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ISO 9001:2015

Non-Conformance, Corrective and ISO 14001:2015

T&D Cleaners ISO 45001:2018
Limited Preventative Action Procedure Reference 4.5.3.2
Document Number: T&D-HSE-PRC-0009 Rev. No: 00
Date of Issue: Rev. Date: 00

1 Purpose and Scope

This document sets out the procedure for reporting and investigation of HSE Non-Conformances.

It is designed to assist with analyzing the type, severity, and cause of non-conformances in order for
corrective and preventative action to be taken to address the root causes of non-conformances and avoid the
recurrence of non-conformances. This procedure applies to all HSE non-conformances at temporary sites or
permanent operations, as well as contractor operations.

An HSE non-conformance / incident is an undesired event that could, without intervention, impact the
environment or health and safety of employees/contractors. Non-conformances include, but are not limited to:

 non-compliance with legal and other requirements,

 non-conformance with company targets (business plan or scope of work)
 HSE emergencies (non-conformances requiring immediate action to prevent and control damage),
 external complaints
 Uncontrolled releases to the environment (i.e. spills and leaks).

2 Procedure

2.1 Non-Conformance Reporting

Dangerous conditions can occur at any level in any department or function. Therefore, reporting non-
conformance is a shared responsibility of all employees.

Any employee / technical officer (on-site) noting an HSE non-conformance should:

 report the non-conformance immediately to the OHSE Manager; and

 Take any immediate possible corrective actions to minimize HSE risks/impacts.

A Non-Conformance Report Form – HSE-FRM-0020 must be completed by the employee / Field Supervisor
who noted the non-conformance (including photos). This report should then be sent to the OHSE Manager

A Non-Conformance Register – HSE-REG-0004 of non-conformances will also be maintained by the OHSE

Manager as an overall summary.

WARNING: All Printed Copies are Uncontrolled (Excluding Master Copy)

Document Number:T&D-HSE-PRC-0009 Rev: 0 Owner: Robert Mugabi
Title: Non-Conformity, Corrective and Preventative Action Procedure Page 1 of 3
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The OHSE Manager will coordinate NCRs as follows:

 Record the NCR in the Non-Conformance Register

 Communicate NCR to the relevant customer within 2 days for investigation and implementation of
corrective/preventative actions. (In case of urgent non-conformances the NCR will be issued to
the client immediately.)
 Follow up with customer regarding feedback and status of NCR within one week after NCR was
issued. (In case of urgent NCR, it will be followed up daily to monitor the status of the NCR.)
 Receive feedback and proof of corrective and/or preventative action(s) taken from the Customer
 Record Corrective Actions with dates into the Non-Conformance Register
 Record Preventative Actions with dates into the Non-Conformance Register
 Review, sign off, and return the closed NCR to the Customer and the Operations Department
 The controlled copy of the Non-Conformance Register shall be saved and maintained as per the
record control procedure.

2.2 Non-Conformance Investigation

All HSE non-conformances (minor, serious and major) should be investigated by the customer to identify the
root cause and measures required to correct and prevent further occurrences.

2.3 Follow-up and Close Out of Non-Conformances

The purpose of follow-up and close-out is to verify the effectiveness of the non-conformance reporting process
and the effectiveness of the corrective and preventative action taken. Follow-up will:

 Assess if the non-conformance was reported and investigated within the specified timeline
 Assess if corrective and preventative actions were implemented effectively after reporting of the
occurrence
 Assess legal and other requirements compliance during the implementation of corrective and
preventative actions.
 Verify that all necessary documentation is completed.
 Assess if any HSE procedures need to be updated, or if a new procedure is required in order to
prevent reoccurrences.

It is the responsibility of the OHSE Manager to follow up and close out corrective actions in cooperation with
the relevant Operations Manager (where applicable).

2.4 Non-Conformance Communication

The OHSE Manager shall report all non-conformances and corrective and preventative actions for discussion
at the HSE Meetings.

An NCR summary report is included in the information supplied for the annual Management Review Meeting.

This summary report includes details regarding the status of corrective and preventative actions and the
effectiveness of actions taken.

WARNING: All Printed Copies are Uncontrolled (Excluding Master Copy)

Document Number:T&D-HSE-PRC-0009 Rev: 0 Owner: Robert Mugabi
Title: Non-Conformity, Corrective and Preventative Action Procedure Page 2 of 3
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3 Non-Conformance Process

OHSE Manager reviews

Employee / Field Manager forward
Send to relevant Line the NCR form &
Supervisor complete completed NCR form to
Manager for review suggests corrective /
NCR Report Form OHSE Manager
preventive actions

OHSE Manager to
OHSE Manager to Customer / Contractor OHSE Manager forward
follow up on NCR's and
review and close out to implement corrective NCR to the relevant
obtain feedback from
NCR / preventative actions Customer / Contractor
customer / contractor

HSE Manager forward

All NCR's and the NCR
signed off NCR to
Register shall be filed by
Customer / Contractor
HSE department
and Operations

4 Applicable / Referenced Documents

 OHSAS18001:2007 Standard
 ISO14001:2004 Standard
 HSE-FRM-0020 Non-Conformance Report Form
 HSE-REG-0004 Non-Conformance Register

Written & Reviewed by: Approved by:

QHSE Manager Managing Director

WARNING: All Printed Copies are Uncontrolled (Excluding Master Copy)

Document Number:T&D-HSE-PRC-0009 Rev: 0 Owner: Robert Mugabi
Title: Non-Conformity, Corrective and Preventative Action Procedure Page 3 of 3