Non Conformance and Corrective and Preventative Action
As part of the audit process the organization takes action on any “findings” (concerns or deviations from its planned activities) to make sure that nonconformances are examined for their root causes, corrected, and prevented from reoccurring. Identifying and correcting non-conformances is an activity that allows an organization to improve and strengthen the EMS. It’s an opportunity to realize the organization’s commitment to continuous improvement and should not be looked upon negatively.
What is an EMS Audit Finding?
- A failure or weakness in the EMS
- An indication that some element of the EMS is not in conformance with
the design or expectations of the organization
Classifying Findings
Nonconformance
- A deficiency or failure that could adversely affect the EMS
Examples
- A single infraction that can cause a system failure
- Procedure exists but not implemented
- Employees permitted to disregard WIs/SOPs
- An isolated incident or small number of instances of failure to conform to requirements
- Failure in a few cases to follow documented procedures
- Documented procedure requires clarification
Observation
- A practice, while not in strict violation of EMS requirements, may constitute
a poor practice that can lead to a nonconformance
Example
- A practice that can make conformance difficult or provide opportunities for error
- Procedures that are long and difficult to follow
- Poor housekeeping
- General awareness of environmental issues is excellent. However, personnel confuse environmental policy with safety-related issues.
Documenting a Finding
Essentials:
- Need supporting objective evidence to support the classification
- Clarity and precision are important
There is no single approved format for summarizing and reporting the results of an audit. Click here for a format that has proven useful. Note that the same form may be used for reporting both nonconformance and observations.
Once the finding is classified and documented it then needs to be corrected. This is called a corrective action request or CAR. We suggest that the management of the area in which the finding occurred be designated as the one responsible for responding to the CAR. They are responsible for identifying the root cause of the finding and documenting what steps will be taken to address the finding. Once the finding is addressed the Audit Manager or other will need to verify the corrective action was taken.
Nonconformances call also be identified outside of an audit. Anyone in the organization can identify and report a finding. Some organization choose to follow a “find and fix” approach for the smaller issues rather than go through the documentation exercise. If you’re unsure which approach to follow you can start off documenting every finding and CAR and scale back at a later date.