N.C. Division of Pollution Prevention and Environmental Assistance
EMS and Pork Production Tools

Environmental Management Systems for Pork Producers

4.5.2 Nonconformance and Corrective and Preventive Actions

No EMS is perfect - especially in the beginning - and therefore problems with the system will probably occur. 

The term used to describe problems with the EMS is “nonconformance,” not to be confused with “noncompliance.” A nonconformance is a deficiency where implementation is inconsistent with the EMS description, or the system does not meet the EMS criteria. Whereas “noncompliance” refers to a violation of an environmental standard, “nonconformance” refers specifically to the EMS. Examples of a nonconformance include failure to follow farm SOPs, failure to review environmental aspects in timeframe specified (i.e. EMS procedures not followed), employees not aware of their EMS responsibilities (not properly trained), etc. 

To address a nonconformance, the problem needs to be identified, corrected (corrective action), and prevented from happening in the future (preventive action). Corrective and preventive action allows for ongoing improvement of the EMS and environmental performance.

Corrective and preventive actions should:

  • resolve the immediate problem;

  • consider whether the same or similar problems exist elsewhere; 

  • prevent the problem from recurring; and

  • define the responsibilities and schedules associated with these three steps. 

Step 1

  • Develop a clear process for initiating and completing corrective and preventive actions. The process should provide a means to:

    • Determine the problem and identify the cause;

    • Identify and implement corrective action;

    • Initiate preventive actions;

    • Apply controls so that preventive actions taken are effective; and

    • Record any changes in written SOPs resulting from the corrective action.

This process will be most successful when employees are encouraged to report any problems they see that might result in a negative environmental impact.

See the link below for a tracking form to help personnel record and report corrective and preventive actions. 

  • Tip - Main reasons EMS problems occur:

    • Poor communication; 

    • Lack of training;

    • Lack of understanding;

    • Procedures not followed; and/or

    • Equipment malfunctions or not maintained.

Step 2

  • Write a procedure that documents the following:

    • Authority for reporting actual or potential nonconformance.

    • Responsibility and methodology for investigating, recording and reporting corrective and preventive actions.

    • Responsibility for recording changes to EMS documentation. 

The responsible party within this procedure is often the management rep and/or EMS coordinator.

See the link below for an example of a corrective and preventive action procedure.

(This procedure can be downloaded and customized by replacing the red highlighted areas with the specifics for your farm. You can incorporate your procedure for this element within your EMS manual or maintain it as a separate document. A small farm may decide to incorporate language within the manual that addresses this element as opposed to having separate documents.)