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Non-conformance and non-conformance handling
All enterprises must have procedures to uncover, report, remedy and prevent non-conformance with health, safety and environmental legislation (HSE legislation).
All breach of HSE rules is considered non-conformance
Any incident involving a breach of relevant legislation is considered non-conformance. Non-conformance can entail workers not having access to protective equipment, chemicals being handled or stored incorrectly, workers being injured at work, or workers who have been exposed to noise not having their hearing checked. Non-conformance can also entail breach of important procedures, instructions or routines within the enterprise.
The term non-conformance covers anything that does not conform to safe operations within the enterprise, without taking into consideration industry or tasks. Normal variations within daily operations do not constitute non-conformance.
Examples of non-conformance
The cause of unwanted incidents must be recorded as non-conformance:
- The cause of serious incidents or accidents that led to personal injury or damage to the environment or equipment. Examples include causes of occupational accidents and work-related illness, damage to equipment and the environment, fire and emissions that are harmful to health or the environment.
Other incidents may be less obvious, but should still be registered as non-conformance:
- Causes of near misses that, under different circumstances, could have had much worse outcomes. Examples include faults on security-critical equipment that are discovered in time, an open vent that is closed, or incorrect packaging that needs to be replaced before leaks can occur.
Example: What is the non-conformance?
A worker slipped and fell on ice outside the entrance to the workplace and broke their leg. What is the non-conformance?
In this case it would be easy to say that the non-conformance is that the worker broke their leg. While it’s true that a worker breaking their leg is an unwanted incident, is it a non-conformance?
In identifying the non-conformance, one must ask the question, “why did things go wrong?”.
In our little story, the non-conformance is that the enterprise had not conformed to the procedure of sanding icy access paths. The non-conformance can be recorded as follows:
“The procedure for preventing icy conditions had not been followed. The access path to the warehouse had not been followed on Friday 13 January 2018.”
All non-conformance handling requires you to ask “why?”. Asking why is necessary to find the true, under-lying reason for the incident, and not just the outcome of the non-conformance.
The employer is responsible
The injury is not the non-conformance – the record of the non-conformance should reflect the cause of the injury.
The employer is responsible for making sure the rules are followed, and this includes rules for health, safety and the environment. This means the employer is also responsible for making sure the enterprise has, and uses, a system for recording and handling non-conformance.
Read more about systematic internal control
Record and handle non-conformance
The law requires employers to establish a system for handling non-conformance. Good non-conformance handling requires identifying what happened, why it happened, remedying the situation and making sure it does not happen again. This can contribute to
- the enterprise reaching its goals
- preventing the same non-conformance from happening again and again
- reducing the risk of unwanted incidents
- a safer working environment and an improved external environment
- increased productivity through fewer disruptions and reduced absences, wastage and loss
Record near-misses
You should also record causes of near misses as non-conformances, even if nothing went wrong this time.
It can be more costly to deal with the outcomes of an unwanted incident than to prevent what causes the incident in the first place.
Build a strong culture for reporting non-conformance
A vital non-conformance system is an integral part of internal control. In order for the system to work, the employer must arrange for an HSE culture where it is not only acceptable, but expected, for workers in all levels of the organisation to report non-conformance. In addition, workers should feel confident that their employer actually follows up on the non-conformance and takes it seriously.
Correlation between non-conformance and risk assessment
The list of recorded non-conformances should form part of the documentation the enterprise’s risk assessments are based on. The goal is that a systematic approach to reducing risk within the enterprise over time will
- reduce the number of non-conformances
- reduce potential costs stemming from non-conformances
The responsibility of the worker
All workers must immediately report non-conformances or defects in the workplace. This helps the enterprise learn from its mistakes.
Read more about the responsibility of workers to contribute (in Norwegian)