4.5.2 Nonconformance and Corrective and Preventive Action

Purpose

To define the corrective or preventive actions necessary to eliminate the causes of nonconformities, including complaints, in order to prevent their recurrence, mitigate the impact and drive continual improvement of the Environmental Management System.

Corrective actions are implemented as appropriate, considering the actual or potential impact of the nonconformities.

Procedure

Responsibility

The Environmental Manager has overall responsibility for handling and investigating nonconformance and for taking action to mitigate the impacts caused by the nonconformance.

When specialist or external assistance is required to deal with the nonconformance and the resulting impacts, the Environmental Manager shall maintain overall responsibility.

Whenever a nonconformance has the potential to expose the organisation to significant costs or legal action, the Environmental Manager must keep top management informed at all times. 

Corrective and preventive action

The Environmental Manager has overall responsibility for initiating and completing corrective and preventive action in the event of a nonconformance.

When appropriate, responsibility may be delegated to suitably qualified and experienced personnel. In determining the appropriate corrective and preventive actions to be taken, careful consideration shall be given to the type and magnitude of the problem and environmental impact.

Where necessary the Environmental Manager shall consult with internal and external specialists to ensure that the most effective and appropriate measures are used to mitigate the impact or prevent the occurrence.

Corrective Action Required

• When a nonconformance is identified a Corrective_Action_Required (CAR) form shall be completed. All personnel are trained and encouraged in the use of CAR forms.
• After completing the details, the CAR form is passed to the Environmental Manager.  If appropriate, the CAR is discussed at staff meetings and meetings of top management.
• The Environmental Manager shall then process the form promptly, identifying underlying or root causes and notes these on the form. 
• The Environmental Manager shall then proceed with appropriate corrective or preventive action, noting these on the form. 
• A Corrective_Action_Required_Log shall be maintained by the Environmental Manager, and the status of the CAR will be maintained.  CAR issues that are outstanding will be followed up regularly.
• The CAR log will be presented at the regular environmental management meetings.  The Environmental Manager has the responsibility for making the appropriate changes to procedures, forms and management systems as required, from issues arising from the CAR forms.
• Top management will review and approve major CAR actions.

Evaluation

All instances of nonconformance are evaluated to determine the cause and the impact that they have on the environment, safety, customer satisfaction etc.

As part of the evaluation process, any action to prevent a recurrence of the non-conformance is considered and evaluated.

During this evaluation consideration is given to the potential for a recurrence, long term impact, safety, customer satisfaction, legal and regulatory implications etc.    

Corrective action

Following the evaluation of the cause, potential for recurrence and the actual or potential impact on the environment, consideration is given to determine the most appropriate method reducing or eliminating the risk of recurrence.

Communication and Documentation

All evaluation results and corrective actions taken to mitigate or eliminate the potential for further nonconformance are communicated to all relevant parties, recorded and stored in accordance with the procedure 4.5.3.

Review

The effectiveness of corrective actions are reviewed on a regular basis, every three (3) months or as deemed necessary by the Environmental Manager or top management.

Where the nonconformance is considered to be serious, the frequency of review may be increased in order to ensure effective control. Where a nonconformance is detected, changes to procedures, work instructions, training and checklists may be implemented to prevent the recurrence.

Complaints

Major corrective action is necessary when the nonconformance includes complaints which have legal or financial impact or which might impact upon the reputation of the organisation.

Minor corrective action is necessary when the nonconformance includes complaints which are minimal or low impact and are easily resolved, with no long-term effects.