10.1 Nonconformity and corrective action
Relevant Definitions:
Requirement: | need or expectation that is stated, generally implied or obligatory |
Nonconformity: | non-fulfilment of a requirement |
Corrective Action: | action to eliminate the cause of a nonconformity and to prevent recurrence |
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Conformity to requirements, taking action to address the consequences of not conformity to requirements, or to take action to ensure they don't occur again, is the crux of this clause.
The standard here is asking that you consider requirements that are:
- requirements of this standard, such as documentation, evidence and process
- requirements of interested parties, borne out by their expectations of certain actions or behaviour by your organization
- requirements that are such because they are common or expected practice by your organization
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Nonconformities could be:
- lack of required documentation, action, policy, procedures and processes required by this standard;
- ineffective implementation of them; or
- lack of awareness by those doing work under the control of the organisation of the requirements
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Pre-Event Planning Phase:
In this phase nonconformities could be the realisation that requirements dictated within the standard are not in place, for example the non-existance of a Policy! In this case, the 'corrective action' would be to create a policy and ensure it is documented and communicated, along with the other requriements of the standard around policy.
Other more subtle nonconformities could be the failure of effective engagement with stakeholders over a particular issue, even if the steps outlined by the standard are in place - i.e. the existence of procedure and process documentation to direct the communications and engagement process. In this case a corrective action to take would be to re-address the engagement process and identify other communications and engagement routes and strategies, and importantly, to document the new approach and its outcomes.
In this last example, the documenting of the outcomes of communication is both a requirement of the 'Interested Parties' clause (4.2), and a requirement of documenting corrective action, as per this clause (10.1).
During the Event:
The 'identification of nonconformities and taking of corrective action' may occur during the event. This is likely to be 'Operational Control' based and a nonconformity to the planned operation and implementation of procedures and processes. Nonconformities could be the complete absence of implementing a plan.
For example forgetting to go around and induct food traders onsite as to the waste systems set up. The corrective action to take in this case, of course, is to go around and brief the food traders! Being able to identify the nonconformity could be through having a process onsite whereby the staff member responsible must report in to a supervisor that the inductions has occurred, and through that process, either the staff member or the supervisor identifies that the inductions have not yet occurred. Another way to identify this could be to have a big action list of inductions required (across all types of subject areas) in the site office, and for the various team members to have to check it off when complete. Thus a very public reminder of what needs to be done. The Site Office manager could be in control of chasing all staff members responsible for undertaking inductions.
Another example of a nonconformity could be the failure of a planned system, no matter how carefully executed. This failure could be a result of either poor foresight or knowledge by the team in the planning phase, or through circumstances outside of their control such as weather, unexpected attendance, clashes with other events or local activities, or failure by a contractor or supplier to deliver products or services as expected. In these cases, no matter the cause of the nonconformity, steps must be taken to address this in real time.
For example enough bins not being delivered, or not delivered on-time to allow enough time for effective placement and set-up. Several things are critical for effective corrective action to play out. First is for the team to have the skills and knowledge to be able to identify the nonconformity and to be able to foresee the consequeences to the sustainability performance of this nonconformity. Next for the team to CARE about the consequences enough to be bothered to take action. And thirdly is that staff responsible for taking corrective action to have the organisational competencies to deal with the challenge at hand. This is the base skill-set of any event organiser, and so we will have to assume that all staff engaged on an event have this most critical of abilities!
Post-Event Debrief:
Post event, the nonconformities that occurred pre and during the event, should be documented, including who was responsible for the correcting the nonconformity, what action was taken, what the outcomes were and how this will be included in future plans, procedures and processes to ensure it will not re-occur. Included in this process and documentation of it will be who will take these next steps, how a review will occur to ensure the new steps are embedded, and the timetable for both.
During the event debrief, the operations of the event will be the most likely targets undergoing scrutiny. Use this opportunity to review the accuracy of your issues identification processes, the implementation of plans to address issues and the operational control mechanisms and their effectiveness. Log nonconformities either with documented plans, policy, procedures and processes. Identify ways to take steps to ensure these nonconformities do not occur again.
Taking mobile power supply as an example - the plan could have been to have 4 generators or a certain size positioned across the event site so that stage lighting and sound is on one generator, site infrastructure/toilets etc on another, bars and caterers on a separate generator and overnight refrigerators on the last. Upon delivery, it may ensue that only two (larger) generators were supplied due to a mix-up at the generator supplier's depot and non-availability of the four smaller units. Whilst the actual supply of power has not been effected, and the event can still go on as planned, the sustainability performance impact could be that significantly higher fuel wastage (and GHG emissions) occurs, as both generators now need to be on overnight, with a significantly low power draw on them.
Corrective action to take in this case, could not be done in real time, as there was no solution to be had as the event site plan could not be altered in time and the smaller generators were just not available. The corrective action to take post-event, is to identify that the non-delivery of planned generators is a possible issue to be identified early, with the supplier. To discuss with them ways to ensure this does not occur, and if necessary include guarantees by them and penalties by you, to ensure prioritisation of correct delivery of generators at future events. Basically you are documenting this issue - what occurred last time, and what the planned intervention could be to ensure it doesn't happen next time - and raising the flag on this issue for future event teams, (or as a reminder to current ones) that this is an issue to be addressed.
Connection to Internal Audit (9.3)
The internal audit process is the main vehicle through which you will identify nonconformities and plan for corrective action. This clause (10.1) is describing in more detail how to document the nonconformity and corrective action. As such it requries you to have a procedure which outlines the authority, schedule and process for identifying and correcting nonconformities to the standard. This includes the documentation required, the implementation of procedures and processes, and awareness of requirements.
The key take away from all of this is that learnings have been achieved and new processes established for future activity control.
Suggested Steps:
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- Create a procedure which includes identifying non-conformities and steps to corrective action. See an example procedure here.
- Create a nonconformity logging form/report template.
- Ensure all staff are aware of the requirements and the actions they must take.
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Requirements of this Clause:
To meet the requirements of ISO 20121 you are recommended you have a procedure that outlines the authority, schedule and process for identifying and correcting nonconformity to the standard. This includes the documentation required, the implementation of procedures and processes, and awareness of requirements.
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- Non-conformities should be documented
- Who is responsible for the correcting the non-conformity should be documented
- Who will review action taken should be documented
- Timetables for both must be documented
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