Corrective Action That Fixes the Symptom
A previous audit raised a major nonconformity: torque values on flange bolting were not recorded. The client's corrective action response, received within the required 30 days, states: 'Toolbox talk conducted with all fitters on the importance of recording torque. Revised form issued. All fitters retrained.' Attached are a sign-in sheet with nine signatures and a copy of the revised form. The client's workforce includes fourteen fitters across two shifts, and the revised form has been in use for two weeks. Your procedure requires the response to include root cause analysis, correction, corrective action, and evidence of effectiveness before closure.
1. Evaluate the adequacy of this response and state what you would do.
Read the worked answer
The response addresses correction and awareness, not corrective action.
Gaps:
- No root cause analysis. 'People forgot' is a restatement of the problem. Why was recording not possible or not checked? Was the form impractical, was there no verification step, was there time pressure on the shift?
- Training is not a systemic fix. If the cause is a process design or verification gap, retraining will not prevent recurrence.
- Incomplete coverage. Nine of fourteen fitters signed; the second shift is unaddressed.
- No effectiveness evidence. Two weeks of a revised form is not evidence the recording now happens; you need a sample of completed forms checked against bolted joints.
Action: do not close. Return the response with specific deficiencies and request a revised root cause analysis and a verification-based effectiveness check. Keep the CAR open and record the resubmission date; if the required timeframe lapses, escalate per procedure.
2. What would adequate effectiveness evidence look like?
Read the worked answer
It would let you conclude the recording now happens reliably, not that people were told to do it. For example: a sample of recent jobs where torque records exist for every bolted joint, cross-checked against the job's bolting schedule; a supervisory verification step with its own records; and a spot check at the point of work showing the form in use on both shifts. The client should also show that the root cause they identified is actually addressed by the change they made - the evidence must map to the cause, not just to the symptom.