Major nonconformity in ISO 14001: what happens and what do you do?
A major nonconformity in ISO 14001 is a shortcoming that means the environmental management system cannot achieve its intended result. This is how ISO/IEC 17021-1 , the standard for certification bodies, defines it. As long as it is not resolved and verified, you do not get a certificate. The difference from a minor nonconformity and the role of the certification body are described on the audit process. Here you read what you concretely do. You will find the costs of additional audits on costs and timeline.
What exactly is a major nonconformity?
A major nonconformity is not just an error in the paperwork. It is a situation in which an important part of the system does not work. The auditor then sees not a single error, but a gap in the approach.
The auditor decides case by case which finding is major. Examples that may count as major (indicative, not a fixed list):
- There is no environmental aspects register, or it is so incomplete that it undermines the rest of the system.
- A legal environmental obligation is not complied with, and the company has not identified this.
- No internal audit has been carried out, or management has not reviewed the system.
- A significant environmental risk is structurally not controlled, for example a leak that nobody follows up.
A minor nonconformity is different. It is a shortcoming that does not fundamentally undermine the system, such as one missing record in an otherwise working system. You resolve that within the deadline set by the certification body.
Whether a finding is major or minor is a judgement by the auditor and the certification body. If you disagree with the classification during the audit, ask for an explanation and record your response in writing.
What it means for your certificate
If a major nonconformity arises during the initial certification, the certification body does not issue the certificate. You must first resolve the nonconformity and have it verified. This can be done with a re-audit, a limited audit at the place of the error, or sometimes a check of documents. The certification body decides which form is needed and within which period. Ask the certification body for that deadline.
For your planning, this means a major nonconformity can extend your track. Allow for extra time and possibly extra costs. What a re-audit costs differs per certification body. Ask for it in the quote, see comparing ISO 14001 quotes.
An example: the missing spill tray inspection
A company with a storage area for lubricants (fictional, 80 employees) receives a major nonconformity at the certification audit. The auditor finds that the spill trays under the drums have not been inspected in the past year. The company has a procedure, but nobody carries out the inspection and nobody checks that it happens.
This is a major because the company does not control a significant environmental risk and the procedure does not work in practice. The company tackles it as follows:
| Step | What the company does | Evidence for the auditor |
|---|---|---|
| 1. Analysis | Investigate the cause: why did the inspection not happen? | Root cause analysis using the five whys |
| 2. Correction | Inspect all spill trays immediately and clear out empty trays | Inspection list with date, initials and photos |
| 3. Structural | Schedule the inspection in the work plan with a responsible person | Revised schedule and job description |
| 4. Check | The storage manager checks the inspection list every month | Monthly check with initials |
| 5. Effectiveness | After three months, review whether the inspections have been carried out | Overview of the inspections over the period |
Note the order. The company first resolves the direct error, and then addresses the cause. Without that second step, the same nonconformity returns next year.
How to tackle a major nonconformity
Read the finding and the standard
Note which clause of ISO 14001 is concerned and what the auditor exactly saw. Ask for the evidence if you do not understand it. Without that understanding, you fix the wrong problem.
Investigate the cause
Ask yourself why it went wrong. Was it a matter of time, knowledge, a wrong procedure or the absence of a responsible person? Use a simple method, such as the five whys. The approach is described on nonconformities and improvement under ISO 9001, which is the same for ISO 14001.
Set up a corrective action
Describe the direct correction and the structural measure. For each action, record who is responsible and when it must be done. Send this plan to the certification body if it asks for it.
Carry out the actions and record the evidence
Carry out the measures and keep the evidence. Think of lists, photos, revised procedures and reports. The evidence must show that the action was done, not just that it is scheduled.
Arrange the verification
Ask the certification body which form of verification it wants and within which period. Schedule it as soon as you have completed the measures.
Common mistakes
- Only writing a plan without carrying it out. An auditor wants evidence that the action was done, not that it is on paper.
- Skipping the cause. A correction without a root cause analysis often returns as the same nonconformity.
- Forgetting the verification. A resolved problem is only closed once the certification body has verified it.
- Waiting too long. An open major extends the track. Start straight away, even if the deadline seems generous.
- Not discussing the classification. If you disagree with the major, say so in good time and back it up with evidence.
How do you prevent a major nonconformity?
The best approach is a good internal audit before the external one. A major often arises in a place that the internal audit did not review. Therefore, use the report of your internal audit to look structurally at your most important environmental aspects, and make sure the environmental aspects and the compliance evaluation are in order. What the auditor checks per clause is on the ISO 14001 checklist.
Common doubts
What if the major only comes up at a surveillance audit? Then the nonconformity must also be resolved and verified. The certification body decides within which period and what happens to your certificate, for example whether it is suspended. Ask this explicitly during the audit.
Does a major carry over to the next year? A closed major does not disappear from view. Auditors often check at the next audit whether the solution still works. A superficial fix then comes back.
Can I have the classification as major reviewed? Discuss it with the auditor first, with evidence. If that does not work, an accredited certification body has an appeal or complaints procedure. Ask for that procedure and its deadlines.
Next step
If you now have a major nonconformity, start today with the root cause analysis and record the evidence. If you want to know what happens after the audit, read the frequently asked questions.