ISO 14001:2015 Clause 10.2 Nonconformity and corrective action

ISO 14001:2015 Requirements

When a nonconformity occurs, the organization shall:

1. react to the nonconformity and, as applicable:
   • take action to control and correct it;
   • deal with the consequences, including mitigating adverse environmental impacts;
2. evaluate the need for action to eliminate the causes of the nonconformity, in order that it does not recur or occur elsewhere, by:
   • reviewing the nonconformity;
   • determining the causes of the nonconformity;
   • determining if similar nonconformities exist, or could potentially occur;
3. implement any action needed;
4. review the effectiveness of any corrective action taken;
5. 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).
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.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

One of the key purposes of an environmental management system is to act as a preventive tool. The concept of preventive action is now captured in 4.1 (i.e. understanding the organization and its context) and 6.1 (i.e. actions to address risks and opportunities).

1) When a nonconformity occurs, the organization shall react to the nonconformity

In EMS (Environmental Management System), non-conformities refer to instances where an organization’s activities, products, or processes do not conform to its established environmental management standards, policies, or legal requirements. Reacting to non-conformities is a crucial aspect of maintaining and improving an EMS. Here’s how an organization should typically react to non-conformities:

• Establish a robust system for identifying and documenting non-conformities. This can be done through regular audits, inspections, monitoring, and employee reporting.
• Determine the significance and potential environmental impact of the non-conformity. Some non-conformities may be minor and have minimal environmental impact, while others could be more significant.
• Take immediate corrective actions to address the non-conformity. This may involve stopping the non-conforming activity, isolating non-conforming products, or implementing temporary fixes to prevent further environmental harm.
• Conduct a thorough investigation to identify the root causes of the non-conformity. This involves analyzing why the non-conformity occurred and what factors contributed to it.
• Develop a corrective action plan that outlines the steps to be taken to prevent the recurrence of the non-conformity. This plan should address the root causes and be specific, measurable, achievable, relevant, and time-bound (SMART).
• Implement the corrective actions as outlined in the plan. Assign responsibilities to individuals or teams, and ensure that the actions are carried out effectively.
• Continuously monitor and verify the effectiveness of the corrective actions. This may involve follow-up inspections, testing, and performance tracking.
• Maintain thorough records of the non-conformity, corrective actions taken, and the verification process. Proper documentation is essential for compliance and future reference.
• Communicate the non-conformity and corrective actions to relevant stakeholders, including employees, suppliers, customers, and regulatory authorities if necessary.
• Identify opportunities for preventive actions to reduce the likelihood of similar non-conformities occurring in the future. This may involve updating procedures, improving training, or changing processes.
• Periodically review the effectiveness of the corrective actions and preventive measures. Use this information to make continuous improvements to the EMS and related processes.
• Present information about non-conformities, corrective actions, and preventive actions during EMS management reviews. Top management should be involved in assessing the overall effectiveness of the EMS.
• Ensure that the organization remains in compliance with relevant environmental laws and regulations throughout the process.

Reacting to non-conformities in an EMS is not just about fixing immediate problems but also about learning from them and making systemic improvements to prevent their recurrence. This proactive approach helps organizations minimize environmental risks and continuously improve their environmental performance.

2) When a nonconformity occurs, the organization shall take action to control and correct it

When a nonconformity occurs in EMS, the organization must first make correction before taking corrective action.In the context of EMS (Environmental Management System) and quality management systems, the terms “correction” and “corrective action” have specific meanings:

1. Correction: Correction refers to the immediate actions taken to address the immediate nonconformity or problem. These actions are typically aimed at fixing the issue at hand, preventing it from getting worse, or temporarily stabilizing the situation. Correction is about addressing the symptoms and ensuring that the nonconformity does not escalate.
2. Corrective Action: Corrective action, on the other hand, goes beyond correction. It involves a systematic investigation to determine the root causes of the nonconformity. Corrective actions are aimed at preventing the nonconformity from recurring in the future by addressing the underlying causes.

