Harmonisation Act: organisations must submit a plan within 3 months to address minor non-conformities
SKAO published a new Harmonisation Act relating to CO₂ Performance Ladder 4.0. This Harmonisation Act concerns the period within which organisations must be able to submit a plan to address minor non-conformities. This period has been shortened from 12 months to 3 months. The period allowed for actually implementing the corrective measures remains unchanged: this may still take place up to 12 months after the audit.
Earlier submission is more effective and more common practice
A certification body (CB) only issues a CO₂ Performance Ladder Certificate if an organisation meets the requirements of a specific level of the Handbook. If this is not (fully) the case, the auditor identifies so-called non-conformities. These may be major or minor non-conformities. For minor non-conformities, CO₂ Performance Ladder 4.0 states that the organisation has until the next audit (approximately one year) to draw up and implement a corrective action plan. It is more effective (as it allows the CB to assess the plan) and more common practice (including under ISO/IEC 17021-1) to prepare and submit the corrective action plan at an earlier stage.
Implementation of the plan may take place later
Organisations must therefore draw up and submit a corrective action plan to the CB within 3 months after a minor non-conformity has been identified. The deadline for implementing the plan remains unchanged (before the next audit), meaning that the minor non-conformity does not need to be resolved within 3 months.
About Harmonisation Acts
In some cases, a passage in the Handbook may require further clarification, or there may be evolving insight into how a requirement should be interpreted. In such cases, an additional rule is drawn up for that passage, which we refer to as a ‘Harmonisation Act’. The Handbook is normative, and this also applies to these harmonisation acts that have been added at a later stage.
The decision tree shows the timeframe within which organisations must start correcting deviations. For minor deviations, the timeframe within which the plan must be submitted has been adjusted from 12 months to 3 months.
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