Non Conformance (NCR)

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Non Conformance Report (NCR)

Purpose : To define this procedure for planning, conducting and reporting of HSE Assessments carried out
pertaining to OSHA Act 1994 Section 15, EQA Act 1974, and its regulations. The main objective will be to
eliminate Hazard and reduce risk at work place.

Scope: This procedure applies to HSE Non conformance audit/Inspection conducted by HSE Department or
by HSE Committee or on site visit at Megasteel locations and in addition it may cover remote access
surrounding Lion Steel complex that contains information that is relevant to the HSE related matters. NCR
will be issued in order to eliminate the unsafe act or unsafe conditions.

Responsibility: HSE Manager is responsible for overall implementation of this procedure. The HSE
Department shall be responsible for ensuring that the audit is planned, managed and conducted in
accordance with this procedure.

Procedure: Schedule or non schedule HSE audit or inspection will be conducted by HSE personnel and
Safety Committee. When there are unsafe acts or unsafe conditions been found, NCR will be raised to
the audited area and person in charge and to the Department Head of Department, HOD.

Section 1 - To describe the non conformance issue and explanations of the finding during an audit or
inspections. The Risk Classification will be determined by Major, Minor and Observation finding
and interpreted as per below.

 Major – Where when the risk could lead to human fatality, serious bodily injury,
permanent disability, loss from property/environmental damage or if more than 3 minor
risks will lead to a major and or not complying to OSHA 1994 and FMA 1967 legislation
and EQA 1994 Act and Regulations.

 Minor – Where the Risk is not as defined in major, and not complying with internal safe
work practices could lead to unsafe act and unsafe condition.

 Observation – Where the risk can be instantaneously closed or improve in the terms of
safe work practices.

Section 2 - The receiver to identify the possible root causes of the NCR finding and acknowledge the Hazard
in the area. The receiver will take “immediate corrective action” for short term measure. While the long term
permanent corrective measure will be plan and complete with in the targeted Completion date. Receiver will
ensure “Person(s) Responsible for the Corrective Action” (if involve more people to conduct corrective action.
This may take the form of specific control measures and should take into account the hierarchy of controls.
HOD and Manager needs to be informed and made aware of the NCR.

Sections 3 - The HSE Department to evaluate the NCR whether improvement has been met such as or
eliminate or reduce the risk in the area. Once the NCR has been evaluated it can be closed and reviewed
in the future.
Guideline of Non Conformance Code.
A. CODING OF IMMEDIATE CAUSES. CHECK ALL APPLICABLE

SUBSTANDARD ACTIONS
Operating equipment without authority
Failure to warn
Failure to secure
Operating at improper speed
Making safety device inoperable
Removing safe devices
Using defective equipment
Failure to use personal protective equipment properly
Improper placement
Improper loading
Improper lifting
Improper position for tank
Servicing equipment in operation horseplay
Under the influence of alcohol and / other drugs
Others (Please specify)

SUBSTANDARD CONDITIONS
Inadequate guards or barriers
Inadequate or improper protective equipment
Defective tools, equipment or materials
Congestion or restricted action
Hazardous environment conditions gasses, dusts, smokes, fumes, vapor
Noise exposures
Radiation exposures
High or low temperature exposures
Inadequate or excess illumination
Inadequate ventilation
Others (Please specify)

B.CODING OF BASIC CAUSES:

PERSONAL FACTORS TYPE OF CONTACT


Inadequate capability Stuck against Fall to below
Lack of knowledge Stuck by Fall on same level
Lack of skill Caught in
Stress Caught on
Improper motivation Caught between
Others (Please specify) Slip

JOB FACTORS CONTACT WITH


Inadequate work standards Radiation
Inadequate leadership / supervision Caustics
Inadequate engineering Electricity
Inadequate purchasing Heat
Inadequate maintenance Cold
Inadequate tools/ equipment Noise
Inadequate work standards Toxic or noxious
Wear and tear Substances
Abuse and misuse Overexertion
Others (Please specify)

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