Last Updated on October 13, 2025 by Hafsa J.

Corrective Action Planning Post FSSC 22000 V6 Audit

Let’s be real—finishing your FSSC 22000 audit doesn’t mean you’re off the hook. In fact, once that audit report lands on your desk, the clock starts ticking.

I’ve worked with enough food businesses to know that most teams either breathe a sigh of relief… or go into silent panic mode when nonconformities pop up. And under FSSC 22000 Version 6, the pressure is even higher. Auditors expect more than just a band-aid fix. They want to see that your team actually understands what went wrong—and that you’ve put something solid in place to make sure it doesn’t happen again.

Here’s the hard truth: most corrective action plans fail not because people don’t care—but because they don’t dig deep enough. I’ve seen CAPs that look good on paper but fall apart in the field because they didn’t address the root cause, didn’t involve the right people, or just got buried in a spreadsheet and forgotten.

This guide is here to change that.

We’re going to walk through exactly how to handle nonconformities after your FSSC 22000 audit—from your initial response to writing a corrective action plan that actually works. I’ll show you what strong plans look like, what auditors expect, and how to avoid the weak fixes that get flagged again and again.

Whether you’ve just wrapped your audit or want to get ahead before the next one, you’re in the right place.

Let’s get into it.

Understanding the Corrective Action Requirement in FSSC 22000 V6

Here’s something I’ve noticed across multiple facilities—most teams understand what a corrective action is in theory, but under FSSC 22000 Version 6, the expectations have evolved. It’s not just about fixing what’s broken. It’s about showing that you understand why it broke, what you’re doing about it, and how you’re going to make sure it doesn’t happen again.

In other words, the standard is raising the bar—and so are the auditors.

What the Standard Actually Requires

Let’s break it down. The core requirement comes from Clause 10.2 of ISO 22000:2018, which is the backbone of the FSSC 22000 scheme. It says your organization must:

• React to the nonconformity (containment and correction)

• Evaluate the need for action to eliminate the cause

• Implement the necessary actions

• Review the effectiveness of the actions taken

• Make changes to the FSMS if needed

• Keep all of this documented

Simple in theory—but in reality, it requires clear ownership, structured thinking, and documented follow-through.

What’s Different in Version 6?

FSSC 22000 Version 6 has added sharper expectations in a few areas:

• Linking corrective actions to food safety culture: Are your findings a one-off or part of a pattern?

• Emphasis on verification of effectiveness: Auditors don’t just want to see action—they want to see proof that the fix worked.

• Integration into management review: Significant nonconformities should feed into top management decisions.

• Digital traceability: More facilities are using tools that track CAPs in real-time—auditors are beginning to expect faster visibility and less ambiguity.

Why It Matters

If you’re still responding to findings with one-liners like “retrained staff” or “reminded operators,” you’re falling behind. Not only are you risking repeat nonconformities, but you’re also sending the message that your system might look good on the surface—but lacks depth when challenged.

Auditors are trained to see through quick fixes. What they respect is a clear, honest, well-reasoned plan that shows ownership and learning.

Immediate Response vs. Long-Term Correction: Knowing the Difference

Right after an audit wraps, it’s tempting to jump straight into damage control. I’ve seen teams scramble to “fix” findings the same day, just to look responsive. But here’s the thing—not every corrective action needs to be immediate, and not every quick fix counts as a true solution.

Understanding what needs attention now, versus what needs deeper analysis, is key to avoiding rushed responses that don’t hold up under scrutiny.

What Needs to Happen Within the First 24–48 Hours

If you’ve got a major nonconformity, especially one related to product safety or legal compliance, you need to act fast:

• Isolate affected product lots

• Suspend risky activities if needed

• Communicate internally (and sometimes externally)

• Begin documenting initial actions

• Let leadership know what’s at stake

This is your containment phase. It’s about controlling the situation—not solving the whole thing yet.

Triage: Critical vs. Non-Critical Findings

Critical or product-impacting findings need immediate attention, both for safety and certification.
Examples:

• Allergen label missing on finished product

• Pest control breach near open product zone

• CCP not monitored for an extended period

Non-critical or procedural findings (like outdated training records or minor documentation gaps) still need correction—but you have time to investigate and respond with depth.

What Not to Do

Here’s what often goes wrong in the rush:

• Slapping on a short-term correction (like rewriting a form) without investigating why it failed

• Using generic phrases like “informed staff” or “procedure updated,” with no context

• Skipping the documentation of your initial containment and risking future traceability problems

If the auditor revisits—or if your cert body requests follow-up—they’ll want to see what you did and when.

A Real-World Example

One site I worked with received a nonconformity for missing allergen verification on their cleaning logs. The team’s first move? Retrain sanitation staff and revise the checklist. Sounds solid, right?

