VSP Inspections: A Problem Understood Is a Problem Half-Solved

An image of a blackboard with the equation 1+1=3 written in chalk, with the words VSP Inspections A Problem Understood Is a Problem Half-Solved

ISO 9001 is a globally recognized standard outlining requirements for quality management systems. It defines a corrective action plan (CAP) as a formal process to systematically address nonconformities; namely, a failure to comply with a regulatory requirement or a company Standard Operating Procedure (SOP). A CAP is an essential tool that assists organizations in identifying the fundamental reasons behind nonconformities (i.e., the root cause), enabling the implementation of remedial measures to prevent future occurrences.

Considering that numerous cruise lines and ship management companies have achieved ISO 9001 certification, how is this accomplishment reflected in corrective actions applied after Vessel Sanitation Program (VSP) inspections? More, is there any evidence that corrective actions successfully prevent recurrence of similar violations?

In addressing these questions, we reviewed the corrective action statements submitted by cruise lines to VSP following 231 sanitation inspections. Given the paramount importance of public health in cruise ship operations, one might reasonably anticipate that the corrective actions implemented would prevent similar deficiencies being reported on subsequent inspections. Should this be the case, the findings discussed in this article may prove unexpected.

How to Implement an Effective Corrective Action Plan

Kidlin’s Law is a principle of problem-solving theory that states, “If you write the problem down clearly, then the matter is half-solved.” While this concept may appear to be a straightforward proposition, it carries considerable underlying significance to the development of corrective action plans. The essence of Kidlin’s Law rests squarely on the word “clearly,” implying that understanding the nature of a problem is the initial and crucial phase in devising the appropriate resolution.

The application of Kidlin’s Law to the VSP inspection process can be broadly realized as follows:

  • Step 1 – Identify the problem. The first step in recognizing an existing issue is facilitated by the VSP inspectors, who identify deficiencies during inspections and document them in their reports. They provide a quantifiable description of the violation (nonconformity), accompanied with what is termed as a “recommendation” which details the specific VSP Operations Manual standard not adhered to. This process of defining the problem (the violation) and clearly outlining the expected outcome (the recommendation) enables cruise lines to understand the reason for a deficiency and the necessity for its rectification.
  • Step 2 – Determine the root cause. Identifying the fundamental reasons for a nonconformity is the most challenging aspect of the corrective action process. It’s essential to recognize the distinction between causal factors and root causes. Causal factors, also known as contributing factors, are the direct reasons that result in a noncompliance, whereas root causes investigate the deeper, underlying issues behind a nonconformity. Root causes often stem from systemic deficiencies such as inadequate procedures or insufficient training. This distinction is important as corrective actions that focus exclusively on causal factors will not be successful in preventing nonconformities from reoccurring.
  • Step 3 – Develop corrective actions that address the root cause. This stage begins by considering various ideas to address the deficiency rather than immediately aiming for a final resolution. Prioritize feasible solutions and determine the most efficient method for their implementation. While some corrective actions may be as simple as replacing a faulty backflow prevention device, if similar violations are repeatedly identified, it is likely that the root cause has not be successfully addressed; in other words, why do the backflow prevention devices keep failing?
  • Step 4 – Review the corrective actions. A crucial aspect in the execution of a solution is to review its efficacy in solving a problem. After an appropriate time, it’s important to follow up and check that a corrective action has resolved the issue. If the intended result has not been achieved, further investigation is needed by repeating steps two to four until the actual root cause has been ascertained.

A Review of VSP Corrective Action Statements

Maritime Health Services’ analysis encompassed 231 VSP inspections on 163 cruise ships over a period from 1 October 2022 through 1 March 2024. VSP records indicated that at the time of MHS’s evaluation in March 2024, there were 18 corrective action statements pertaining to 411 violations that had not been submitted. Additionally, out of the 213 corrective action statements that were reviewed and included within our analysis, corrective actions to address 72 violations were unaccounted for within the submitted reports.

In total, 5,553 corrective actions were evaluated and classified by MHS under one of three primary root cause categories:

  1. Physical causes: Problems with any physical component of equipment, instruments, facilities, or an electronic system, such as hardware failure or equipment malfunction.
  2. Organizational causes: A system or process that is faulty or insufficient, such as incomplete company instructions or the absence of a procedure.
  3. Human factors: Human error, such as those caused by a lack of skill and knowledge to perform a task.

The categorization of corrective actions was determined by the presumed underlying cause that corresponded to the remedial measure described in the corrective action statement. For example, if a violation cited an issue with a warewashing machine’s final sanitizing rinse temperature and the corrective action only indicated that maintenance was required, then it was categorized under “Physical Causes.” Conversely, if a corrective action involved a briefing, instruction, or retraining of crew, the category assigned was “Human Factors.”