So, in practice, when a nonconformity occurs in an EMS:

• The organization must first implement correction measures to address the immediate issue and prevent it from getting worse or causing further environmental harm.
• After correction, a more in-depth investigation should be carried out to identify the root causes of the nonconformity.
• Based on the findings from this investigation, the organization can then develop and implement corrective actions to prevent similar nonconformities from happening again in the future.

In summary, correction is the immediate response to the nonconformity, while corrective action addresses the root causes and aims to prevent recurrence. Both steps are important in effectively managing nonconformities within an EMS and ensuring continuous improvement in environmental performance.

3) When a nonconformity occurs, the organization shall deal with the consequences, including mitigating adverse environmental impacts

Dealing with non-conformity in an organization, especially when it involves adverse environmental impacts, is crucial for maintaining compliance, reducing risks, and promoting sustainability. Here’s a step-by-step approach on how to handle non-conformity and mitigate its adverse environmental impacts:

• Establish a robust system for identifying and reporting non-conformities, whether they are related to environmental regulations, internal policies, or industry standards.
• Encourage employees, suppliers, and other stakeholders to report non-conformities promptly.
• Conduct a thorough investigation to determine the root causes of the non-conformity. Use techniques like the “5 Whys” to get to the underlying issues.
• Assess the scope and severity of the non-conformity, including its environmental impact.
• Take immediate corrective actions to address the non-conformity and prevent further harm to the environment. This may involve stopping the activity causing the issue. Ensure that actions are effective and tailored to the specific problem.
• Maintain detailed records of the non-conformity, including the investigation process and the corrective actions taken. Proper documentation is essential for accountability and compliance purposes.
• Notify relevant stakeholders, both internal and external, about the non-conformity and the actions being taken to address it. Be transparent and honest in your communication to build trust with stakeholders.
• Develop and implement preventive measures to avoid similar non-conformities in the future. This may involve revising processes, enhancing employee training, or updating policies and procedures.
• Ensure that the organization complies with all relevant environmental laws and regulations. Seek legal counsel if necessary to understand the full extent of legal obligations and potential liabilities.
• Conduct a comprehensive assessment of the environmental impacts caused by the non-conformity. This assessment should include short-term and long-term consequences.
• Develop and implement a mitigation plan to minimize the adverse environmental impacts. This may include remediation efforts, restoration of affected areas, or compensation for environmental damages.
• Use the lessons learned from dealing with the non-conformity to improve environmental management practices continuously.
• Report on your organization’s progress in addressing the non-conformity and mitigating its environmental impacts to relevant stakeholders and authorities as required.
• Invest in training and raising awareness among employees and stakeholders about environmental responsibilities and the importance of conformity.

Dealing with non-conformity and its environmental consequences requires a systematic and proactive approach, emphasizing prevention, accountability, and continuous improvement to protect the environment and maintain compliance with regulations.

3) When a nonconformity occurs, the organization shall to eliminate the causes of the nonconformity, in order that it does not recur or occur elsewhere

To ensure that non-conformances do not recur in an Environmental Management System (EMS) or occur elsewhere in the organization, you need to implement a robust system for addressing and preventing non-conformities. Here are steps to help you achieve this:

• When a non-conformance occurs, conduct a thorough root cause analysis to understand why it happened. Use techniques like the “5 Whys” or Fishbone (Ishikawa) diagrams to dig deep into the underlying causes. Ensure that the root cause analysis is comprehensive and identifies both immediate and systemic causes.
• Develop and implement corrective actions based on the findings of the root cause analysis. Corrective actions should directly address the identified causes of the non-conformance. Ensure that corrective actions are well-documented, specific, and have clear timelines for completion.
• Verify and validate the effectiveness of the corrective actions. Ensure that they have indeed addressed the root causes and resolved the non-conformance. Use data and evidence to confirm that the issue has been rectified.
• In addition to corrective actions, establish preventive actions to eliminate the potential for similar non-conformances in the future. Preventive actions should focus on addressing systemic issues that could lead to non-conformances elsewhere in the organization.
• Maintain detailed records of non-conformances, root cause analyses, corrective actions, and preventive actions. Documentation is essential for tracking progress, demonstrating compliance, and facilitating audits.
• Ensure that employees are trained and made aware of the non-conformance, its root causes, and the actions taken to address it. Training should emphasize the importance of compliance with EMS procedures and environmental regulations.
• Implement a robust monitoring and surveillance system to track the effectiveness of corrective and preventive actions. Use key performance indicators (KPIs) to measure progress and compliance.
• Include discussions of non-conformances and actions taken in regular management reviews. Use these reviews to assess the overall performance of the EMS and make necessary adjustments.
• Continuously review and improve EMS processes, policies, and procedures to prevent non-conformances. Encourage a culture of continuous improvement and innovation.
• If applicable, report non-conformances and their resolution to relevant external stakeholders, regulatory bodies, or certification agencies.
• Share the lessons learned from non-conformances and their resolutions across the organization. Encourage a culture of knowledge sharing to prevent similar issues in other areas.
• Involve relevant stakeholders, including suppliers and contractors, in efforts to prevent non-conformances throughout the supply chain.
• Regularly audit and review the EMS to ensure ongoing compliance and effectiveness in preventing non-conformances. Use audit findings to identify areas for improvement.

