SMS Pro Aviation Safety Software Blog 4 Airlines & Airports

All Corrective Preventative Actions Not Created Equal: Initial Mitigating Actions

Posted by Tyler Britton on Dec 4, 2017 5:55:00 AM

What are Corrective Preventative Actions (CPAs)

Corrective Preventative Actions Not Created EqualCorrective preventative actions are used to correct any undesirable element of your safety program. They are created in response to safety concerns, such as safety incidents, investigations, audits, etc. Their sole goal is to bring adverse elements of your SMS into an acceptable level of safety (ALoS). You might also see them called CAPAs (Corrective Actions, Preventative Actions).

They are the critical element of continuous improvement. This is why, for example, the fifth element in the FAA’s Safety Assurance process is interchangeably called “Continuous Improvement” and “Corrective/Preventative Actions.”

CPAs can be an element of proactive risk management

  • Inspections;
  • Audits;
  • Safety case; or
  • Change management.

CPAs can also be an element of reactive risk management:

  • Hazard occurrence (safety incident);
  • Risk occurrence (safety accident); or
  • New oversight agency regulation.

CPAs are most often created and facilitated by subject matter experts, which most often are department heads.

Different Types of Corrective Preventative Actions

There are three main (parent) types of CPAs:

  • Corrective actions – used to “fix” safety concerns;
  • Preventative actions – used to prevent occurrence of safety concerns
  • Detective actions – used to identify safety concerns before they pose a threat (hazard occurrence)

That being said, in real world environments CPAs are more often a combination of these parent types, such as:

  • Corrective/Detective;
  • Preventative/Detective;
  • Corrective/Detective/Preventative;
  • And so on.

Moreover, corrective preventative actions can be classified as:

  • Long term: passive, long term fixes to the SMS (such as a new bird flock detection device, job checklist, etc.)
  • Short term: temporary changes to fix the SMS (SMS training, policy review, official warning, etc.)
  • Initial mitigating actions: Important actions taken immediately in response to high risk issues, in order to mitigate the high-risk threat (damage control, emergency response, etc.).

Most people have heard of short/long term CPA types, but initial mitigating actions (may go by other names) are an emerging classification of CPAs in SMS programs.

What are Initial Mitigation Actions

Initial mitigating CPAs are a special classification for CPAs the denote corrective/preventative actions taken in immediate response to high risk safety concerns. The purpose of this CPA classification is to:

  • Identify the “critically” important CPAs;
  • Document CPAs that should be considered more highly than other CPAs (i.e., like key performance indicators vs other performance indicators); and
  • Communicate to the person assigned the CPA that this CPA is top priority.

Initial mitigating actions should be completed as soon as possible in response to high risk safety issues (such as same day, one day, or two days).

They can be either short term or long term – but this is irrelevant – so long as the initial mitigating action(s) bring the safety concern into a manageable level of safety. After that, management can use “regular” CPAs to bring further reduce the issue into an ALoS range.

When to Use Initial Mitigating Actions for CPA Type

Initial mitigating actions should be used in response (reactive risk management) to an initial high-risk issue classification. In SMS Pro, Initial Mitigating Actions are a selectable option during CPA creation; when the CPA is created users will clearly be able to see that it is of this type. In your program, you will simply need to clearly indicate that the CPA is an Initial Mitigating Action.

With initial mitigating actions, it’s a standard practice to set a hard due-date for all CPAs of this type, such as:

  • Due same day as assignment;
  • Due within one day of assignment; or
  • Due within two days of assignment.

In SMS Pro, this hard-due date is equal to the closure date for the issue. Again, the point is complete this type of CPAs as soon as possible.

Once you begin classifying CPAs as this type, you can track performance for these critical CPAs. For example, in SMS Pro, when users choose to use initial mitigating actions, they can see On-Time Completion performance for initial mitigating actions.

This gives safety managers a strong basis for assessing critical-issue response performance.

Final Thought: Implementing Initial Mitigating Actions in Your SMS

Implementing this classification type is very easy. You simply need to:

  • Documenting when and how they will be used;
  • Communicate this new type of CPA to employees, including why it’s being implemented and how employees will know if they have been assigned this CPA type; and
  • Ensure a consistent way of clearly marking this CPA assignment type.

Adding this type of CPA to your organization provides an excellent way for you to separate types of CPAs that are the “most important.”


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Topics: 3-Safety Assurance

Site content provided by Northwest Data Solutions is meant for informational purposes only. Opinions presented here are not provided by any civil aviation authority or standards body.

 

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