John Nolan Having prepared well for an ISO 14001:2015 audit, it is obviously disappointing for any organization when the auditor identifies nonconformities during the visit. Of course, prevention of nonconformance, which we looked at in the previous article How to avoid nonconformities during the ISO 14001:2015 transition, is always preferable, but part of the whole compliance process is understanding what forms that nonconformities raised can take and knowing how to successfully correct and prevent reoccurrence. While dealing with a nonconformity can be frustrating, it is wise to remember that correction and prevention are necessary components of the whole continual improvement cycle that underpins the ISO 14001 standard, so the subject of dealing with nonconformity assumes great importance. But, as those with experience in constructing an EMS (Environmental Management System) will know, nonconformities can be manifested in many different ways, can be classified as “minor” or “major,” and can have different requirements in terms of repairing and preventing reoccurrence. So, what are the differences between these minor and major nonconformities?
Major and minor – The difference
Major and minor nonconformities can differ depending on what sector your organization operates in. Any type of nonconformity may have a greater environmental impact at a nuclear power station than at a car parts retail facility; nonetheless, if you are handed a nonconformity you may fail your 14001:2015 audit, so it is vitally important that you understand the difference. With that in mind, let’s look at some examples of each to help you relate this to your own business and understand how both major and minor nonconformities may manifest in your company.
Minor nonconformities (a minor deficiency that does not seriously affect the efficiency of the EMS):
- Let’s say your organization has a process and procedures, but it is discovered during the audit that one person is not using this correctly or at all. This may be raised as a minor nonconformity.
- Your organization keeps maintenance records to prove machinery is maintained. This is generally done, but one or two instances have been missed.
- A procedure exists, but is not found to be accurate and needs amendment to ensure the process can be followed accurately.
Major nonconformities (a major deficiency that seriously impairs the effectiveness of the EMS):
- The organization has failed to comply with or implement a clause of ISO 14001:2015.
- There is no evidence, or evidence is not substantial enough, of corrective action.
- Procedures are missing.
In this way, we can quite clearly see the difference between the two categories and the potential effect that the particular type of nonconformity would have on your organization’s environmental performance. And, most critical of all is how either type of nonconformity being raised will affect the results of your audit:
- A minor nonconformity should not delay your registration to ISO as long as it is fixed within 60 days, and correction can be confirmed at the next audit. (The auditor can use his judgement as to the number of minor nonconformities that may translate to deeper problems with your EMS, which may prompt him/her to raise a major nonconformity on the basis of that judgement.)
- A major nonconformity will result in your registration being delayed, and another audit arranged – along with the cost and time investment required.
So, we now know the difference between major and minor nonconformities, and can see the potential impact they might have. Of great importance, how do we fix them and ensure they do not reoccur?
Fixing nonconformities for good
Minor and major nonconformities can be treated slightly differently, as some minor instances can almost be fixed on the spot. However, a good practice is to use your established corrective action procedure to ensure your nonconformities are treated in the correct way in terms of root cause analysis, monitoring, and prevention of reoccurrence. Remember that clause 10.2 of the 14001:2015 standard specifies how to deal with nonconformity and corrective action, and documenting any changes that may occur in your EMS due to repairing nonconformity falls firmly into that category. So, if you treat the process of repairing a nonconformity as you would with any corrective action, you will have evidence to demonstrate compliance to the auditor if executed correctly. While prevention is better than cure, we understand that in reality there will be instances where we have to fix problems identified by an auditor, whether internal or, in this case, external. Using these guidelines will help you to do just that, and allow you to demonstrate continual improvement, satisfy the auditor, and attain that all-important ISO certificate.
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