Operational Guide · Registers & Logbooks

# Corrective and Preventive Action (CAPA)

The action that truly closes the loop: how to plan, document and verify the effectiveness of a CAPA so the Non-Conformity does not recur.

ISM Code CAPA root cause analysis continuous improvement

## Operational Explanation

A Corrective Action eliminates the cause of a Non-Conformity that has already been identified; a Preventive Action eliminates the cause of a potential Non-Conformity that has not yet occurred. Together they form the CAPA cycle that operationalises the continuous improvement principle required by the ISM Code.

A well-executed CAPA does not simply "fix the symptom": it addresses the root cause, has an owner, a deadline and — a point often overlooked — an effectiveness verification carried out after a suitable interval.

## Regulatory Reference

ISM Code, par. 1.2.3.2 ("to establish safeguards against all identified risks") and Section 9: the Company must establish procedures for implementing corrective actions.

## Scope of Application

Applies to every Non-Conformity (minor or major) and every risk identified as potential, both on board and at the Company's shore offices.

## Procedure / How to Complete It

1. Define the action starting from the root cause identified in the NC analysis, not from the observed symptom.
2. Assign a clear owner and a realistic deadline for implementation.
3. Distinguish whether the action is corrective (on an NC that has already occurred) or preventive (on a risk identified but not yet manifested).
4. Implement the action and document its execution (e.g. a procedure change, training, technical intervention).
5. Verify the effectiveness of the action after a defined interval, before considering the CAPA closed.
6. If the verification shows the problem persists, reopen the analysis and re-plan the action.

## Practical Example

Example: NC for an inconsistent sludge balance. Root cause: no dedicated form for recording internal tank-to-tank transfers. Corrective action: introduction of a dedicated form in the PMS. Effectiveness verification: after 2 months, the sludge balance verified consistent across all records. CAPA closed.

## Real Cases

A frequent error found in certification audits is the premature closure of CAPAs, without waiting the necessary time to verify their effectiveness: the NC is formally closed, but the underlying problem resurfaces a few months later, generating a new NC on the same topic — a signal auditors immediately recognise as a systemic weakness of the SMS.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Corrective action addressing the symptom, not the root cause | The NC recurs in similar form | Use structured root cause analysis techniques (5 Whys, cause-and-effect diagram)
No effectiveness verification scheduled | Impossible to know whether the action actually worked | Always set a verification date, even months ahead
Preventive actions neglected in favour of corrective ones only | Risks identified but not yet manifested remain without mitigation | Treat preventive actions with the same discipline as corrective ones

## PSC Observations

Certification auditors and, indirectly, PSCOs assess the quality of CAPAs as an indicator of SMS maturity: generic actions, without an owner or an effectiveness verification, are among the most common observations in external audits.

## Operational Tips

- Never close a CAPA on the same day the action is implemented: time is needed to verify its effectiveness.
- Explicitly distinguish corrective from preventive in the record, to facilitate trend analysis at the Management Review.
- Involve whoever reported the NC/Near Miss in the effectiveness verification: they are often best placed to judge whether the problem is truly resolved.

## Checklist

- Root cause identified (not just the symptom)
- Owner and deadline assigned
- Action implemented and documented
- Effectiveness verification scheduled and carried out
- Verification outcome recorded before formal closure

## FAQ

What is the difference between a corrective and a preventive action?
A corrective action eliminates the cause of an NC that has already occurred; a preventive action eliminates the cause of a potential NC, identified before it actually materialises.
How much time must pass before verifying a CAPA's effectiveness?
There is no fixed period in the ISM Code: it depends on the nature of the action. Standard practice is to define the verification interval already at the planning stage, proportionate to the risk.
Can a CAPA remain open beyond the external audit?
Yes, if the action requires a longer timeframe (e.g. technical work in dry dock); what matters is that progress is documented and communicated to the auditor.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Non Conformity (NC) Management Internal SMS Audit Near Miss Reporting

### Leave feedback

Help us improve the platform during the beta -- it takes thirty seconds.

How useful do you find the platform so far?
Comment (optional)
Sign me up for the newsletter
Role