Why is it important to get the right category for a finding or a non conformance?
Well, for certification purposes, it’s a very important issue. A major non-conformity that is presented at any closing meeting for a certification audit means that the certification process cannot proceed until the issue has been properly addressed. For UKAS accredited certification bodies, this means that appropriate corrective and preventive action has been put in place to deal with the issue raised.
Often this relates to a legal compliance issue. For OHSAS 18001 an example may relate to the fact that pressure vessels have not had their inspection and therefore the insurance associated with such equipment is not valid. This happened during a recent audit, but the measures put into place were swift and comprehensive, the preventive action was accepted by our audit team, and as a result the certification process was only slowed down by a week or so. A legal compliance issue usually relates to a major nonconformity, but other examples abound.
In the environmental side (ISO 14001) an example of a major nonconformity that I raised related to the a waste skip. It contained swarf (metal turnings from the enginnering sector). That swarf was dripping in cooling oil from the lathes where it arose. The metal swarf was put into a large skip outside and this was bunded. At intervals of about 2 weeks, the bund was emptied out by an operator into a rain using a pump. The drain was assured to be a foul water drain, which still begged the question – “have you got a consent to do this”. It turned out to be a surface water drain (by inspecting drainage maps) and so we have a MAJOR nonconformity.
Other issues often generate minor nonconformities, which means that the MANAGEMENT SYSTEM has broken down, but only in a localised area which won’t have a significant legal issue or environmental concern.
At least the business can then deal with the issue. If not, the minor becomes a major by default at the next certification audit. In this way, we certification auditors have a way of escalating an issue if it is not being addressed in the right way.
Observations are items that COULD become findings, if the issue is not addressed. They don’t have to be acted upon, but act as items for discussion and consideration. The best organisations really do address these as though they are nonconformances.
So there it is, the new ISO 14001:2015 will have absolutely no influence on the way findings are determined, but it will provide a slightly different set of requirements. I will have a talk about some more of those issues in another blog.
Hope you enjoy these thoughts…. let me have your comments.
John Marsden (coming up for 20 years of certification audits – average of 100 days per year!) Thats a lot of audit days.