Operational guide · SMS process

Corrective and Preventive Action (CAPA)

The action that truly closes the loop: what the ISM Code actually requires — corrective action under Section 9 — and where the CAPA cycle used by many Companies comes from instead.

ISM CodeCAPAroot cause analysiscontinuous improvement

Operational Explanation

What the ISM Code requires is corrective action. Section 9.2 requires the Company to establish «procedures for the implementation of corrective action» in response to non-conformities, accidents and hazardous occurrences: action that eliminates the cause of a non-conformity already identified.

The Code does not prescribe the acronym CAPA or a separate process called “preventive action”. It does require measures to prevent recurrence (9.2) and assessment of identified risks with appropriate safeguards (1.2.2.2). The Company may organize these activities within a CAPA cycle; choosing a name or form does not make those obligations optional.

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, Section 9.2: the Company must establish procedures for the implementation of corrective action, including measures intended to prevent recurrence. Read together with par. 1.2.2.2 ("assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards"), which is the Code's risk-based obligation. Distinguish the Company’s CAPA structure from ISM correction and prevention obligations.

Amended provisions: MSC.273(85) · IMO ISM.

Scope of Application

Report and analyse non-conformities, accidents and hazardous occurrences on board and ashore; determine actions appropriate to the findings and risk. Identified risks require safeguards before an event occurs as well. Also follow the SMS-defined CAPA process where adopted.

Procedure / How to Complete It

Assess and contain risk promptly; distinguish immediate correction from action on the cause.
Establish the cause and choose proportionate measures with an owner and deadline.
Agree required conditions and timing for external findings; document any accepted compensating measures.
Implement the action and collect technical, training or procedural evidence.
Verify effectiveness using risk-based criteria and timing; completing an intervention alone is insufficient.
Close with a justified outcome or revisit the analysis if results are inadequate.

Practical Example

Learning example: an inconsistent sludge balance requires investigation of actual quantities, tanks and operations, not artificial reconciliation of forms. PMS support may help but does not replace the Oil Record Book where required. Preserve correction traceability and check actual residue management under MEPC.1/Circ.736/Rev.2. Determine causes and effectiveness evidence after establishing the facts.

What Typically Goes Wrong

Closing a CAPA solely on a statement of completion can leave causes unresolved. Verify the outcome with relevant evidence; if the problem recurs, revisit the analysis and measures. The time required depends on risk and the planned effectiveness check.

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
The Company's own SMS procedure not followed where it provides for a preventive branch	Risks identified but not yet manifested remain without mitigation	Treat preventive actions with the same discipline as corrective ones

What the PSCO Checks

Auditors verify actions, implementation and follow-up against the Code and SMS. A PSCO may examine actions relevant to shipboard deficiencies. Distinguish their mandates: an open CAPA neither replaces required rectification nor authorizes impermissible operating conditions.

Operational Tips

Define effectiveness criteria during planning: the required time depends on action and risk, not a universal ban on same-day closure.
Distinguish containment, correction and prevention of recurrence.
Involve competent personnel and process users; self-declaration must not replace evidence.

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

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

Are correction and corrective action the same?

Correction addresses the observed condition; corrective action treats the cause and prevents recurrence. A CAPA process can also handle potential risks under the SMS.

How long before checking effectiveness?

Long enough to obtain evidence appropriate to the risk and action, while respecting external conditions. The Code sets no single interval.

Can the work wait until dry dock?

Informing the auditor alone is insufficient. Assess safety and requirements, apply controls and obtain applicable authority/RO acceptances or approvals. An open CAPA does not authorise operation outside permitted conditions.

Corrective and Preventive Action (CAPA)

Operational Explanation

Regulatory Reference

Scope of Application

Procedure / How to Complete It

Practical Example

What Typically Goes Wrong

Common Mistakes Mistake Library

What the PSCO Checks

Operational Tips

Preparation checklist

FAQ

Related Topics