Closing major nonconformities at a port operator
Harbourline Port operates three container terminals, 14 ship-to-shore cranes, 60 straddle carriers and 22 km of rail. It has just completed its initial stage 2 ISO 55001 audit. The team raised two major nonconformities. First, there has been no management review since January 2023, although the audit is in March 2024 and clause 9.3 requires reviews at planned intervals. Second, asset management objectives are 'improve availability' and 'reduce cost', with no measurable targets, no responsible persons and no plans showing how they will be achieved. Seven minor nonconformities were also raised, including incomplete competency records for crane technicians and two asset management plans not reviewed after a route expansion. The client submits a corrective action plan 20 days later. For the majors it proposes: 'Management review scheduled for 15 April; all senior managers to attend training on ISO 55001; objectives to be reviewed at that meeting.' It asks for the certificate to be issued after the management review, with objective-setting verified at the first surveillance audit. The account manager wants to close the majors administratively to meet the client's contract deadline.
1. Evaluate the client's corrective action plan for the two major nonconformities against clause 10.1 and certification requirements.
Read the worked answer
Clause 10.1 requires reaction to the nonconformity, evaluation of the need for action to eliminate the cause, implementation of action, review of effectiveness and retention of documented information. The plan addresses symptoms, not causes. 'Calendar oversight' is not a root cause; it does not explain why no one noticed for 14 months, who owns the management review process, or how scheduling and follow-up will be assured. Training on ISO 55001 is generic and cannot by itself correct a missing management review.
For the objectives nonconformity, 'review at the meeting' is only a first step. The client must define measurable objectives at relevant functions and levels, assign responsibility and resources, set timelines and establish monitoring. The plan also lacks evidence of correction, such as a completed management review, and a completion date for verification.
The plan is not acceptable as written. Ask for root cause analysis, actions addressing system causes, responsible persons and due dates. If the client cannot provide this, the majors remain open.
2. What verification would you require before closing each major nonconformity, and can either be deferred to surveillance?
Read the worked answer
Each major must be corrected and the corrective action verified before certification. For the management review, require evidence that a review has actually been held, with the inputs and outputs required by 9.3, decisions and actions, attendance by top management, and a schedule or mechanism for future reviews. Verification by document review plus interview is usually needed; a calendar entry is not enough.
For the objectives, require revised objectives with measurable targets, alignment to organizational objectives, and plans showing what will be done, resources, responsibility, timing and evaluation. Sample the objectives and test whether managers know them.
Neither major can be deferred to the first surveillance audit; ISO/IEC 17021-1 requires major nonconformities to be resolved before certification. If the client cannot provide evidence by the agreed date, certification is delayed or refused, and the decision must be recorded. Minor nonconformities may have longer closure timelines if the body's procedure allows, but the majors gate the decision.
3. The account manager wants administrative closure. How should the audit team and certification decision-maker respond?
Read the worked answer
Commercial pressure is not a valid reason to close a nonconformity. The account manager should be excluded from the certification decision; the decision-maker must be independent of sales and competent to review the evidence. The team leader should document the client's request and the body's response, and escalate to the technical reviewer or certification manager. If the account manager persists, invoke the impartiality procedure.
Tell the client in writing that the majors remain open until verification evidence is accepted, and that the certificate cannot be issued on the basis of a planned future review. The body should also consider whether the sales quote or contract created a commitment that compromised impartiality.
At the closing meeting, present the findings and the verification path clearly, avoid promising a date, and record the client's acknowledgement. The certification decision record should show who decided, on what evidence, and why the decision was independent of commercial considerations.