But during the root cause phase, they realized the issue was tied to poor shift handovers, not training or forms. The actual fix required revising shift procedures and adding a verification step before restart—not just handing out a new log sheet.

That kind of insight takes time—but it’s what auditors are really looking for.

Root Cause Analysis That Auditors Will Actually Respect

Here’s the truth—most weak corrective action plans fail right here. Not because the issue wasn’t real. Not because the team didn’t care. But because the root cause analysis was shallow.

If your go-to response is “we retrained staff,” you’re just scratching the surface. And trust me, auditors can spot that from a mile away.

Why “Staff Retraining” Is Not a Root Cause

Let’s say a product went out with a missing label. You trace it back to one operator forgetting to verify the packaging.

The temptation? Write “operator error” and fix it by retraining.

But the deeper questions are:

• Why was the verification step missed?

• Was the procedure too vague?

• Was the line rushed?

• Was there a communication breakdown during shift change?

Unless you answer why the error occurred in the first place, your “fix” won’t prevent it from happening again.

Tools That Actually Work

You don’t need expensive software to do real root cause analysis. Just use simple tools—and take them seriously.

1. The “5 Whys” Method
Ask why the issue happened—and then ask why again. Keep going until you hit the true root.
Example:

• Why was the CCP not monitored? → The log was blank.

• Why was the log blank? → The operator said they were too busy.

• Why were they too busy? → They were covering two lines.

• Why? → Short-staffed during second shift.

• Why? → Scheduling error not flagged in daily review.

Now you’re dealing with a staffing issue—not just a monitoring one.

2. Fishbone Diagram (Ishikawa)
Great for team brainstorming. Helps identify categories like methods, materials, people, equipment, and environment that might contribute to a failure.

3. Fault Tree Analysis
Useful for technical or process-heavy systems where multiple failures compound into a major issue.

How to Document It (So Auditors Take You Seriously)

Make your thinking visible. A great RCA includes:

• The analysis method used

• A written or visual breakdown of the investigation

• Names of those involved (this shows cross-functional input)

• Evidence you considered process, equipment, people, and environment

• A clearly stated root cause—not just symptoms

Avoid vague terms like “human error,” “operator forgot,” or “unaware of policy.” Auditors expect you to go further.

Watch Out for These RCA Pitfalls

• Blame culture: “The new guy didn’t know better” is not root cause analysis. It’s an excuse.

• Skipping verification: You need to test if the root cause you identified actually matches the issue.

• Treating every issue as isolated: Look for patterns. Has this happened before under different names?

Real Talk

I once reviewed a corrective action plan that blamed a labeling error on “staff oversight.” When we sat down to review the process, we discovered the labels had been switched because two SKUs used nearly identical artwork—and there was no system for double-checking lot numbers. Training wasn’t the issue. Packaging design and quality control were.

That kind of insight? That’s what actually prevents recurrence.

Writing a Corrective Action Plan That Passes Scrutiny

Here’s where a lot of teams slip up—not in fixing the issue, but in documenting how they fixed it. And in FSSC 22000 Version 6, a strong corrective action plan is more than just a formality. It’s a signal that your organization understands the risk, took it seriously, and put something real in place to prevent recurrence.

The best plans don’t just check boxes—they tell a clear, logical story.

What a Strong CAP Includes

A good corrective action plan should follow this structure, clearly and completely:

1. Description of the Nonconformity

   • Use the auditor’s language, but clarify with internal context if needed.

   • Be specific about where and when the issue occurred.

2. Root Cause

   • Summarize your analysis findings (you’ve done the deep dive already).

   • Avoid vague terms like “oversight” or “forgot.” Instead, explain the failure point in the system.

3. Correction

   • What immediate steps did you take to contain or fix the issue?

   • Include dates and who did what.

4. Corrective Action

   • What changes did you make to address the root cause?

   • Think: process updates, engineering controls, system alerts, structural fixes—not just “retraining.”

5. Preventive Action (if applicable)

   • What will you do to prevent similar issues elsewhere in the system?

6. Responsible Person and Timeline

   • Who is accountable for completing the actions?

   • When will each step be done?

7. Verification of Effectiveness

   • How will you prove the corrective action worked?

   • Include evidence to show follow-up, results, and whether the issue has recurred.

8. Supporting Documents

   • Attach revised procedures, training logs, calibration certificates, or photos as proof.

What a Weak CAP Looks Like

• “Operator retrained. Issue resolved.”

• “Added reminder to check paperwork.”

• “Updated procedure.” (with no proof of rollout or feedback)

These responses are easy to write—but they don’t answer the core question: Why did this happen, and what changed?

Use Tools That Keep You Accountable

If you’re managing CAPs with a mix of emails, spreadsheets, and sticky notes—there’s a better way.
Whether you use a document control system, audit management software, or just a shared tracker, the key is to:

• Assign owners

• Track due dates

• Link findings to actions

• Make follow-up easy to verify

Auditors often review how you manage corrective actions as much as the actions themselves. A well-organized system shows maturity.

