Use of Audit Program Results

There are several key steps that must be initiated to implement a corrective action program. The most critical one, as seen in review of the Federal Sentencing Guidelines, is to communicate the problem to responsible officials, develop solutions, and implement them in a timely manner. 

Based on experience, the most effective approach to corrective action is to extensively involve those personnel and organizations where problems were detected, since they are the ones who can most easily identify practical solutions and agree to implement them quickly. This approach is far more effective than having solutions imposed from the outside. 

Corrective Action Teams (CATs) have been used widely in manufacturing environments during the last ten years. The composition of the CAT may vary from company to company. In the case of several semiconductor companies, its composition has evolved as their compliance programs have matured. A CAT may be composed of the following functional areas  

Our experience indicates that the CAT should include only those functions and personnel necessary to develop corrective actions and who have responsibility for implementation, both from a management and complianee perspective. 

A key objeetive of the CAT is to correct the deficiencies identified as part of the environmental compliance audit program through the use of sound management systems and controls. The CAT must have the following eharacteristics, including the responsibility, authority, and aceountability to act  

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