- IMPROVING WELFARE
- ENSURING CONFORMANCE
- STRENGTHENING ESCAS
The management of nonconformance under LGAP follows what typically occurs in other conformity assessment programs based on international guidelines and considers the principles of natural justice.
Under such programs, nonconformities may be identified during either internal or external audits or in response to feedback or complaints and assigned to any area deemed to be not meeting the specified requirements.
Nonconformities represent a departure from the specified requirements and are an opportunity for the Operator or Facility to permanently correct their nonconforming activities within a specified timeframe.
In 'closing out', or correcting nonconformities, Operators and Facilities are required to focus on addressing the cause of the nonconformity to ensure the likelihood of a repeat occurrence is eliminated or mitigated. This approach identifies areas that must be improved, requires changes to be made in a specified timeframe and encourages continual improvement over time.
Failure to close out a nonconformity in a prescribed timeframe initiates a progression through an escalation pathway.
Categorising and assigning nonconformities
Three categories of nonconformity exist under LGAP: critical, major and minor nonconformities. The framework for auditors to use when determining the severity of a nonconformity considers the impact and frequency of issues relating to the nonconformity. This framework is clearly defined in the LGAP Certification Rules to ensure its appropriate and consistent application.
The Program Owner also has the ability to assign nonconformities outside of the regular auditing process or move to suspend or withdrawal certification in certain situations.
Nonconformities are identified through a process of monitoring and auditing and corrective actions are required to be undertaken in order to ‘close out,’ or correct nonconformities.
Failure to close out a nonconformity in a prescribed timeframe initiates progression through an escalation pathway, as shown below. The responsibility for undertaking corrective action rests with the Facility or Operator, understanding that in some cases exporter or importer Operators may assist in this area.
In a departure from ESCAS, the Approved Certification Body and Approved Auditor takes responsibility for reviewing the corrective action and either closing out the nonconformity or escalating the nonconformity. This is usual practice under conformity assessment programs and more effective as these parties are on the ground and can investigate more immediately.
This is an evidence based approach designed to ensure impartiality and fairness in the manner in which nonconformities are assigned and managed. This approach also ensures the consequences of nonconformance, such as suspension and withdrawal, are administered in a timely manner that is judicially fair.