Real Talk

One client I worked with had solid corrective actions—but they kept missing verification steps. The result? Recurring issues that never got closed out properly. Once we built a corrective action template with embedded checklists and ownership fields, they not only improved closure rates—they also cut repeat findings by over half in one year.

Structure creates clarity. Clarity builds confidence. And confidence keeps certification bodies off your back.

Verifying and Closing the Loop: Don’t Let Findings Linger

Writing a solid corrective action plan is only half the job. The part that often gets overlooked? Following up to make sure the action actually solved the problem.

I’ve seen companies do all the right things—good root cause analysis, strong documentation, team involvement—and then forget to check back six weeks later to see if the issue stayed fixed. And that’s where auditors start asking tough questions.

What Verification Really Means

Verification isn’t just saying, “We did it.” It’s proving it worked.

You need to show that:

• The action was implemented

• The issue hasn’t recurred

• The system is stronger now than it was before

That might sound simple, but in practice, it requires a bit of discipline—and a clear process.

How to Verify Corrective Actions Effectively

1. Set a Follow-Up Timeline Immediately
Before you submit your CAP, define when and how you’ll check on the results.
Examples:

• One week after training, review operator performance

• One month after SOP change, audit records for compliance

• Quarterly review to monitor for recurrence

2. Use a Different Person to Verify Closure
Ideally, the person who verifies effectiveness should not be the one who implemented the fix. This adds objectivity and reduces blind spots.

3. Look for Evidence of System Stability
What does “it worked” look like in your system?

• No repeat incidents

• Records showing consistent compliance

• Internal audits or observations confirming changes stuck

4. Document the Outcome
Don’t just say “verified”—attach proof. That could be:

• Photos of a revised label or workstation setup

• Training records

• Updated calibration logs

• Follow-up audit checklists with comments

If the auditor revisits the issue during a surveillance audit, you’ll have clear, dated evidence that the loop was fully closed.

What Auditors Look for

• Is the nonconformity still visible in another form?

• Was the root cause really addressed?

• Are similar issues showing up elsewhere?

• Can the team explain what changed and why?

If you can answer those questions confidently, you’re in great shape.

Real Talk

I once supported a facility that got dinged for missing traceability information. They added a new form and trained the staff—great start. But during the next audit, the auditor asked, “Can you show me how that form helped during a recent mock recall?”
Crickets.
They had never tested the new form in a real scenario.
Lesson learned: implementation isn’t the same as effectiveness—and auditors know the difference.

Turning Corrective Actions into Continuous Improvement

Here’s something I tell every team I work with: if you’re only using corrective actions to pass audits, you’re leaving value on the table.

Corrective action planning isn’t just a compliance activity—it’s a window into what your system’s telling you. When used right, it becomes one of your most powerful tools for strengthening processes, training, and culture.

Look for Patterns, Not Just Problems

Over time, your corrective actions form a data trail. If you’re tracking CAPs in any sort of system—digital or manual—you should be reviewing:

• How often issues come from the same process

• Which departments generate the most findings

• What types of root causes are recurring

• Whether certain suppliers or shifts show up frequently

This isn’t about blame. It’s about focus.

Feed Insights Into Risk Assessments

Let’s say you’ve had three nonconformities in the last year related to metal detection.

Instead of just addressing each one in isolation, ask:

• Does our risk assessment reflect the true risk level here?

• Are our CCP verification procedures still adequate?

• Should we revalidate the process?

This kind of loop—where findings inform your HACCP or risk strategy—is exactly what FSSC 22000 Version 6 wants to see.

Use CAPs to Drive Training and Refresher Sessions

If multiple CAPs cite “operator error,” don’t just retrain—rethink your training process.
Ask:

• Are instructions clear and accessible on the floor?

• Is training interactive, or just a signature on a form?

• Do people really understand the why, not just the what?

Corrective action trends can shape smarter, more engaging training programs.

Include CAP Reviews in Management Review

If you’re only talking about KPIs and complaints during your management review, you’re missing a chance to elevate systemic issues.

Add a section that summarizes:

• Number of open and closed corrective actions

• Themes in root causes

• Effectiveness ratings from follow-ups

• Long-term actions taken

This helps leadership make informed decisions and reinforces that food safety isn’t just QA’s job—it’s everyone’s responsibility.

Real Talk

I worked with a site that had a steady trickle of minor findings around sanitation verification. Nothing serious—but persistent. When we reviewed their last 10 CAPs, a pattern jumped out: third shift never had clear handoffs, and supervisors rotated weekly.

That insight sparked a bigger change: a structured shift handover process, written responsibilities, and consistent sanitation walkthroughs. The findings disappeared. And better yet—team morale improved because expectations were finally clear.

