A CAP is meant to describe the steps that will be taken to DECREASE the possibility that a problem will occur again.  It is impossible, due to many factors (including human behavior), to expect a problem to NEVER occur again.  And failure to meet the expectation of a problem never reoccuring causing another citation is unreasonable and not realistic.  The expectation for a problem to never occur again is an impossible standard to meet.  12VAC35-105-170H & 12VAC35-105-620D.3 should be removed from the final regulations.