The “Organizational Causes” category was reserved for instances where a corrective action specifically described an amendment to, or creation of, a company-approved procedure, or where extra resources were documented as necessary to conform to the standard associated with the violation. While immediate changes to on board processes may mitigate public health hazards on a temporary basis, interim containment measures must be supplemented by verified corrective actions that permanently prevent similar deficiencies from occurring.

Figure 1 – Root cause of VSP violations determined by cruise line corrective action statements

Figure 1 illustrates how underlying issues behind violations raised during VSP inspections were categorized by cruise lines in their corrective action statements. It was observed that human factors were the main contributors in 55.2% (n=3064) of all reported deficiencies.

The corrective action strategies in these instances were primarily focused on correcting the violation on-the-spot or retraining crew. Notably, reeducation efforts described in the corrective action statements were predominantly directed at food and beverage crew, particularly those working in the galley. In contrast, higher-level cruise staff such as supervisors, managers, and members of the deck and engine departments were seldom the focus of corrective actions that prescribed retraining.

Corrective actions addressing physical causes, such as repairing equipment, retiling decks, or adjusting the ventilation in food areas, were identified as the primary root cause for 43.8% (n=2433) of all nonconformities cited. This is consistent with the fact that most violations reported during VSP inspections pertain to food safety standards for the construction and maintenance of decks, bulkheads, and deckheads within food areas. Often, remedial maintenance measures were complemented by additional corrective actions involving the retraining of crew. This refresher training was again principally applied to food service personnel, emphasizing the importance of promptly communicating any maintenance issues to on board technical teams.

Out of the 5,553 corrective actions reviewed, only 1% (n=56) determined that the fundamental reason for the violation stemmed from organizational issues such as insufficient company protocols or inadequate shipboard resources to properly execute a task. The overwhelming majority of these 56 corrective actions involved a responsible person shoreside updating an existing company procedure.

While acknowledging that classifying root causes into one of only three categories has its constraints—as violations often have multiple underlying reasons—the classification was based on the specifics of the corrective actions described in the reports provided by cruise lines to the VSP. On this basis, the observation that a mere 1% of corrective actions proposed changes to an established company process is significant. It implies that nearly all issues identified during a VSP inspection can be attributed to the application of company protocols, rather than any shortfalls in the processes themselves.

How Corrective Action Plans Can Be Improved

Any discussion regarding violations of public health regulatory requirements must acknowledge that the employment conditions aboard cruise vessels are a contributing factor in noncompliance. The majority of crew members typically work 10 hours a day, 7 days a week, over a continuous period of 9 to 10 months without respite. It is unreasonable to anticipate that any individual can be expected to perform at their maximum capacity in such demanding circumstances. In essence, the concept of a cruise ship continuously maintaining 100% compliance to all VSP hygiene standards—a prevalent misconception when a ship is awarded a score of 100—is inherently flawed.

Thus, the purpose of analyzing how companies approach the correction of violations raised during a VSP inspection is not to attribute blame or to exacerbate the prevalent “us” (the crew on board) versus “them” (the shoreside personnel) dynamic common within the cruise industry. Rather, it is to highlight the public health consequences that arise when the underlying symptoms of deficiencies are not appropriately managed: when temporary solutions are erroneously believed to be permanent.

Overdependence on immediate remedial measures creates a perpetual cycle which our previous research corroborates: the same violations are frequently identified in successive VSP inspections. Reliance on “quick fix” remedies is a growing dependence that will progressively get worse unless the true underlying causes of violations are addressed. The successful application of Kidlin’s Law to the development of corrective actions plans relies not on the reconciliation of casual factors, but on resolving the fundamental reasons behind the deficiencies.

An interesting phenomenon discovered during our analysis was the widespread use of draft VSP inspection reports to submit corrective actions and a likely a contributing factor to the omission of the 72 corrective actions reported earlier. This observation further underscores the conclusion that immediate solutions take precedence over a thorough trend analysis and detailed root-cause examination.

As the final validated report is typically sent by VSP to a cruise line’s nominated shoreside representative within a few weeks after an inspection, it appears that the onus of devising corrective action plans falls primarily on the ship’s management team. Consequently, this may explain the hesitance to pinpoint organizational problems as the root cause of the violations.

While contributing factors are generally easier to identify and resolve—and are unlikely to involve appropriating blame to someone in the office—too often they do not represent the primary cause of a violation. When cruise companies rely exclusively on shipboard staff to draft corrective action statements, they miss out on crucial perspectives that highlight necessary operational enhancements, prioritize key areas for improvement, and pinpoint the most effective strategies to prevent recurrence.

If repeated violations continue to be reported during VSP inspections and a subsequent serious health-related incident occurs on board, it may be perceived as corporate negligence. By thoroughly investigating regulatory violations and adopting a systematic approach to formulating corrective actions, cruise companies will ensure health risks are more effectively mitigated, will demonstrate their commitment to ISO 9001 requirements, and will enhance passenger (and crew) satisfaction.