Managing non-conformance close out
In this issue we’re going to cover how to manage NCN’s effectively – how to create them and then close them out…
NCN stands for non-conformance note, or non-compliance note. It is also sometimes known as a NCR – non-conformance record. But whatever you call it, it’s basically the record which documents the non-conformance and it’s close out.
The BRC standard is quite specific about the type of information that must be recorded when raising a non-conformance.
The non-conformance note (NCN) must include:
- A clear explanation of the non-conformity
- A consequence assessment
- The corrective action
- The root cause
- The preventive action
- Timescale for completion
- Who is responsible for close out of the actions
- Verification of close out
The consequence assessment, basically must decide what would happen if this non-conformance was not to be completed effectively…
Would it create a quality, legal or food safety issue? It is causing an immediate contamination issue, that is happening as we speak? Or is it likely that it will affect the product if it isn’t rectified soon? Or is the non-compliance something that needs to be corrected, but the product is not at immediate risk?
How you want to score this consequence is up to you, you could decide on minor, major and critical, or high medium and low, or you could even have a 1,2,3 score if you wish. The overall purpose of the consequence assessment is to ensure that the frequencies for completion are aligned to the risk to the product. So you could also decide what maximum timescales are allowed for each type of risk, and apply those. I would be cautious doing this though, as it does tie you down and put you at risk of getting a non-conformance in an external audit if you don’t adhere to the timescales that you’ve set.
This assessment must be carried out by someone who is competent to decide what the consequence would be. This person must be authorised to carry out this task as well, which means that they must be aware that it is part of their responsibilities – this is normally done, either through documenting this on the procedure, or writing it into their job description.
Corrective action, root cause and preventive action
For more information on this, please refer to our previous issue on “Correction, root cause & preventive actions explained!”
Verification of close out
This is a really key part of the close out of the non-conformance and it often gets missed. Once the person who has been assigned the NCN has completed the action, they must provide evidence to show that it is complete…
Another individual, must then assess the evidence provided to make sure that the non-conformance has been completed effectively. Just the same as you would do, if you were closing out non-conformances for your BRC audit – you provide the evidence and then your auditor checks the evidence to make sure you’ve closed out the NCNs properly. Once this is complete, the NCN can then be closed out. Until this is done, it is not essentially closed.
Make sure that you keep the evidence of the close out of the non-conformance, so you can show this if required at audit.
Making sure that non-conformances are closed out effectively and to the timescales set, is no easy task. It is important that it doesn’t come down to one person to get this done, it needs to be overseen by management and instilled in each department.
One way of ensuring that non-conformances have a high profile in the business is to ensure that they are reviewed by senior management routinely. Communicating KPI’s for non-conformance close out is a good idea, but it can be easily overlooked. Reviewing non-conformances that are due in the next month, plus those that are overdue, at monthly management meetings means is a good way of making this really visible.