Question: What is a corrective action?
Answer: According to the Business Directory, a corrective action is the Identification and Elimination of the causes of a problem, thus preventing their recurrence.
So, how is this achieved?
There are three (3) areas that need to be addressed when developing a corrective action for an event that takes place at the work place. These areas are:
1. Immediate/Specific Action – This is the first element of the corrective action equation. What is done right after an event happens? Is the scene frozen? Has any or all injured persons been taken for medical treatment? Has the upper management team been informed of the event? Does the client know?
2. Preventative Action – This is the second item in the corrective action equation. This is the change implemented to address a weakness in a management system. It is a proactive process to identify opportunities for improvement rather than a simple reaction to the identified problem. Can the hazard or the root cause of the event be eliminated to prevent the reoccurrence? Is there a procedure that has some holes in it? Does a new policy need to be put in place? Can we add or achieve better protection with different Personal Protective Equipment (PPE)? Using the Hierarchy of Control(s), this is where the creation of the corrective action is done.
3. Systemic Action – This is the third item in the corrective action equation. Simply put, this action is to help ensure the effective implementation of the preventative action and related measures related to mitigating the risk to ensure the event will not take place again. Another way to look at this is to ask the following: Are the action items put in place to prevent reoccurrence auditable? How can I prove the effectiveness of the corrective action?
Too often a summary of the event at a toolbox talk or a safety meeting is viewed as the corrective action to the event; however, this is where safety professionals and management teams are mistaken. A review of an event is good, to inform the craft of what happened and what the findings of the investigation was, but can we truly call this the corrective action? The answer to that is simple, no. If we follow the three step equation to develop the corrective action, more education and awareness will come from it.
Let’s use the new tool that was laid out to show how to build an effective Corrective Action.
The Event
A 2nd year apprentice scaffolder was tasked with using a banding tool to bundle up piles of various lengths of scaffold tubes. The worker organized all the tubes into bundles of equal size and according to length. Once the bundles where organized the worker took the banding tool and began to band the bundles.
One of the bundles that the worker banded was sitting on an angle on the pallet it was resting on. The worker grabbed the bundle by the bands with the intention of making it straight on the pallet for safe transport with the fork lift.
When the worker did this the banding he was holding on to, cut through his gloves causing a laceration to the inside of his palm.
The worker screamed which got the attention of another worker. The second worker, using a radio called for a supervisor and administered first aid. When the supervisor came to the scene the worker was transported to an on-site medical center and received seven (7) sutures.
The investigation found the following:
- The worker that was using the banding machine said that he was told that the banding material was sharp, but failed to identify it on his Job Safety Plan.
- In the workers personal file, there was a document that stated the worker was trained in the proper use, care and maintenance of the banding machine.
- The worker was deemed competent to use the banding tool.
- There was no Task Specific Hazard Assessment for the use of a Banding tool.
- The gloves the worker was wearing were only a cut level #2 glove.
The following outlines the Corrective Action Plan for the event. This document is what can be used at a toolbox or safety meeting to review the findings and go over the corrective actions to ensure that this event is not duplicated in the future.
Date: January 23, 2018
Location: Plant ABC, Somewhere in Canada
Project: Maintenance
Event Classification: Medical Aid
Event Summary: A 2nd year apprentice scaffolder was tasked with using a banding tool to bundle up piles of various lengths of scaffold tubes. While trying to straighten a banded pile the worker cut his hand on the edge of the banding he was pulling on. **Note - This is just a very brief summary of the event because the full event summary is in the incident investigation report**
Immediate/Specific Action Taken: The scene was frozen immediately, supervision and the client were both informed of the event. The worker was taken to the on-site medical facility and was treated for his laceration. **Note – Just identified what took place right after the event occurred**
Preventative Action Taken: The worker was taken for an A&D test to ensure that drugs and/or alcohol was not a factor in the event. A review of the material handling procedure to be completed to ensure that it addresses the stacking of banded material on pallets for transport. A Task Safety Analysis (TSA) will be created and all workers will review and sign off on the document before the use of the banding machine continues. New gloves to be ordered to ensure they meet at minimum a cut level #4 to be used when handling banding. **Note – Notice the Hierarchy of Control(s) used the hazard cannot be eliminated completely so administrative and PPE are reviewed and changed to support the corrective action**
Systemic Action Taken: All field workers will identify any sharp edges associated with their task in red pen on their Job Safety Plan (JSP/FLHA) for the following 4 shifts to help stimulate awareness. Supervisors will conduct field audits to ensure workers are wearing the correct PPE when using the bander. Safety Department to ensure that all field workers are made aware of the TSA and have signed it at the next safety meeting (01/28/2018) **Note – All Items can be audited to see if the effectiveness of this corrective action plan works as well as dates for reference if in the event an outside auditor wants to review**
In summary, this is an effective way of being able to track, log and trend your companies corrective actions, as well as audit the plan to see if it works.