By following these steps and fostering a culture of continuous improvement and environmental responsibility, organizations can minimize the risk of non-conformances in their EMS and ensure they do not recur or occur elsewhere. Preventing non-conformances is not just about addressing issues when they arise but also about proactively identifying and mitigating potential risks to the environment.

4) when non conformity occurs the organization must be reviewing the nonconformity; determining the causes of the nonconformity; determining if similar nonconformities exist, or could potentially occur.

Absolutely, when a non-conformity occurs within an organization, it’s crucial to follow a systematic process that includes the steps you mentioned:

1. Reviewing the Nonconformity: Start by thoroughly reviewing the non-conformity to understand the nature and scope of the issue. Document the specifics of the non-conformity, including where and when it occurred, who was involved, and any relevant details about the situation.
2. Determining the Causes of the Nonconformity: Conduct a root cause analysis to identify why the non-conformity happened. Use techniques like the “5 Whys” or Fishbone (Ishikawa) diagrams to delve into the underlying causes. Ensure that you identify both the immediate or proximate causes and the deeper, systemic causes that contributed to the non-conformity.
3. Determining if Similar Nonconformities Exist or Could Occur: Investigate whether similar non-conformities exist in other parts of the organization or could potentially occur. This involves a proactive assessment of processes, procedures, and potential risks to identify areas where similar issues might arise.

These steps are essential in addressing the immediate non-conformity and in preventing its recurrence. Identifying the root causes and assessing the potential for similar non-conformities helps organizations implement corrective and preventive actions that go beyond just fixing the immediate issue. It promotes a culture of continuous improvement and risk mitigation, which is crucial for the long-term success of any quality or environmental management system.

5) When a nonconformity occurs, the organization shall implement any action needed;

Implementing corrective actions in response to non-conformities within an organization’s Environmental Management System (EMS) is a critical step in resolving issues, preventing their recurrence, and maintaining compliance with environmental regulations. Here’s a step-by-step guide on how to effectively implement corrective actions:

• Start by documenting the specific corrective actions that need to be taken based on the root cause analysis of the non-conformity. Ensure that each corrective action is clear, specific, and includes the responsible person or team.
• Assign responsibility to individuals or teams who will be responsible for implementing each corrective action. Clearly communicate these responsibilities to ensure accountability.
• Establish clear timelines and deadlines for completing each corrective action. Make sure these timelines are realistic and achievable. Monitor progress regularly to ensure actions are on track.
• Ensure that the necessary resources, including personnel, tools, equipment, and budget, are allocated to support the implementation of corrective actions.
• Provide training or awareness programs to ensure that employees understand the corrective actions and how to execute them effectively.Ensure that employees are aware of the importance of these actions for environmental compliance.
• Begin implementing the corrective actions according to the documented plan and within the specified timelines.Monitor the execution of actions to ensure they are carried out as intended.
• Maintain detailed records of the implementation process for each corrective action. This documentation should include progress reports, task completion dates, and any deviations from the plan.
• After the corrective actions have been implemented, verify their effectiveness. This step confirms that the actions have indeed resolved the non-conformity.Use data and evidence to confirm that the issue has been rectified and that there is no recurrence.
• Once the corrective actions have been successfully implemented and verified, formally close the non-conformity report.Communicate the closure to relevant stakeholders and document it for records.
• Continuously monitor the area or process where the non-conformity occurred to ensure that the corrective actions remain effective.Use key performance indicators (KPIs) to track and measure progress.
• Include the corrective actions and their effectiveness in regular management reviews of the EMS. Ensure that the organization maintains a commitment to continuous improvement.
• Encourage feedback from employees and stakeholders involved in the corrective actions. Collect lessons learned to improve the organization’s response to non-conformities in the future.
• Consider implementing preventive actions to address systemic issues that may have contributed to the non-conformity and to prevent similar issues from occurring in the future.

