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By following this guide, you will independently verify that a corrective or preventive action has been effectively implemented, assess whether the identified risk has been adequately addressed, and document your findings for compliance.
Who should read this: CPA verifiers, safety managers, and quality assurance personnel. Any workspace member with Safety Manager or Admin permissions can serve as a verifier, provided they are not the CPA owner.Prerequisites: A CPA in Implemented status with evidence attached by the CPA owner. Familiarity with the CPA lifecycle (see CPA Lifecycle).

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CPA lifecycle context

Verification occurs after the CPA owner has completed the assigned action and marked it as implemented. The full lifecycle is: The verification phase is where your organization confirms that actions are not just completed but actually effective. Without rigorous verification, CPAs can become a checkbox exercise rather than a genuine safety improvement mechanism.

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Separation of duties

The verifier must be a different person than the CPA owner. This separation of duties is a fundamental principle of Safety Assurance — the person who implemented an action cannot objectively assess its own effectiveness. PlaneConnection enforces this rule at the system level. When a CPA moves to Implemented status, the Verify action is unavailable to the assigned owner. Only other users with Safety Manager or Admin permissions can initiate verification.
Do not work around the separation of duties requirement by having the owner dictate verification findings to another user. The verifier must independently assess the evidence and form their own conclusion about effectiveness. This independence is what gives the verification process its value.

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The 4-step verification process

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Step 1: Completeness check
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Confirm that all planned actions were carried out as described in the CPA.
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  • Navigate to Safety > Corrective Actions and click the Verification tab to see CPAs awaiting verification.
  • Open the CPA you are verifying.
  • Read the CPA title, description, and effectiveness criteria carefully. Understand what was supposed to be done and what measurable outcomes were expected.
  • Review the progress notes to understand the sequence of actions taken.
  • Confirm that every element of the planned action has been addressed:
    • Were all described steps completed?
    • Were any aspects of the original action plan modified? If so, is the modification documented and justified?
    • Were there any partial implementations or deferred items?
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    Completeness QuestionWhat to Look ForWere all planned steps completed?Progress notes documenting each stepWere any modifications made to the plan?Notes explaining why and what changedIs anything deferred or outstanding?Partial implementation indicators
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    Step 2: Evidence review
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    Examine the documentation attached by the CPA owner to confirm the action was actually performed.
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  • In the Evidence section of the CPA, review all attached files.
  • For each piece of evidence, assess:
    • Relevance: Does this evidence relate directly to the CPA action?
    • Sufficiency: Does the evidence demonstrate that the action was completed, not just initiated?
    • Authenticity: Are dates, signatures, and references consistent with the reported implementation?
  • Common evidence types and what to look for:
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    Evidence TypeWhat Demonstrates EffectivenessUpdated SOP or procedureNew revision number, effective date, approval signaturesTraining recordsCompletion dates, attendee lists, assessment scoresMaintenance work ordersWork performed, parts replaced, inspector sign-offPhotos of physical changesBefore/after comparison, date stampsMeeting minutesApproval of changes, attendee acknowledgmentSystem configuration screenshotsSettings changed, dated capture
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    If the evidence is insufficient, you do not need to fail the verification immediately. Contact the CPA owner to request additional documentation before making your assessment. The goal is an accurate evaluation, not a gotcha.
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    Step 3: Effectiveness assessment
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    Evaluate whether the action has eliminated or adequately mitigated the identified risk. This is the most critical step — it determines whether the CPA actually solved the problem.
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  • Review the effectiveness criteria defined when the CPA was created. These are the measurable criteria the verifier should use to confirm effectiveness.
  • Assess against each criterion:
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    Effectiveness LevelDefinitionActionEffectiveThe action fully addresses the root cause or risk. Evidence confirms the deficiency is resolved. No recurrence observed.Proceed to documentation (Step 4)Partially EffectiveThe action addresses some aspects of the issue but gaps remain. Risk is reduced but not adequately mitigated.Return to In Progress with specific notes on what remainsNot EffectiveThe action does not address the root cause. The deficiency persists or the risk remains at an unacceptable level.Return to In Progress with detailed explanationCannot DetermineInsufficient time has elapsed or insufficient data exists to assess effectiveness.Return to In Progress with a note specifying what additional data or time is needed
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  • Consider these effectiveness questions:
    • Has the original deficiency been resolved? Is there evidence of resolution, not just activity?
    • Has the risk been reduced to an acceptable level per your organization’s risk criteria?
    • Has there been any recurrence of the issue since implementation?
    • Are there unintended consequences or new risks introduced by the action?
    • Is the corrective action sustainable, or is it a temporary fix that will degrade over time?
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    Effectiveness assessment is not purely retrospective. For preventive actions or recently implemented corrective actions, there may not be enough operational history to confirm effectiveness through recurrence data alone. In these cases, assess whether the action is structurally sound — does the procedure change address the gap? Is the training designed to build the right competency? Is the engineering control robust?
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    Step 4: Documentation
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    Record your verification findings in the CPA record. This documentation becomes part of your SMS record per 14 CFR 5.97.
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  • In the Verification section of the CPA detail page, enter your verification notes. Document:
    • What you reviewed (evidence, procedures, operational data)
    • Your assessment of completeness and effectiveness
    • Any observations or concerns
    • Your conclusion (effective, partially effective, not effective, or cannot determine)
  • Select your effectiveness assessment from the dropdown.
  • If the CPA is effective:
    • Click Verify to advance the CPA to Verification status.
    • The verification date and your identity are recorded automatically.
    • The safety manager is notified that the CPA is ready for closure.
  • If the CPA is not effective (partially effective, not effective, or cannot determine):
    • Click Return to In Progress.
    • Enter the failure reason — this is required. Be specific about what needs to change.
    • The CPA returns to In Progress status.
    • The CPA owner receives a notification with your notes explaining what additional work is required.
    • The due date may be extended if the remaining work warrants it.

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    After verification

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    If verified effective

    The CPA moves to Verification status. The safety manager reviews the verified CPA and advances it to Closed. Closed CPAs are read-only and retained per 14 CFR 5.97 — as long as the associated safety risk control remains relevant.

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    If verification fails

    The CPA returns to In Progress for the owner to address the identified gaps. The verification cycle repeats: 
    In Progress --> Implemented --> Verification (attempt 2)
    There is no limit on the number of verification attempts, but repeated failures should prompt a review of whether the original action plan is adequate or whether a different approach is needed.
    If a CPA fails verification more than once, escalate to the safety manager for review. Repeated failures may indicate that the root cause was not correctly identified in the original investigation, or that the CPA scope is insufficient to address the underlying issue. A new investigation or a new CPA may be warranted.

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    Regulatory alignment

    14 CFR Part 5 SectionRequirementVerification Component
    5.73Safety performance assessmentIndependent verification of CPA effectiveness
    5.75Continuous improvementFeedback loop when verification fails
    5.97SMS recordsVerification notes, date, and verifier identity retained
    Verification is how your organization demonstrates to the FAA that Safety Assurance is functioning — that you are not just identifying problems and assigning actions, but confirming that those actions produce results.

    Create and Track CPAs

    Full guide to CPA creation, assignment, and progress tracking.

    CPA Lifecycle

    Complete reference for statuses, transitions, and verification rules.

    Track Your First CPA

    Tutorial walkthrough of the complete CPA lifecycle including verification.

    Manage Investigations

    How investigations produce the recommendations that become CPAs.
    Last modified on April 11, 2026