Closing the Major Nobody Closed
Two weeks after the closing meeting of a surveillance audit, the client submits a corrective action plan for the single major nonconformity: contractor pre-qualification was not completed for six of the nine contractors working on site, with no evidence of review of their OH&S arrangements before mobilisation (8.1.4). The plan states: root cause - contractor supervisors were not aware of the site rules; correction - the six contractors were pre-qualified retrospectively on 3 March; corrective action - a toolbox talk, with an attendance sheet signed 12 February, before the audit took place; evidence enclosed - the attendance sheet and the six new pre-qualification forms. The site manager's email says: 'Assume this closes the NC so we keep our certificate.'
1. Evaluate the submitted response against Clause 10.2. What will you accept and what will you reject?
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Work through 10.2.1 as a sequence and check each element against the deficiency.
- Correction (react): the six retrospective pre-qualifications are a correction and are acceptable - provided the forms are complete, actually assess OH&S arrangements rather than collecting signatures, and are marked as completed retrospectively so the record is honest. Ask to see two of them in full.
- Root cause: rejected. 'Supervisors were not aware' describes a symptom of an individual. The question is why a control at the selection stage of 8.1.4 depends on site supervisors at all. The plausible root cause is that contractor pre-qualification is not a gate in procurement: no owner, no checklist, no hold point before mobilisation, no verification. Ask for the process map and the name of the person accountable.
- Corrective action: rejected. A toolbox talk is awareness-raising, not a change to the process that failed. It also addresses the wrong population - the failure is at procurement and contract award, not on the site.
- Evidence: rejected as evidence of implementation. The attendance sheet is dated before the nonconformity was raised, so it cannot demonstrate that action taken after the finding was implemented. It also cannot demonstrate effectiveness.
Return the plan with specific requirements: a revised 8.1.4 process with a defined pre-mobilisation gate, an accountable owner, and a verification sample of contractors engaged after the finding date.
2. What verification will you require, and who actually decides whether the certificate is maintained?
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The client's assumption misplaces the decision. The lead auditor verifies and recommends; the certification decision is taken by a competent decision-maker who was not part of the audit team, on the basis of the audit report and the verification evidence. Say this plainly in your reply, in writing.
Verification for a major normally involves more than reading documents:
- Review of the revised process and evidence that it is owned and used.
- A sample of contractors engaged after the date of the nonconformity, tracing from contract award through pre-qualification to mobilisation. That is the only way to test implementation.
- Where the failure was on-site in nature, a follow-up visit; where it is purely documentary and the evidence is unambiguous, a documented review may suffice - record your reasoning for whichever you choose.
- A statement of effectiveness, not just of action taken.
Timeframes matter: the certification body's rules on closing majors usually require verification within a defined period (commonly three months) and specify suspension if it is not closed. Put the deadline, the verification method and the consequence in writing to the client the same day you reject the plan, so the record shows no drift.
3. Was this correctly graded as major? How would you justify the grade if challenged?
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Grade on two axes: the consequence of the failure and its extent across the system.
- Consequence: contractor pre-qualification is a primary control for one of the highest-risk interfaces in the business. Six contractors were mobilised with no review of their OH&S arrangements - the organization had no knowledge of their competence, their equipment or their legal compliance status before they were on site.
- Extent: six of nine. That is not an isolated miss; it is the normal state of the process. The documented procedure exists and is systematically not applied where it matters most.
That combination is a major: a systemic failure of a required control with direct OH&S consequence, requiring correction and corrective action before the certificate can be relied upon.
A minor would have been defensible if, say, one contractor out of twenty had been missed while the gate otherwise operated, was detected by the site's own checks, and was corrected before mobilisation. If challenged, present the sampling: which contractors, which files, what was absent, and whether any other site showed the same pattern. If the same finding appeared at a second site in the sample, say so - it strengthens rather than weakens the grade.