Management system guidance
10.0 Improvement
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10.2 Nonconformity and corrective action
Clause 10.2 sets out what your organization must do when a nonconformity occurs within the environmental management system (EMS). A nonconformity is a failure to meet a requirement. In an EMS this may be a requirement of ISO 14001, of your own EMS (procedures, operational controls, objectives) or a compliance obligation such as a permit condition or a customer environmental requirement.
When a nonconformity occurs, your organization must react to it and, as applicable, take action to control and correct it and deal with the consequences, including mitigating any adverse environmental impacts. It must then evaluate whether action is needed to eliminate the cause(s) so that the problem does not recur or occur elsewhere. That evaluation involves reviewing the nonconformity, determining its cause(s) and checking whether similar nonconformities exist or could occur. Any action needed must be implemented, the effectiveness of corrective action reviewed and, if necessary, the EMS changed. Corrective actions must be proportionate to the significance of the effects of the nonconformity, including its environmental impacts.
What changed in ISO 14001:2026: the requirements of clause 10.2 are unchanged in substance. ‘Causes’ is now written as ‘cause(s)’, in line with the revised definition of corrective action, and documented information must be available as evidence of the nature of the nonconformities, the actions taken and the results of corrective action (previously ‘retained’).
Sources of environmental nonconformities
- internal and external audit findings (clause 9.2);
- results of evaluation of compliance, such as exceeded discharge or emission limits (clause 9.1.2);
- monitoring and measurement results outside operating criteria (clause 9.1.1);
- spills, leaks, releases and other environmental incidents, and the response to emergencies (clause 8.2);
- operational controls not followed (clause 8.1);
- complaints or notices from neighbors, regulators or other interested parties (clause 7.4.3);
- observations raised by workers and contractors.
Correction and corrective action
A correction deals with the nonconformity itself, for example containing and cleaning up a spill, repairing a bund, or segregating waste that was placed in the wrong skip. Under ISO 14001 it also includes dealing with the consequences, such as notifying the regulator, remediating contaminated ground or restoring a damaged habitat.
A corrective action deals with the cause(s), so that the nonconformity does not happen again or elsewhere. ISO 14001:2026 defines corrective action as action to eliminate the cause(s) of a nonconformity and to prevent recurrence. Annex A notes that the separate concept of preventive action is now covered by understanding the organization’s context (clause 4.1) and by addressing risks and opportunities (clause 6.1.4).
A practical corrective action process
- Record the nonconformity: what happened, where, when, the requirement not met and the environmental effect.
- Contain and correct: take immediate action to stop or limit environmental harm and deal with the consequences.
- Evaluate whether corrective action is needed, based on the significance of the effects; a minor, isolated slip may need only correction.
- Investigate the cause(s) using simple tools such as the 5 whys or a cause-and-effect diagram. Look for weaknesses in processes, controls, training and equipment rather than someone to blame.
- Look wider: check whether the same problem exists, or could arise, at other sites, processes or shifts.
- Implement the agreed actions, with owners and target dates.
- Verify effectiveness after a suitable period, using monitoring data, audit or inspection, before closing the action.
- Update the EMS where needed: aspects register, risks and opportunities, operational controls, emergency plans, training and documented information.
Trends in nonconformities and corrective actions are a required input to management review (clause 9.3), and corrective action is a key source of improvement (clause 10.1). A simple log or database of nonconformities makes it easy to analyze trends and report status. Our environmental management system templates include a corrective action procedure and report form.
You should seek and record evidence that nonconformities are identified, recorded and controlled; that environmental consequences have been dealt with; that the need for corrective action has been evaluated and cause(s) determined where appropriate; that actions are proportionate to the significance of the environmental effects; that their effectiveness has been reviewed; that the EMS has been updated where necessary; and that documented information of the nonconformities, actions and results is available.
More information on PDCA
Planning
Context
Planning
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Doing
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