By following these steps and maintaining a disciplined approach, organizations can effectively implement corrective actions to address non-conformities in their EMS. This not only resolves immediate issues but also helps build a culture of environmental responsibility and continuous improvement.

6) When a nonconformity occurs, the organization shall review the effectiveness of any corrective action taken

Reviewing the effectiveness of corrective actions taken in response to a non-conformity related to an Environmental Management System (EMS) is crucial to ensure that the problem has been resolved, and the likelihood of recurrence is minimized. Here’s a systematic approach to reviewing the effectiveness of corrective actions:

• Before implementing corrective actions, define specific success criteria or key performance indicators (KPIs) that will help assess whether the corrective actions have been effective. Success criteria should be measurable and aligned with the objectives of the corrective actions.
• Continuously monitor the situation or process where the non-conformity occurred after the corrective actions have been implemented. Collect data and evidence to track progress and verify that the non-conformity has been resolved.
• Analyze the collected data to determine whether the defined success criteria have been met.Use statistical methods or trend analysis to identify any trends or patterns that could indicate a recurrence of the non-conformity.
• Validate the effectiveness of the corrective actions by comparing the current state with the state before the non-conformity occurred. Ensure that any identified root causes have been addressed and that the non-conformity is no longer present.
• Seek feedback from relevant stakeholders, including employees, supervisors, and other involved parties, to gauge their perceptions of whether the corrective actions have been effective. Encourage open communication to identify any lingering concerns or issues.
• Conduct internal audits or reviews specifically focused on assessing the effectiveness of corrective actions. Ensure that the audit scope covers the areas impacted by the non-conformity.
• Include a review of corrective action effectiveness in regular management review meetings for the EMS. Management should evaluate the data, feedback, and audit results to make informed decisions about the ongoing effectiveness of the actions.
• Maintain comprehensive records of all data, analysis, feedback, and decisions related to the review of corrective action effectiveness. Proper documentation is essential for demonstrating compliance and facilitating audits.
• Use the results of the effectiveness review to drive continuous improvement within the EMS. If the corrective actions were effective, consider how similar issues can be prevented in the future. If not, identify areas for further improvement.
• Communicate the findings of the effectiveness review to relevant stakeholders, including employees, management, and, if applicable, external parties such as regulatory authorities or certification bodies.
• If the review identifies any issues with the effectiveness of corrective actions, take further action to adjust and re-implement corrective measures as needed. Repeat the review process as necessary until the non-conformity is fully resolved and recurrence is unlikely.

By following these steps and maintaining a commitment to continuous improvement, organizations can ensure that corrective actions taken in response to EMS non-conformities are effective in addressing the root causes and preventing future occurrences. This contributes to the organization’s environmental sustainability and regulatory compliance efforts.

7) When a nonconformity occurs, the organization shall make changes to the environmental management system, if necessary.

