The Importance of Reviewing Corrective Actions

Closing out a corrective action is a critical aspect of ISO compliance, but it can be easily forgotten.

In our work, it is not uncommon to see organisations identify a non-conformity, determine a root cause, implement a correction and corrective action, and then… that’s it. But there is a crucial next step: review the effectiveness of the corrective action.

Clause 10.2 of ISOs 9001, 14001 and 45001 explicitly requires organisations to do this. The story of a nonconformity does not end with the corrective action being decided and implemented, it ends with the corrective action being reviewed as effective after a reasonable period of time.

There are two important reasons for this: a) the solution may be the correct one, but is it still being followed months after the nonconformity was raised? and b) the solution may actually be ineffective. Let’s go through two examples for each.

Your solution is good, but is it being followed?

Under ISO 9001, an organisation might update an assembly checklist after reoccurring product defects. Initially, the defect rates drop, showing the corrective action is effective, but six months later, operators quietly revert to memory rather than using the physical checklist, and the defects resurface.

Under ISO 14001, a facility might introduce a dedicated waste management process to handle hazardous waste correctly, yet after a few months, workers stop segregating materials properly, perhaps because they forgot, or maybe production pressures increased at the expense of the corrective action.

And under ISO 45001, a site might mandate a new pre-use inspection log for forklifts following a near-miss. While the forms are filled out meticulously for the first few weeks, a review six months later reveals drivers are pre-signing the entire week’s sheet on Monday morning just to get moving faster.

Your solution is being followed, but is it solving the problem?

Then there are instances where the corrective action was implemented fully, but simply turned out to be ineffective at solving the underlying root cause.

Take an ISO 9001 example where a customer complaint arises due to incorrect billing addresses. The team’s corrective action might be to add a second person to manually double-check invoice entry, yet errors persist because the real issue was a glitch in the CRM software fetching outdated client profiles automatically.

Under ISO 14001, a company experiencing local noise complaints might install acoustic screening around an outdoor extractor fan. This solution is implemented correctly and consistently, but post-implementation monitoring shows neighbour complaints are continuing because low-frequency vibration is actually travelling through the building structure itself rather than through the air.

And under ISO 45001, an employer might respond to repetitive strain injuries by procuring ergonomic chairs for workstation operators. A follow-up review months down the line reveals injury rates haven’t changed at all because the primary stressor wasn’t seating posture, but rather the repetitive overhead lifting routine required by the assembly process.

Reviewing Corrective Action Effectiveness is Key

So, even if your corrective action is a good solution…

… or, even if your corrective action is being properly implemented…

… it is crucial you schedule a time to review its effectiveness. Schedule this review process a reasonable distance away to let it mature, but close enough that any deficiencies with the corrective action don’t go unnoticed too long. It might be an idea to review it on a regular basis, depending on the risk of the original nonconformity and the available capacity to do so.

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