PASA Corrective Action Plan

About This Document

The PASA Corrective Action Plan is a structured working document aligned to the format and expectations of the WRAP audit corrective action process. It is designed to be completed following a PASA Self-Assessment or professional gap assessment — capturing each non-conformance finding, the corrective action required, the responsible party, the target completion date, and the verification method. This document may be presented to a WRAP-registered monitor as evidence of active remediation.

A Corrective Action Plan is not a compliance formality — it is a management tool. The most important thing a facility can do after identifying a compliance gap is assign it an owner, a deadline, and a verification method. Gaps with no owner do not close. The PASA CAP enforces exactly that discipline: every finding has a named responsible party, a risk classification, a specific corrective action, and a date by which that action must be verified complete.

How to use this document: Complete the Facility Information block first. Then transfer each gap identified in your PASA Self-Assessment into the CAP table — one row per finding. Score each finding's risk level, define the corrective action required, assign a responsible owner, and set a realistic remediation deadline. Update the Status column as corrective actions are implemented and verified. Present to your compliance monitor or leadership team at your next review.

Complete Facility Info

Fill all fields in the header block. Assign a CAP reference number and document date.

Enter Findings

Transfer each PASA gap into the table. One row per finding. Complete all columns.

Assign & Schedule

Name the responsible party and set a realistic due date for each corrective action.

Track & Close

Update status as actions are completed. Document verification evidence. Obtain sign-off.

Section A — Facility & CAP Identification

Complete all fields before distributing this document

Facility / Company Name

CAP Reference Number

Facility Address / Country

CAP Issue Date

Compliance Manager / CAP Owner

CAP Target Completion Date

Assessment Type That Generated This CAP

Target Certification Standard

Scope of CAP — Departments / Operations Covered

Section B — Corrective Action Register

One row per finding — complete all columns

STATUS KEY:

Open — Not yet started

In Progress — Action underway

Closed — Verified complete

N/A — Not applicable

Labor Practices — Principles 2, 3, 4, 7, 9

WRAP Principle / Ref #	Finding / Non-Conformance	Risk Level
P2 — Forced Labor	Worker document retention or deposit arrangements identified PASA Item 2.2	Critical
P3 — Child Labor	Age verification documentation missing or incomplete at hire PASA Item 3.2 / 3.3	Critical
P4 — Harassment	Anti-harassment policy absent or not posted in worker language PASA Item 4.1	High
P4 — Harassment	Grievance procedure not documented or not communicated to workers PASA Item 4.2	High
P7 — Discrimination	Non-discrimination policy missing or training records absent PASA Item 7.1 / 7.2	High

Compensation & Hours of Work — Principles 5, 6

WRAP Principle / Ref #	Finding / Non-Conformance	Risk Level
P5 — Compensation	Payroll records incomplete, inconsistent, or not retrievable PASA Item 5.1 / 5.2	Critical
P5 — Compensation	Wage statements not provided to workers each pay period PASA Item 5.3	High
P6 — Hours	Time and attendance records incomplete or gaps identified PASA Item 6.2	Critical
P6 — Hours	Rest periods or meal breaks not documented or not compliant PASA Item 6.3	Medium

Health & Safety — Principle 8

WRAP Principle / Ref #	Finding / Non-Conformance	Risk Level
P8 — H&S	Fire safety equipment not inspected or documentation not current PASA Item 8.2	Critical
P8 — H&S	Emergency evacuation drills not conducted or not documented PASA Item 8.3	Critical
P8 — H&S	Health and safety training records absent or not current PASA Item 8.5	High
P8 — H&S	Chemical handling, PPE, or equipment safety docs not current PASA Item 8.6	High

Environment, Customs Compliance & Drug Policy — Principles 10, 11, 12

WRAP Principle / Ref #	Finding / Non-Conformance	Risk Level
P10 — Environment	Environmental permits expired or not current — wastewater, waste disposal PASA Item 10.2	High
P11 — Customs	Country-of-origin documentation incomplete or not maintained on file PASA Item 11.2	High
P12 — Drug Policy	Drug and alcohol policy not posted or training not documented PASA Item 12.1 / 12.3	Medium

Additional Findings — Enter as identified in PASA or professional assessment

WRAP Principle / Ref #	Finding / Non-Conformance	Risk Level	Required Corrective Action	Responsible Party	Due Date	Status	Verification Evidence

Section C — CAP Progress Summary

Update at each review cycle

____

Total Findings

____

Open

____

In Progress

____

Closed / Verified

Review Notes / Management Comments

Section D — Authorization & Sign-Off

Required before submitting CAP to external monitor or auditor

Compliance Manager / CAP Owner

Signature Date: ___________

Facility / General Manager

Signature Date: ___________

External Monitor / Auditor (if applicable)

Signature Date: ___________

Standards & References

WRAP — Corrective Action Plan Format & Requirements, Certification Program Guidelines (2024) — wrapcompliance.org
International Labour Organization — Core Labour Standards, Audit Remediation Guidance (2024) — ilo.org
U.S. Department of Labor — ILAB Social Compliance Toolkit, CAP Methodology (2024) — dol.gov/ilab
Social Accountability International — SA8000 Corrective Action Guidance (2023) — sa-intl.org

Need Help Building Your CAP?

RC2 Consulting works alongside facility teams to complete gap assessments, structure corrective action plans, and guide organizations through full remediation — from first finding to audit-ready closure.

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