Mark Hammar When most people think of nonconformity, they immediately turn their thoughts to the management of nonconforming product in the ISO 9001 quality management system. While ISO 14001 includes requirements for dealing with nonconformity in the environmental management system, it does not have the same applicability, and the requirements are not as extensive. This article helps to explain why.
How the ISO 14001 requirements differ
When you are dealing with the requirements for an environmental management system in ISO 14001, you are not dealing with nonconforming product as you are in the ISO 9001 quality management system. In ISO 9001, the focus of the requirement is to have a method to control the product or service that is found to be nonconforming to the product or service requirements, so that it is not used or delivered without being corrected or accepted by the appropriate parties. However, when ISO 14001 speaks of nonconformity, the requirements refer to the nonconformity of a process with respect to the environmental aspects associated with that process. Additionally, ISO 14001 includes in the requirements a need to take action on potential nonconformities.
For help on understanding the environmental aspects, see: Environmental aspect identification and classification.
An example of how this would apply would be a process that has an environmental aspect that emits a small amount of a chemical into the air through a vent. The process may be designed and approved to emit less than 200 parts per million (ppm) into the atmosphere per day. Nonconformity would occur if this limit was exceeded; say the process emitted 250 ppm one day. When this happens, the company would need to have a process to deal with the nonconformity. Additionally, if the process was being monitored and it was noticed that the emissions were rising past the normal point and getting close to the 200 ppm limit, action would need to be taken to correct the problem.
How environmental nonconformity links with corrective and preventive actions
Nonconformity is more closely related to corrective action and preventive action in ISO 14001 than it is in the ISO 9001 standard. In a quality management system, not every nonconforming product or service would necessarily lead to a corrective action unless it was a recurring problem. Conversely, if you have a process that exceeds the limits set for the environmental aspects related to the process, it is much more likely that a corrective action will need to occur.
In the example above, the cause of the problem may have been identified as a filter that needs to be replaced, and this correction would be done, but an analysis of the root cause might find that the process for monitoring the filter needs to be improved so that it is changed before the process produces nonconforming emissions. If this occurred when the process went above the 200 ppm limit, this would be classified as a corrective action to the process, and if it was found and corrected before the limit was actually exceeded, the actions would be classified as preventive actions.
For a more complete look into how the corrective and preventive action system works, please see: Corrective and Preventive Actions to Support Environmental Management.
Important consideration for nonconformity, corrective and preventive action
There are two important considerations included in the requirements for nonconformity, corrective action, and preventive action. The first is that the actions taken need to be appropriate to the magnitude of the problems and the environmental impacts encountered. This means that you must consider the actions in light of how detrimental the impacts are to the environment. If you are reacting to a process that doubles its air emissions past the acceptable legal limit, you will have actions that are much different from those for a process that is found to only recycle 85% of the waste paper produced rather than the full 100%. The second consideration is that the documentation in place for the environmental management system needs to be changed, if necessary, due to the outcomes of the corrections, corrective actions, and preventive actions.
If you already have a quality management system in place, the processes already present can often be utilized by the environmental management system, but it is important to understand the differences in the needs so that you can make any necessary changes to address the requirements of the new environmental standard. Using the same process can save both time and money, but make sure you think through your implementation for the new system. Not doing so could cause you problems that would easily be avoided if proper changes were made.
Use this free Gap Analysis Tool to compare your EMS with the ISO 14001:2015 standard.
