No Quality, WHS or Environmental System is perfect and no business is perfect. Problems may occur with the service you provide, your products, your processes, and your suppliers, the result being that stated requirements are not met. Those requirements might be stated in the specifications for the product, the service level agreements, a regulatory body, or your own internal procedures.
In the language of management systems these problems are called non-conformances, but you may call them anything you like. It simply means that something went wrong – a problem has occurred and needs to be addressed.
A non-conformance could be identified through, for example, customer complaints, regulatory authorities, work, health & safety incident reports, environmental incidents, audits, incoming material inspections or simply during normal monitoring activities.
ISO 9001 for Quality, ISO 14001 for the Environment, ISO 18001 and AS/NZS 4801 for WHS all require that you have a written non-conformance procedure and keep records of the issues you identify and the actions taken. This procedure needs to explain how you:
- Identify the problem.
- Determine the extent of the problem – how much has been made, how bad is it.
- Determine when and how a non-conformance is recorded – in some circumstances if the problem can be fixed immediately it need not be recorded as a non-conformance.
- Prevent the problem material, product-in-progress, finished product, or service from being used until it is fixed or scrapped – for example by placing a special label on it, by placing it in a special area set aside for defective products.
- Where it is fixed, how you check that it now complies – normally the product or service would go through the same checks as “good” products and services.
- Come up with the solution – how you are going to fix the problem.
- Implement the solution – who will be responsible for implementing the solution and when must it be done by.
- Evaluate whether the solution was effective – that it actually fixed the problem.
- Determine whether further corrective action is necessary to address the root cause of the problem.
These solutions tend to be reactive – something has gone wrong and these are the actions taken to deal with the problem as quickly as possible. For example:
- A customer is unhappy about the service they received so you call them to discuss and resolve their issue.
- The temperature of cold raw materials is greater than 5oC so you send the delivery back.
- Waste water samples have not been taken for a day so you retrain the person who was meant to take them.
- During a WHS inspection you find emergency exits are obstructed so you have the objects removed.
- A product doesn’t meet the required safety standards and has to be recalled.
The standards also require that you record your non-conformances, actions taken and review of effectiveness. Normally a single page Non-conformance Report and/or a Non-conformance Register is used. If a Non-conformance Report is used then some of the information in it usually needs to be transferred to the Non-conformance Register/Log so that you can track them. Whenever possible, I prefer to use a Non-conformance Register/Log because it reduces the amount of ‘paperwork’. This is simply a table in which you list all the details of the non-conformance, your solution, who is responsible for implementing the solution and by when, and the review of effectiveness. I usually do it in Excel as then I can filter the non-conformances which helps in determining where to focus my corrective action efforts and how to best address the root cause. Customer complaints are also non-conformances and can be handled in this way although most businesses prefer to record them separately.
But wait, there’s more. Dealing with non-conformances effectively means not just finding the quick-fix solution but also taking corrective actions to ensure it doesn’t happen again, and again, and again. This leads one to the corrective action requirements in another clause in the Standards. More about this in the next article.