We're exploring a key piece of ISO 14001:2015, known as Clause 10.2. This section is all about identifying problems and taking steps to fix them for good. If that sounds a bit daunting, don't worry! We're going to simplify everything, so you'll walk away knowing how to make things right when they go wrong.
Before I get started on the clause, I think it’s important to understand the definition of a nonconformity. After all, if we don’t know how to recognize one then we won’t know when to take action, will we? Referring to clause 3 of ISO 14001 where the definition of a nonconformity states that it is a non-fulfilment of a requirement and the definition of a requirement is a need or expectation that is stated, generally implied or obligatory.
These requirements that we are bound to conform with may come from our customers, product or legal requirements, ISO Standard requirements, or even our own environmental management system requirements. Put simply, we need to identify and understand what our requirements are and then follow them. When we don’t that is a nonconformance.
This will now help us as we move through the clause requirements so let’s get started. Let’s take a look at what Clause 10.2 wants us to do. The clause starts off by stating ...
When a nonconformity occurs, the organization shall:
a) react to the nonconformity and, as applicable:
1) take action to control and correct it:
2) deal with the consequences, including mitigating adverse environmental impacts;
This action and dealing with the consequences can be referred to as the action. This is the first step we take to deal with the consequences of a nonconformance. This could be managing a chemical spill and isolating the area or machine that may have caused the spill and so on. Basically, mop up what’s happened and put some actions in place immediately to ensure nobody else or nothing else is impacted.
This is not a long-term fix or corrective action. It is just getting it under control initially.
The next part of the clause is where we look at the long-term fix or corrective action. Therefore, this clause goes on to state that the organization shall:
b)evaluate the need for action to eliminate the causes of the nonconformity, in order that it does not recur or occur elsewhere, by:
1) reviewing the nonconformity;
2) determining the causes of the nonconformity;
3) determining if similar nonconformities exist, or could potentially occur.
You will have noticed that the overarching goal is to prevent the nonconformity from recurring or occurring elsewhere. This is done by reviewing and analyzing the nonconformity to determine the cause or causes. By doing this we also have the opportunity to find out whether there have been similar nonconformities that have already occurred or have the potential to occur.
For example, if a nonconformance has been raised several times at different locations for workers not completing the Environmental site inspection checklist prior to work commencing, this may indicate that the root cause has not been identified and appropriate corrective action implemented as the issue continues to reoccur. This could be further exacerbated if an incident occurs, and the investigation identifies that the site inspection may have prevented this from occurring.
The intent is to investigate, determine the cause, and then implement corrective action to prevent the nonconformance from happening again, not only where they were identified in the first place, but in any other location or situation as well.
The next step is to review and analyze what occurred and how it actually happened. This might involve following the set process and timeframes, interviewing workers responsible for completing the environmental inspection checklists, reviewing the checklist itself, and so on. Once we have gone through this process, we should have identified the root and core cause of this issue. And then we can move on to implementing a corrective action that should prevent it from recurring or occurring elsewhere.
This leads us to the next part of this clause where it states that the organization shall...
c) implement any action needed;
d) review the effectiveness of any corrective action taken.
Not only do we implement the corrective action, but we should also be giving it sufficient time to be followed and used so that we can review whether it has effectively prevented the issue from recurring.
Therefore, in this example, if we identified that the root cause of this issue was the timeframe for completing the environmental inspections, then the schedule would be updated and any matching procedures, possibly communication or training would be conducted. Then the new process is followed and monitored for a period of time (normally based on risk) to ensure that the new process does ensure that the inspections are conducted when they have been scheduled.
Then to finalise the considerations the clause goes on to state...
e) make changes to the environmental management system, if necessary.
Corrective actions shall be appropriate to the significance of the effects of the nonconformities encountered, including the environmental impact(s).
These few points are saying that when there has been a nonconformity then part of the corrective action may include updates to the management system. This provides that final loop back from an Operations level up to a Systems level. And of course, the corrective action taken should be at a level that is suitable for what actually occurred. For example, a corrective action of firing all of the workers who didn’t complete the environmental inspections for is not proportionate to the actual issue and in particular even the root cause.
Then finally the clause states that...
The organization shall retain documented information as evidence of:
- the nature of the nonconformities and any subsequent actions taken;
- the results of any corrective action.
Any nonconformities identified need to be recorded as to what they were and what actions were taken, including the results (successful or otherwise) of the corrective action taken. This is normally in the form of a Nonconformance Register or Improvement Register – you can call it whatever you want, as long as it does record this information at a minimum. Other information that this register might also include that is helpful is:
- who is responsible
- the created or occurrence date
- the due date for corrective action
- the due date for review of implemented corrective action
- any links to photos or investigations
- identified by category (which might be an internal audit, external audit, daily operation, complaint, and so on
These are just a few additional fields that I have come across that help with analyzing ongoing improvements. This then makes it easy to communicate to workers and any other parties that may have been impacted by the nonconformance or will be impacted by the corrective actions.
Now that you have a better understanding of these requirements, it's time to take action and implement them in your own organization and ISO 14001 Environmental management systems.
If you're keen to expand your knowledge on ISO 14001, make sure to check out our other articles on the topic, starting with a comprehensive breakdown of What is ISO 14001:2015 Environmental management systems??
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