When a nonconformity occurs within an Environmental Management System (EMS), the organization should indeed consider making changes to the EMS if necessary. The objective is to prevent similar non-conformities in the future, enhance the EMS’s effectiveness, and continuously improve environmental performance. Here’s how the organization can approach making changes to the EMS:

• Before making any changes, conduct a thorough root cause analysis to understand why the nonconformity occurred. Identify any deficiencies or weaknesses in the EMS processes or procedures that contributed to the nonconformity.
• Based on the findings of the root cause analysis, assess whether changes to the EMS are necessary to address the root causes and prevent similar non-conformities. Consider the severity and frequency of the non-conformity, as well as its potential environmental impact.
• If deficiencies or weaknesses in EMS procedures or processes are identified, revise them as needed to eliminate these issues.Ensure that the revised procedures are clear, effective, and aligned with environmental objectives.
• Provide training to employees and relevant stakeholders on the revised procedures and any changes made to the EMS.Ensure that everyone involved is aware of the updates and understands their roles and responsibilities.
• Document all changes made to the EMS, including the rationale behind each change and the date of implementation.Communicate these changes throughout the organization to ensure everyone is informed.
• Incorporate the changes into the internal audit process to verify compliance with the updated procedures and identify any additional areas for improvement.
• Implement a system for ongoing monitoring and measurement to assess the effectiveness of the changes and ensure they have the desired impact.Use key performance indicators (KPIs) to track progress.
• Include a review of the changes and their impact in regular management review meetings for the EMS.Management should evaluate whether the changes have resulted in the desired improvements and make further decisions as necessary.
• Continuously assess the EMS and look for opportunities to further enhance its performance, even beyond addressing the immediate non-conformity.Encourage a culture of continuous improvement within the organization.
• If required by regulations or stakeholders, report the changes made to the EMS to relevant external parties, such as regulatory authorities or certification bodies.

The decision to make changes to the EMS should be driven by a thorough assessment of the non-conformity’s root causes and the organization’s commitment to environmental responsibility. It’s a proactive approach to prevent recurrence and align the EMS with best practices and regulatory requirements.

8) Corrective actions shall be appropriate to the significance of the effects of the nonconformities encountered, including the environmental impact(s).

Absolutely, the appropriateness of corrective actions should be directly related to the significance of the effects of the nonconformities encountered, including their environmental impact. This principle aligns with the fundamental concept of risk-based thinking within an Environmental Management System (EMS). Here’s how organizations can ensure that corrective actions are commensurate with the significance of the nonconformities:

• Begin by assessing the significance of the nonconformities, particularly in terms of their environmental impact. Consider factors such as the severity, duration, extent, and potential harm to the environment.
• Conduct a risk analysis to determine the potential consequences and likelihood of recurrence of the nonconformities. High-risk nonconformities with significant environmental impacts should receive more rigorous and immediate corrective actions.
• Match the corrective actions to the level of risk and significance of the nonconformities. For high-impact nonconformities, prioritize and implement more comprehensive and immediate corrective actions.
• Consider implementing preventive actions in addition to corrective actions, especially for nonconformities with high environmental significance. Preventive actions aim to proactively eliminate potential risks and prevent similar issues in the future.
• Allocate the necessary resources, including personnel, equipment, and budget, based on the significance of the nonconformities. High-impact nonconformities may require more resources to ensure effective resolution.
• Document the rationale behind the choice of corrective actions, including how they are commensurate with the significance of the nonconformities. Keep records of the assessment, risk analysis, and resource allocation.
• Verify and validate the effectiveness of corrective actions to confirm that they have indeed addressed the nonconformities’ environmental impact. Validation may involve measuring environmental performance indicators to ensure compliance and improvement.
• Clearly communicate the nature and significance of the nonconformities and the corresponding corrective actions to relevant stakeholders, including employees, regulatory authorities, and interested parties.
• Regularly review the effectiveness of corrective actions in relation to the nonconformities’ significance. Adjust the actions as necessary to achieve the desired environmental outcomes.
• Include discussions of corrective actions and their effectiveness, especially for nonconformities with significant environmental impacts, in regular management review meetings for the EMS.
• Ensure that the organization complies with any reporting requirements related to significant nonconformities, as specified by regulatory authorities or certification bodies.

By aligning corrective actions with the significance of nonconformities and their environmental impacts, organizations can better protect the environment, meet regulatory requirements, and demonstrate a commitment to sustainable and responsible environmental management.

