Monday, 22 October 2012

Correction vs Corrective Action in an EHSMS

An incident is a situation where some kind of harm occurs (or could occur); a nonconformity is defined as “non-fulfillment of a requirement”.  There is often a relationship between the two – but not always.
Similarly, correction and corrective action are NOT the same.
These are defined terms that have been taken from the quality world and applied to EHS management systems.  They are also an entrenched part of registration audits so it is important to understand how registrars define them (i.e. their ISO 9000 definitions).  When registrars issue corrective action requests (CARs), they often request information on any corrections done as well as a description of the corrective action planned.
A correction is defined as “action to eliminate a detected nonconformity”.  In the quality world, correction is often referred to as containment (as in preventing nonconforming product from reaching the customer).  Correction in a QMS can consist of repair, rework, scrapping the product, etc.  The first action taken is often segregation and control of non-conforming product.
This quality concept was incorporated into ISO 14001 as correction and mitigation – as in taking action to mitigate environmental impacts (see Section 4.5.3 a).  The same concept was also incorporated into OHSAS 18001 as correction and mitigation – as in taking action to mitigate OH&S consequences (see Section 4.5.3.2 a).
In all the standards, the focus of correction is on the immediate fix.
corrective action is defined as “action to eliminate the cause of a detected nonconformity or other undesirable situation.” A note to this definition in ISO 9000 states that “there is a distinction between correction and corrective action.”  The distinction is the focus.  In corrective action, the focus is on what CAUSED the nonconformity.
Since the focus of corrective action is on causation, some type of root cause analysis is a prerequisite to defining the appropriate corrective action.

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