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