9) The organization shall retain documented information as evidence of the nature of the nonconformities and any subsequent actions taken and the results of any corrective action.

it is essential for the organization to maintain detailed records of nonconformities, including the nature of the nonconformities, any subsequent actions taken, and the results of corrective actions. Proper documentation is a fundamental requirement for ensuring compliance, demonstrating accountability, and facilitating effective environmental management. Here’s how to manage these records effectively:

1. Recording Nonconformities: When a nonconformity is identified, document the specific details of the nonconformity. This includes information such as where and when it occurred, who reported it, and any relevant environmental impacts.
2. Recording Corrective Actions: Document the corrective actions taken to address the nonconformity. Include information about what actions were implemented, who was responsible for them, and the timelines for completion.
3. Nature of Nonconformities: Record the nature of the nonconformities accurately and comprehensively. Describe the underlying causes and the extent of the environmental impact, if applicable.
4. Results of Corrective Action: After corrective actions have been implemented, document the results and outcomes of these actions. This may include data, measurements, or assessments that demonstrate the effectiveness of the corrective actions.
5. Documentation Format: Use a standardized format or template for documenting nonconformities and corrective actions. This ensures consistency and makes it easier to track and retrieve information.
6. Timestamps and Signatures: Include timestamps to indicate when each record was created or updated. Ensure that relevant personnel, such as the individuals responsible for corrective actions, sign off on the records to confirm their accuracy.
7. Retention Period: Establish a clear policy regarding the retention period for these records. Ensure that records are retained for a duration consistent with legal requirements and the organization’s needs.
8. Accessibility and Security: Store records in a secure and easily accessible manner. Electronic document management systems can be useful for this purpose. Ensure that authorized personnel can access these records when needed for audits, reviews, or reporting.
9. Reporting: Use the records to prepare reports on the status and trends of nonconformities and corrective actions within the EMS. Reports can provide valuable insights for management decision-making and continuous improvement.
10. Management Review: Include a review of nonconformity records and the effectiveness of corrective actions in regular management review meetings for the EMS. Management should use this information to assess the overall performance of the EMS.
11. External Reporting and Certification (if applicable): If required by regulations or stakeholders, provide records and reports related to nonconformities and corrective actions to relevant external parties, such as regulatory authorities or certification bodies.

Effective recordkeeping of nonconformities and corrective actions is not only a compliance requirement but also a valuable tool for identifying trends, improving environmental performance, and demonstrating a commitment to environmental responsibility and sustainability.

Example of procedure for Nonconformity and corrective action in ISO 14001

Objective: The objective of this procedure is to define the process for identifying, documenting, investigating, and addressing nonconformities within the EMS. It outlines the steps for taking corrective action to prevent recurrence and improve environmental performance.

Scope: This procedure applies to all employees, contractors, and stakeholders involved in the organization’s EMS.

Responsibilities:

• EMS Manager: Overall responsibility for overseeing the procedure.
• Environmental Management Representative: Ensures compliance with ISO 14001 and manages nonconformities.
• Employees and Contractors: Report nonconformities and assist in investigations.

Procedure:

1. Identification of Nonconformity:

• Any employee or stakeholder who identifies a nonconformity related to the EMS should immediately report it to the Environmental Management Representative or designated authority.
• Nonconformities may be identified through audits, inspections, monitoring, incident reports, or other sources.

2. Recording and Documentation:

• The Environmental Management Representative shall document all reported nonconformities using a Nonconformity Report (NCR) form. The NCR should include:
  • Date and time of identification
  • Location and description of the nonconformity
  • Person(s) reporting the nonconformity
  • Environmental impacts and significance
  • Immediate actions taken, if applicable

3. Evaluation and Classification:

• The Environmental Management Representative shall evaluate the reported nonconformity to determine its significance and potential environmental impact.
• Nonconformities are classified based on their significance (e.g., minor, major, critical) and potential risk to the environment.

4. Root Cause Analysis:

• For major or critical nonconformities, a root cause analysis shall be conducted to identify the underlying causes.
• Techniques such as the “5 Whys” or Fishbone (Ishikawa) diagrams may be used.

