A finding such as “poor safety management” leaves everyone guessing. Good HSE audit nonconformity examples show exactly which requirement was missed, what the auditor checked and where the gap occurred. That makes the finding easier to verify and the response easier to manage.
This guide uses fictional workplace examples to help internal auditors write clear findings. The sample procedures and record references below are invented for illustration; they are not legal requirements or evidence from a real company.
What counts as an HSE audit nonconformity?
A nonconformity is a failure to meet an applicable requirement. Your audit criteria might include an adopted management system, a company procedure, a contract obligation or an applicable legal duty. Identify the actual requirement before deciding that a finding is a nonconformity.
An auditor’s preferred method is not automatically a requirement. Nor does a missing document always prove that work was unsafe. Check whether the document was required, whether another permitted record exists and whether the evidence is complete.
The UK HSE guidance on checking performance places monitoring and auditing within the review of health and safety arrangements. The practical purpose is to discover whether controls work, not simply to collect paperwork defects.
A simple structure for a defensible finding
- Requirement: identify the document, revision and relevant provision, or accurately cite the applicable duty.
- Evidence: record the location, date, item or record identifiers and the sample checked. Separate what you observed from what someone told you.
- Finding: state the specific gap without guessing motives or causes.
The ISO 9001 Auditing Practices Group guidance on documenting nonconformities describes this evidence–requirement–statement structure. It is quality auditing guidance, used here as a writing aid. It does not establish ISO 45001 requirements or replace your audit criteria.
Four HSE audit nonconformity examples
Each example assumes that the stated fictional company procedure applies and that the evidence has been confirmed with the responsible team.
1. Damaged equipment returned to available stock
Requirement: Workshop Procedure WP-04, revision 2, requires damaged portable tools to be identified and moved to the quarantine cabinet pending assessment.
Evidence: During the workshop audit, tool T-17 was in the available-for-use rack. Its handle was visibly cracked. The quarantine cabinet was separate and accessible.
Clear finding: The required quarantine process was not followed for tool T-17, which remained in the available-for-use rack with a cracked handle.
Immediate response: have the responsible person prevent use and apply the site’s equipment isolation/quarantine arrangements. Do not wait for the audit report to address an immediate risk. The later investigation should establish how the tool returned to stock.
2. Required induction verification missing
Requirement: Site Procedure SP-03, revision 5, requires an induction completion record to be verified before a new starter receives unescorted site access.
Evidence: Of six new starter records sampled, records N-04 and N-06 showed unescorted access authorization but no induction verification. The supervisor confirmed that no alternative verification record was available.
Clear finding: Induction verification was not recorded before unescorted access was authorized for two of the six new starters sampled, contrary to SP-03.
This finding concerns the required verification. It does not claim the two people received no training unless further evidence establishes that. For the onboarding process itself, see the construction site safety induction checklist.
3. Actions closed without the required check
Requirement: Action Management Procedure AP-02, revision 1, requires a supervisor to verify completion evidence before closing an HSE action.
Evidence: Three of eight closed actions sampled, A-12, A-19 and A-23, had no verification entry. The action administrator confirmed they had been closed when an email saying “done” was received.
Clear finding: The required completion verification was not performed for actions A-12, A-19 and A-23 before closure.
Keep this finding separate from a claim that every action was ineffective. Reopen and check the affected items, then review whether the closure workflow needs changing.
4. Emergency information not updated after a change
Requirement: Emergency Procedure EP-01, revision 3, requires displayed evacuation maps to be updated before a changed route is brought into use.
Evidence: The route change approval identified Stair B as the new route. Two maps displayed in Office Zone C still directed occupants to Stair A. The route change had already been implemented.
Clear finding: The two displayed evacuation maps in Office Zone C were not updated before the approved route change was implemented, as required by EP-01.
Communicate the correct arrangements promptly through the site’s responsible personnel. A corrected map alone may not show that affected workers understand the change.
Wording to improve before issuing the report
| Weak wording | What to write instead |
|---|---|
| Workers ignore safety. | Describe the observed activity, location, applicable rule and confirmed deviation. |
| Training records are bad. | Identify which required records were absent and the size of the sample checked. |
| Management must buy new software. | State the unmet requirement; let the responsible team evaluate an effective solution. |
| The whole system has failed. | Limit the conclusion to the evidence, or expand the audit sample before making a broader conclusion. |
From finding to verified closure
Record an action owner and a risk-based due date using your organization’s process. Keep three separate questions visible:
- Correction: was the specific problem put right?
- Cause and corrective action: why did it happen, and what will prevent recurrence where needed?
- Effectiveness: what later evidence shows the change works?
For example, removing T-17 corrects the immediate stock problem. A revised return-to-stock check addresses a possible process weakness only if the investigation supports it. A later sample of returned tools can test whether the revised check is being applied.
Routine issues may first appear in a daily safety officer report. Cross-reference that record instead of duplicating or losing its action history.
Final review checklist
- Confirm the criterion is current and applicable to the audited activity.
- Check identifiers, sample size and factual accuracy with the responsible team.
- Remove blame, unsupported causes and unnecessary personal details.
- Record any immediate risk controls already taken.
- Apply grading only under the agreed audit scheme.
- Define the evidence needed for closure and who will verify it.
Frequently asked questions
Is every safety observation a nonconformity?
No. A concern may need investigation or improvement without enough evidence of an unmet requirement. Explain its status honestly. Do not soften a confirmed nonconformity merely to avoid an uncomfortable discussion.
Is a missing signature always a major nonconformity?
No universal grading rule applies. Consider the actual requirement, risk, extent and grading rules of the relevant audit scheme. Do not assign a major or minor grade from a generic internet example.
Can these findings be used in any country?
The writing structure can be adapted, but legal findings require the correct jurisdiction and applicable duty. These examples use fictional internal requirements and make no claim of regulatory or certification approval.