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.
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.
Preventive action does not appear in the ISM Code, and neither does the acronym CAPA. Both come from quality-system practice — ISO 9001 — which in turn removed preventive action in its 2015 revision, replacing it with risk-based thinking. Many Companies nonetheless run a combined NC / corrective action / preventive action cycle in their SMS, and doing so is legitimate and often useful: what matters is knowing that it is a Company choice built on a quality-management model, not a requirement of the Code. An auditor will verify corrective action against Section 9; the rest is verified against the Company's own procedure, if the Company has undertaken it.
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. Preventive action and the CAPA acronym belong to ISO 9001 and to Company quality procedures, not to the ISM Code.
Scope of Application
Corrective action applies to every non-conformity, accident and hazardous occurrence, on board and at the Company's shore offices. Where the Company has adopted a full CAPA cycle in its SMS, the preventive branch also covers risks identified as potential — as a commitment the Company has taken on itself, on which it will be audited against its own procedure.
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.
What Typically Goes Wrong
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
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.
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
Related Topics
Last substantive revision of this page: 29 August 2026 · page fingerprint 4a90df0ae485