5. Corrective Action Planning:

• Based on the root cause analysis, a Corrective Action Plan (CAP) shall be developed. The CAP should include:
  • Detailed corrective actions to address root causes
  • Responsible parties
  • Timelines for completion
  • Resource allocation

6. Corrective Action Implementation:

• Responsible parties shall implement the corrective actions as outlined in the CAP.
• Immediate actions may be taken to prevent further environmental harm, even before the CAP is fully implemented.

7. Verification of Corrective Actions:

• The Environmental Management Representative shall verify the effectiveness of the corrective actions through assessments, measurements, or other appropriate means.

8. Documentation of Corrective Actions:

• Document the corrective actions taken, including verification results, in the NCR form or a separate Corrective Action Report (CAR).

9. Closure of Nonconformity:

• Once the corrective actions have been successfully implemented and verified, the nonconformity shall be considered closed.
• The NCR or CAR shall be updated to reflect the closure status.

10. Reporting and Communication: Communicate the resolution of nonconformities to relevant stakeholders, including employees, management, and regulatory authorities if required.

11. Records Retention: Maintain records of nonconformities, root cause analyses, corrective actions, and verification for the specified retention period.

12. Continuous Improvement: – Use lessons learned from nonconformities to drive continuous improvement in the EMS.

Examples of Nonconformity and corrective action in ISO 14001

Example 1: Nonconformity – Unauthorized Discharge of Pollutants

• Nonconformity: An employee was observed improperly disposing of hazardous waste down the drain, which is in violation of environmental regulations.
• Corrective Actions:
  1. Immediate containment: Stop the unauthorized discharge immediately.
  2. Identify and segregate the waste: Determine the type of waste and ensure proper containment.
  3. Cleanup and disposal: Arrange for the safe and proper disposal of the waste in compliance with regulations.
  4. Training and awareness: Provide training to employees on proper waste disposal procedures and the importance of compliance.
  5. Monitoring and inspection: Implement regular monitoring and inspection to prevent future unauthorized discharges.

Example 2: Nonconformity – Inadequate Record-keeping for Chemical Inventory

• Nonconformity: The organization failed to maintain accurate records of its chemical inventory, which is required by environmental regulations.
• Corrective Actions:
  1. Conduct an immediate inventory assessment: Verify the current chemical inventory and identify any discrepancies.
  2. Establish proper record-keeping procedures: Develop and implement a robust system for recording chemical inventory data, including types, quantities, locations, and safety data sheets.
  3. Retrospective documentation: Document the existing inventory as accurately as possible.
  4. Employee training: Train personnel responsible for chemical inventory management on the new procedures.
  5. Auditing and monitoring: Implement regular audits and inspections to ensure ongoing compliance with record-keeping requirements.

Example 3: Nonconformity – Exceeding Emissions Limits

• Nonconformity: During a routine emissions monitoring process, it was discovered that emissions from a manufacturing process exceeded permissible limits outlined in environmental permits.
• Corrective Actions:
  1. Immediate action: Cease the manufacturing process responsible for the emissions until the issue is resolved.
  2. Investigation: Identify the root causes of the emissions exceedance through thorough testing and analysis.
  3. Mitigation: Implement immediate measures to reduce emissions to permissible levels, which may include process adjustments or equipment upgrades.
  4. Reporting: Notify relevant regulatory authorities of the exceedance and provide a plan for corrective action.
  5. Corrective action plan: Develop a comprehensive plan for preventing future exceedances, which may involve process redesign, improved monitoring, and enhanced employee training.
  6. Continuous monitoring: Implement continuous emissions monitoring and real-time reporting systems to prevent future nonconformities.

Example 4: Nonconformity – Failure to Report Environmental Incidents

• Nonconformity: The organization failed to report a significant environmental incident, such as a chemical spill, within the required timeframe to regulatory authorities.
• Corrective Actions:
  1. Immediate reporting: Report the incident to regulatory authorities as soon as possible, even if it is past the initial deadline.
  2. Internal investigation: Investigate why the reporting was not done within the required timeframe.
  3. Regulatory compliance review: Review and revise procedures to ensure timely reporting in the future.
  4. Training and awareness: Reinforce the importance of timely incident reporting to all relevant personnel.
  5. Monitoring and reminders: Implement reminders and tracking mechanisms to ensure compliance with reporting requirements.