all corrective or preventative actions, can be tracked for compliance, or more importantly for quality of action taken.
With all of this in mind, look at the corrective action tracking form below, and see how it can aid your organization and corrective safety measures:
Accident Prevention Planning