ISO 14001-Clause 4.5.3 Nonconformity, corrective action and preventive action
ISO 14001-Clause 4.5.3
ISO 14001 Requirements
The organization shall establish, implement and maintain a procedure(s) for dealing with actual and potential nonconformity(ies) and for taking corrective action and preventive action. The procedure(s) shall define requirements for
- identifying and correcting nonconformity (ies) and taking action(s) to mitigate their environmental impacts,
- investigating nonconformity (ies), determining their cause(s) and taking actions in order to avoid their recurrence,
- evaluating the need for action(s) to prevent nonconformity (ies) and implementing appropriate actions designed to avoid their occurrence,
- recording the results of corrective action(s) and preventive action(s) taken, and
- reviewing the effectiveness of corrective action(s) and preventive action(s) taken.
Actions taken shall be appropriate to the magnitude of the problems and the environmental impacts encountered.
The organization shall ensure that any necessary changes are made to environmental management system documentation.
The Standard requires that the organization shall establish and maintain procedures for controlling non-conformities and for taking corrective and preventive actions to mitigate any impacts caused.No EMS is perfect. You will probably find problems with your system, especially in the beginning through audits, measurement, or other activities. Your EMS will also need to change as your organization changes and grows. When system deficiencies are encountered, your organization will need a process to ensure that:
- problems including nonconformities are investigated;
- root causes are identified;
- corrective actions are identified and implemented; and,
- corrective actions are tracked and documented.
Thus the organization must have the capability of detecting nonconformances and then setting up mechanisms for correcting each nonconformance. Further, it should be able to put into place systems that will prevent a recurrence of the same non-conformance .EMS nonconformities and other system deficiencies should be analyzed to detect patterns or trends. Identifying these trends will allow you to anticipate and prevent future problems. Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur or after they reoccur. This approach is consistent with the continual improvement philosophy. A moment should be taken here to consider what is understood by ‘nonconformance’ because not every organization knows what an environmental non-conformance is. Some time should be spent defining the term ‘environmental non-conformance’ to all interested parties. For example, not following a procedure is an easy non-conformance to identify.However, this is really a management system non-conformance. A true environmental non-conformance could be a cracked bund wall that has not been repaired as programmed – thereby increasing the risk of an environmental incident. The requirement of ISO 14001-Clause 4.5.3 goes on to state that any corrective or preventive action that is taken shall be appropriate to the magnitude of the problem and commensurate with the environmental impact encountered. This is to ensure that the organization is mindful of that word ‘significance’. Referring to the cracked bund wall above, suppose that it is designed to contain only process waters of low toxicity. Clearly, a similar cracked bund wall intended to contain a cocktail of waste solvents has a much higher priority on the corrective action agenda. Higher priority must also be given to monitoring and maintenance costs than the former bund wall. Therefore the organization is using its finite financial resources in the most effective way. The closing paragraph of ISO 14001-Clause 4.5.3 merely calls for an organization to record what corrective actions were taken and to make revisions to any relevant documented procedures. Again, using the above example, a possible change to the maintenance procedure would be to increase the frequency of inspection of the higher-risk bunding.
If your organization has an ISO 9000 management system, you should already have a corrective / preventive action process for quality purposes. You can use this as a model for EMS purposes. Small companies might find they can combine their management review and corrective action processes, especially if the same people are involved in both. At the very least, a strong link should exist between the two processes. The amount of planning and documentation needed for corrective / preventive actions can vary with the severity of the problem and its potential environmental impacts. Don’t go overboard with bureaucracy, simple methods often work best .Once you document a problem, the organization must be committed to resolving it. Corrective actions should be implemented as quickly as possible. Be sure that your corrective / preventive action process specifies responsibilities and schedules. Review your progress regularly and follow up on any deficiencies. Make sure you collect the right data / information to make good decisions. While many corrective actions may be “common sense,” you need to look below the surface to determine why a problem has occurred. Initially, most EMS problems may be identified by your auditors. However, over the long run, most problems and good ideas may come from the people in the shop doing the work. This should be encouraged. Find ways to get employees involved in the system improvement process for example, via suggestion boxes, contests and incentive programs.
- Has the organisation established, implemented and maintained a procedure(s) for dealing with actual and potential non-conformities, and corrective & preventive action?
- Do the procedures defined requirements for identifying and correcting non-conformities and taking action to mitigate the resulting environmental impacts?
- Do the procedures defined requirements for investigating the non-conformities, determining their causes and take action to avoid their recurrence?
- Do the procedures defined requirements for evaluating the need for actions to be taken to prevent non-conformities, and implementing appropriate actions?
- Do the procedures defined requirements for recording the results of corrective and preventive actions taken?
- Do the procedures defined requirements for reviewing the effectiveness of corrective and preventive actions?
- Are the responsibilities and authorities for this process defined?
- How is this procedure updated?
- How do you decide that the action(s) taken to eliminate the causes of actual and potential non-conformities are appropriate to the magnitude of the problem(s) and the environmental impact(s) encountered?
- How do you ensure that changes (if any) are made in the environmental management system documentation?
|Example of Procedure for Incidents,Investigation, Non-Conformity, Corrective Action And Preventive Action|
|Example of Template for Non conformance report/ Corrective and Preventive Action|
Implementation document ( Not mandatory but helps in fulfillment of requirement):
|Example of CAPA tracking log|
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