Pro Tips from the Field: Stronger Corrective Actions, Smarter Systems

These insights come straight from real-world audits—not theory. If you want your corrective action process to hold up under FSSC 22000 Version 6, these are the habits worth building.

Pro Tip 1: Don’t Start with the Action—Start with the Why
If your team jumps straight to “how do we fix this,” you’re probably skipping the real problem. Always start your post-audit review with one question: Why did this happen in the first place? Root cause thinking leads to better fixes.

Pro Tip 2: Review All Open CAPs Monthly—Even If They’re In Progress
In most food safety systems, time kills momentum. Make it a routine to review open corrective actions every 30 days. It helps uncover stuck tasks, missed deadlines, or unclear ownership before the issue snowballs.

Pro Tip 3: Pair a CAP with an Internal Audit Follow-Up
Want to prove a corrective action worked? Schedule a mini internal audit for that process 30 to 60 days after implementation. It shows auditors you’re closing the loop—and it gives your team confidence that the issue is really resolved.

Pro Tip 4: Use Visual Tools to Spot Repeat Issues
Even a simple spreadsheet heat map—tracking findings by department or process—can reveal patterns that narrative reports miss. These visuals make it easier to brief leadership and prioritize systemic fixes.

Pro Tip 5: Build a Corrective Action Playbook
If you keep seeing the same issue across different plants or shifts—say, metal detector resets or supplier documentation gaps—build a short reference guide with proven root causes, tested fixes, and validation steps. You’ll respond faster and more consistently when it shows up again.

Common Mistakes and FAQs

Corrective action planning can fall apart in the details—and auditors see those details. Here are the common missteps I’ve seen time and again during FSSC 22000 Version 6 audit cycles, plus expert answers to the most frequent questions.

Common Mistakes

Mistake 1: Treating “Operator Error” as a Root Cause
Blaming the person instead of the process is the fastest way to miss the real issue. It’s rarely just one bad day. Look deeper.

Mistake 2: Submitting a CAP Without Verifying Effectiveness
Many teams close out corrective actions as soon as they’re implemented—but forget to go back and check whether they actually worked. Without follow-up, the risk stays alive.

Mistake 3: Using the Same Fix for Every Issue
If your standard response is “updated procedure” or “staff retrained,” you’re sending a message that your fixes are superficial. Auditors want variety and relevance, not boilerplate.

Mistake 4: Waiting Too Long to Respond
Even if your cert body gives you 30 or 60 days, long delays signal a reactive mindset. Fast, structured responses show that your team takes issues seriously and knows how to lead.

Mistake 5: Forgetting to Communicate Findings Internally
A lot of CAPs stay buried in the QA office. Strong systems share findings with the whole team—so the same mistake doesn’t happen again in another department.

Frequently Asked Questions

Q1: How quickly should we respond to a nonconformity after the audit?
Start containment immediately—ideally within 24 to 48 hours. The full corrective action plan should follow your certification body’s timeline, typically within 30 days.

Q2: Can we fix the issue during the audit and avoid a CAP?
Fixing something during the audit is helpful, but it doesn’t cancel the need for a root cause analysis and documented corrective action. The fix may reduce the severity, but not eliminate the finding.

Q3: What happens if we submit a weak or incomplete corrective action plan?
The certification body can reject it, ask for revisions, or delay your certificate decision. Too many incomplete CAPs could lead to suspension if issues aren’t resolved in time.

Q4: Who should be involved in corrective action planning?
It should never be just QA. Bring in people from the affected area, supervisors, and anyone involved in the original process failure. Cross-functional involvement improves accuracy and buy-in.

Q5: Do we have to include preventive actions in every CAP?
Not always—but if the nonconformity suggests a broader risk, including a preventive action strengthens your plan and shows proactive thinking.

The Real Value of a Corrective Action Plan

A nonconformity in an FSSC 22000 audit doesn’t mean you’ve failed. But how you respond to it? That tells the real story.

Corrective actions aren’t just about checking a box for your certifying body. They’re about building a system that actually learns from its mistakes—one that protects your product, your brand, and your team. When you take the time to dig into root causes, involve the right people, and verify that your fixes stick, you’re doing more than just fixing a problem. You’re strengthening your entire food safety culture.

The best-performing sites I’ve worked with treat corrective actions like a strategic tool—not a compliance chore. And they see the results in smoother audits, fewer repeat issues, and a lot more confidence during surveillance visits.

If you’re navigating a tough finding or want an extra set of eyes on your CAP process, that’s exactly what we help with at QSE Academy. We’ve guided food businesses around the world through FSSC 22000 Version 6—before, during, and after the audit—and we’d be glad to support your team too.

Reach out today for help strengthening your corrective action system, reviewing your audit response, or building a playbook that works.

You’re closer than you think to turning nonconformities into your competitive edge.