Corrective Action Plan (CAP)
The Corrective Action Plan (CAP) is a structured and scheduled plan that outlines how an operator will fix the problems or weaknesses found during a SEMS audit. The CAP is created after the final audit report is issued and must directly respond to each deficiency identified. This plan plays a key role in improving the safety and environmental performance of the operation.
- Deficiencies are gaps or failures in the management system that reduce its effectiveness. These can include both Nonconformances and Concerns. A nonconformance means a requirement was not met, while a concern suggests that a condition exists which could lead to a future failure if not corrected.
- Concerns are treated as deficiencies by BSEE because the auditor has determined that extra or improved controls are needed to keep the SEMS program effective. These controls help prevent future issues and improve the reliability of safety and environmental processes.
Operators must submit a copy of the Corrective Action Plan (CAP) to the Bureau of Safety and Environmental Enforcement (BSEE) within 60 days after the audit is completed. This deadline ensures timely follow-up and accountability.
The CAP must clearly state the name and job title of each person who is responsible for fixing a specific deficiency. Assigning responsibility helps ensure that corrective actions are carried out properly and on time.
BSEE will review the submitted CAP as quickly as possible. If BSEE finds that the schedule is not realistic or that the plan does not fully address the audit findings, they will notify the operator. In that case, the operator must revise the plan to meet BSEE’s expectations and ensure all deficiencies are effectively corrected.
Having a complete and timely CAP helps maintain compliance with federal regulations and improves the overall strength of the SEMS program.
Ref: Title 30 SECTION 250.1920
Knowledge Check Choose the best answer for the question.
6-3. When should operators provide BSEE with a copy of the Corrective Action Plan (CAP) for addressing the deficiencies identified in the audit?
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