Virtually all certified organizations will receive non-conformances from their certification body auditor from time-to-time. Minor non-conformances -- in limited numbers – are to be expected. Correcting non-conformances is necessary to maintain certification, however, steps to prevent reoccurrences is also required. Continual improvement, including learning from non-conformances, is what makes an organization better, and separates certified facilities from the competition.
While a limited number of minor non-conformances may be acceptable, too many indicate a system that is not working. In such cases, suspension of the certificate may be necessary until the organization can demonstrate it is effectively meeting R2 requirements. Major non-conformances also indicate a system that is not working or may even be missing entire requirements or sections of the Standard.
Regardless of whether non-conformances are major or minor, the process for resolving them is the same. As an example, let’s consider a recycler that receives a non-conformance for failing to annually confirm that one of its downstream vendors continues to conform to the R2 Provision 5.e requirements.
Phases of resolution:
1. Correction – the immediate action to stop the non-conformance from occurring. In this case, removing the vendor from the “approved” list and stopping further sales or shipments to this vendor until due diligence has been completed and it is determined the vendor is properly qualified.
2. Root Cause Analysis – the non-conformance is evaluated to determine why it occurred. There is usually not one cause, but many compounding causes. Determining the root cause requires a deliberate process. Continuing with the example above:
- Was the non-conformance a result of not including downstream vendor confirmation in the monitoring program?
- Was there a change in the personnel responsible for managing downstream vendors?
- Was due diligence information gathered but never reviewed or approved?
Let’s say the root cause was determined to be that the responsible manager quit and re-evaluation was not part of the monitoring activities of the system.
3. Corrective Action – after determining the root cause, an appropriate corrective action plan can be developed to prevent reoccurrences of the non-conformance. Organizations often fail in this process because the real root cause is not identified, so consequently, the corrective action plan does not prevent the problem from recurring. It is important to remember that a repeat minor non-conformance, becomes a major non-conformance. So, it is essential to properly identify root causes and develop effective corrective action plans. The corrective action in this example might be:
- Add a monthly review of approved vendors to your monitoring calendar;
- Add a check by Sales to ensure the vendor is still approved before selling the product; and
- Add a check to the shipping department to verify the vendor is approved before preparing the shipment.
4. Verification – the final step in correcting a non-conformance is to verify that the corrective action is effective. This does not mean verifying that each step was implemented – it means verifying that the actions are achieving the intended goal. In this example, perhaps the operations manager receives the paperwork for every shipment during the next 6-month period to verify that each shipment is going to a current and properly qualified downstream vendor.
Bottom Line: Addressing a non-conformance is not only about stopping the non-conforming practice that was identified during the audit, it is about preventing it from reoccurring.