Whether its safety, quality or environmental management, a key indicator of an organisation’s performance is how it manages its corrective and preventative actions. These arise, usually as a result of one of three things occurring:
- A workplace incident or complaint,
- An audit or inspection identifying a non-conformance with system requirements, or
- Worker identified issues or improvement opportunities.
The corrective component is an action intended for immediate rectification of the incident or issue. The preventative component is an action or actions that may take some time to be implemented and are intended to prevent recurrence. Regardless of how these are identified, it is vital that accountability for the implementation of corrective and preventative actions is held at the appropriate level and actions are completed in a timely manner.
It’s a matter of risk……..
To help understand what “appropriate” and “timely” mean in this context, it comes down to the level of risk associated with the activity that led to the incident, issue, complaint, non-conformance or hazard.
For example, for an incident where a worker has fallen off a roof and sustained a broken leg, it is reasonable to say that the activity of working on the roof is high or even extreme risk. Let’s also say that one of the preventative actions arising from the subsequent incident investigation is the installation of fall-prevention barriers (which were not in use at the time of the incident). Given the level of risk of the activity (high/extreme), the appropriate accountability for ensuring the installation of the barriers is most likely to be a Senior Manager or even Executive Manager, depending on your organisation’s size and risk management system. A commonly used term for the person and role in this instance is the “Risk Owner”. Why? Because they have the decision-making authority and budget to allocate resourcing to complete the nominated action. Again, depending on the organisation, this person and role may also have duties under the WHS Act that obligate that Manager to ensure the health and safety of persons at the workplace.
Defining what constitutes a “timely” completion of the action is dependent not only on the level of risk (i.e. the greater the risk, the sooner the need for completion), but needs to consider the organisation’s wider needs. In the example above, how essential to the organisation is the need for people to work on the roof? Can another method or access be adopted in the interim? What risk is posed by not completing the action within a certain time-frame? Does the organisation have the knowledge and resourcing (personnel and money) to complete the action? The timeframe for completion of corrective and preventative actions is therefore a product of risk, organisational needs knowledge and resourcing.
How often does your organisation look at its Open Corrective and Preventative Actions?
It’s often said that near-hits and incidents provide learning opportunities to take actions that prevent something more serious from happening. How do you think the WHS Regulator would respond if the organisation in the example above had a second person fall from the roof prior to the completion of the installation of the fall-prevention barriers? You’d have to ask, how were workers allowed to access the roof given the barriers were not yet installed. And then it comes out that no-one was routinely monitoring the organisation’s open corrective and preventative actions to ensure these remained on track and progressing towards completion. How often does your organisation look at its open actions – particularly those that relate to a high or extreme risk? Do you maintain a Corrective Actions Register or other solution that tracks and escalates open actions? If you are not reviewing these at least monthly and ensuring they remain on track, and following up when they are not, you could be leaving yourself open to further incidents, complaints and legislative breaches.
Please contact QRMC for more information.