Facilities should be aware of the requirements in the Code of Practices regarding nonconformities (also referred to as nonconformances).

• All Nonconformities must be closed before an R2v3 Certificate can be issued – Both major and minors NCs must be closed and verified with a follow-up remote or onsite audit by the CB auditor.
• Certificate Suspensions – R2 facilities are not permitted to have an active R2 Certificate if they are operating in nonconformance beyond the grace periods specified to correct and close NCs. CBs are required to suspend R2 Certificates if NCs are not corrected and closed in the specified time period.
• Internal Nonconformities must be closed – any open R2 NCs identified through the Facility’s Internal Audit process that are not resolved and closed before the CB certification or recertification audit, will also be recorded by the CB auditor as an NC. Facilities are encouraged to complete their internal audit well in advance of their certification body audits to allow sufficient time to address all NCs. Consider scheduling internal audits half-way between annual CB audits. The CB cannot issue the R2 Certificate until all NCs have been closed.
• Corrections vs. Corrective Actions – Corrections are the actions a facility takes to stop a NC from happening. After correction, a root cause analysis is conducted to determine why the NC occurred. Then corrective actions are implemented to prevent the NC from reoccurring.
• Corrections of nonconformities — R2 Facilities must provide evidence of correction for all major and minor NCs within 30 days of when the NC was issued. This means the facility has stopped the NC from occurring. If a facility is unable to submit this evidence within 30 days, the CB will suspend the Certificate.
• CB Audit nonconformities – NCs will now be issued at Stage 1 audits. All Stage 1 NCs must be corrected prior to the Stage 2 audit. For all other CB audits, CB will schedule either a remote or on-site audit to verify that corrective actions for all minor and major NCs have been implemented and are effective.
• Time to close NCs – Facilities have 3 months from Stage 2 audits, and up-to 6 months from surveillance audits to close the NCs with their CB’s verification.
• Automatic Major NCs – Pay attention to the FM Management Plan, Downstream Vendors, and due diligence requirements. Many companies will need significant upgrades to customize the detail and transparency of each of these areas so that they are comprehensive and robust enough to meet the new R2v3 requirements. NCs in these area are automatic Majors.

The Bottom Line:  Early and detailed preparation will be the biggest factors for preventing NCs and ensuring a successful  audit. The quality of your preparation and internal auditing directly affect the outcome of your Certification process.  Be ready with sufficient objective evidence that will demonstrate to the auditor all R2v3 requirements are being met.  And when nonconformities are identified, be quick to make necessary corrections and provide the required evidence of correction to your auditor to prevent a delay or lapse in your R2 Certification.