Who Should Determine Safety Corrective Actions?

Who Determines Your Organization's Safety Actions?

Who determines safety actions in your organization? In many early-stage safety programs, the safety team plays a dual role—identifying gaps through inspections, audits, and investigations, and then independently deciding on corrective actions and deadlines. While this might seem efficient, it actually creates a critical flaw: it shifts responsibility for safety risk ownership away from the leaders and departments that have the authority, resources, and operational control to implement real, lasting mitigation. Additionally, it places an unrealistic expectation on safety professionals to prescribe solutions without necessarily having the deep operational or technical expertise to determine the most practical and effective fixes.

To understand why this approach falls short, let’s break down some key safety assurance processes and explore a better way to assign responsibility for safety actions. 

Defining Key Terms and Processes

Safety findings and corrective actions are integral to the safety assurance process of a safety management program. Safety assurance identifies and analyzes trends to discover safety gaps, ineffective risk controls, or non-conformance to policy or procedures.

Once gaps are identified, they become safety findings, which require corrective actions to mitigate. After these actions are completed, the work isn’t done, as they must be monitored to ensure long-term effectiveness.

Let’s define some terms and concepts regarding safety findings and corrective actions before I move on:

• Finding: A gap in the organization's safety performance.

• Finding Owner: A leader responsible for the affected department or process.

• CAPA or Corrective Action (Corrective Action and Preventive Action): Actions designed to mitigate a safety finding.

• Action or CAPA Owner: A person within the department responsible for implementing corrective actions.

• Root Cause: Analysis identifying why a finding occurred.

• Causal Factors: Contributing elements leading to the finding.

Triggers for Safety Findings and Corrective Actions

Corrective actions result from several oversight processes, including:

• Workplace inspections

• Operational audits and observations

• Safety evaluations

• Safety risk control monitoring (identifying risk control degradation)

Additionally, organizational monitoring and changes may also trigger corrective actions through:

• Safety performance indicator trends

• Key performance indicator trends

• Risk index trends

• Leadership requests for process reviews

Furthermore, triggers can stem from report investigation, such as reporting from:

• Incidents, accidents, and near misses

• Employee safety concerns (reported through voluntary reporting processes)

• Suggestions for improving safety processes

Classifying Safety Findings for Prioritization

A safety finding should be prioritized based on the risk it poses. The following is a simple way to prioritize findings which gives a timeline for when a corrective action plan should be identified and agreed (note: this is not a timeline for when the actions themselves need to completed, but rather just a plan in place for addressing the finding):

• High Priority: Significant safety risk requiring immediate containment actions and a full corrective action plan within 3 days.

• Medium Priority: Moderate risk requiring a full correction action plan within 10 days.

• Low Priority: Minimal risk requiring a full correction action plan within 14 days.

Why the Safety Team Shouldn’t Determine Corrective Actions

If the safety team is assigned as the safety finding owner and therefore is required to determine corrective actions against that safety finding, it assumes that:

1. The Safety Team Has Authority Over Resources

2. The Safety Team Has Technical Expertise

3. The Safety Team Owns the Safety Risk

The safety team often lacks financial or operational authority to implement corrective actions for most safety findings identity throughout the organization. If the safety team does not have authority over the resourcing of the process or program with the safety finding, the safety team should not determine the action for that finding. Further, if the safety team does not have authority over the affected system or process there is a very good chance that they may not fully understand it, which could lead to inefficient or impractical solutions. And finally, if you read my article titled “Who Owns the Safety Risk?”, you will know that placing overall ownership of safety risk on the safety team is a flawed approach in general. Instead, ownership should rest with process owners who have control over necessary resources.

Establishing the Correct Ownership Structure

To address these challenges, corrective actions should be owned by leaders within affected departments, as they possess the necessary authority to allocate financial, physical and human resources, have direct knowledge of how to close the identified safety gaps properly and most efficiently and are responsible for the prioritization of work in their areas.

The safety finding owner should work with subject matter experts, who may ultimately become corrective action owners, to develop CAPA plans, and ensure alignment with root causes and causal factors. The corrective actions should be assigned to action owners who are best positioned to implement them efficiently.

CAPA Plan Development

Now that we know who should own the finding and corrective action plan, let’s review what a proper corrective action plan looks like. A robust plan should include:

• Identification of the Action Owner responsible for implementation.

• Clear linkage to causal factors contributing to the safety finding.

• Specific corrective actions to address the gap.

• Defined completion dates based on realistic timelines agreed upon by all stakeholders.

By involving process owners in action planning and execution, organizations foster greater buy-in, more effective solutions, and a more sustainable safety culture.

Conclusion

When a safety finding is identified, responsibility must be assigned to the right leader within the organization. Most often, this is not a member of the safety team. That correct leader should have:

• Authority for resources over the affected process or system

• Knowledge of how to implement the necessary corrective measures to be most effective and efficient

• The ability to assign appropriate action owners for mitigation efforts

Corrective actions should be determined by the leader who is the process owner of the department or program and whose technical expertise will ensure practical, efficient, and sustainable safety improvements, with buy-in from the department. By adopting this approach, the safety risk is put on the correct leader and safety team is not put in a position of owning correction actions that they don’t have authority over or perhaps even the proper technical expertise to correct effectively. 

For a deeper dive into safety risk ownership, check out my video: Who Owns the Safety Risk?