hmm, as far as i know, action painting emphasizes on the process when the artist created the painting, using spontaneous body movement or gesture. The artist sees the canvas (or other medium) as an area to perform physical act.
Maybe it depends on your intention after all. But I like it.
TBH I'm hard-pressed to remember, since it's been five years, since I painted this. It's pretty spontaneous, and I didn't have a clear plan in my head, but I did not set out intentionally to do an action painting.
I love the high-energy put off by this work. The color interactions are simply dynamic! The experimentation of art-making just oozes from this work in the way you use your brush strokes. I really feel my eyes being led over the work. This is absolutely stunning. Great work!