Organizations routinely develop corrective action plans (CAPs) for any number of reasons, including discovery of inadequate or outdated processes, incomplete or partial policies and procedures, or gaps related to employee safety and security.
Organizations with regulated transportation operations may find themselves in the position of having to develop CAPs reactively rather than proactively, however, due to a failed New Entrant Safety Audit or a Compliance Review or Focused Review that resulted in a rating of less than Satisfactory.
When this occurs, the first question to ask is, “Why did the violation occur?” Was there a lack of training? A lack of knowledge about the regulatory requirements? Unclear roles and responsibilities with the company? Thoroughly understand the gap that led to your organization’s area of non-compliance.
Another area to look at is whether a lack of management controls resulted in the incident. Are there insufficient resources allocated for oversight of FMCSR compliance and CMV safety? Are the processes to qualify drivers gapped or lacking timeliness? Strategically outline which safety management processes within the safety management cycle are best suited to address identified non-compliance.
Next, you’ll have to determine what you’ll do to ensure future compliance. For instance, have technological solutions such as in-cab camera technology or vehicle stability control been adopted to mitigate accident frequency and severity? Has a process been developed and deployed to routinely validate driver’s records of duty status accuracy with use of various categories of supporting documents? Self-audit your operation for full compliance and provide the results of that self-audit to substantiate your corrective actions.
Finally, you’ll need to submit your CAP to both the Field Office for FMCSA in your business’s state of domicile and the FMCSA Service Center for your applicable region. Time is of the essence, and it is recommended that CAPs be developed and submitted no later than 15 days after notice from FMCSA of a proposed Conditional or Unsatisfactory rating.
Identifying, documenting, and following through on corrective actions is a sign of organizational health and resilience and is indicative of a thoughtful, proactive approach to prompt resolution of any area of concern or opportunity for improvement.