The Non-Conformance Report in Construction: What an NCR Must Record, the Five Dispositions, and Why Most Are Closed Wrongly

A non-conformance report is the quality system's admission that something was built, delivered or done that does not meet the requirement. It is the most useful record on a project and the one most often used badly: raised as a weapon against a subcontractor, closed on the day the work was patched, or not raised at all because raising it looks like failure. This article explains what an NCR is for, what it must record, the five ways a nonconformity can be dispositioned and who can authorise each, how the NCR relates to the corrective action and the concession, and the habits that make the NCR register worth reading.

What the standard requires

ISO 9001:2015 clause 8.7 requires the organisation to ensure that outputs which do not conform to requirements are identified and controlled to prevent their unintended use or delivery, and to take appropriate action based on the nature of the nonconformity and its effect. The clause lists the actions: correction; segregation, containment, return or suspension; informing the customer; and obtaining authorisation for acceptance under concession. It requires records that describe the nonconformity, the actions taken, any concessions obtained, and the authority that decided the action. Clause 10.2 then requires that when a nonconformity occurs the organisation reacts to it, evaluates the need for action to eliminate the cause so that it does not recur, implements the action, reviews its effectiveness and updates risks and the system where necessary.

Two records come out of that: the nonconformity report, which controls this instance, and the corrective action request, which addresses the cause. They are separate documents with separate registers, and a system that merges them produces NCRs that never get closed because the root cause is still being analysed, or corrective actions that are only ever "rework completed".

What an NCR must record

1. Number and date. Sequential, issued from one place, never reused. On a well-run project anyone can raise an NCR; only the quality manager numbers it, so the register is complete.
2. Where and what. Project, location by grid and level, element, the subcontractor or supplier responsible, and the ITP line or specification clause the work was being checked against.
3. The requirement. The specification clause, drawing reference or standard and clause, quoted. "Cover to reinforcement 40 mm, specification clause E10/310, BS EN 13670" is a requirement. "Poor workmanship" is not.
4. The nonconformity. What was found, measured, with the evidence: the reading, the photograph number, the check sheet reference, the delivery note. The description should let someone who was not there understand exactly what is wrong.
5. Detected by and how. Contractor's inspection, subcontractor's own check, client's witness, the certifying engineer, a customer complaint. The detected-by field is what later tells you whether your own inspections are finding the problems or the client is.
6. Immediate action. Work stopped, area quarantined, material segregated and labelled, the client informed where the contract requires it. The NCR records the containment even where the disposition is not yet decided.
7. Proposed disposition and authorised disposition, with the authority that decided it: see below.
8. Cost and programme effect, and whether a corrective action request has been raised.
9. Close-out. The rework or repair re-inspected against the original requirement, with the check sheet reference, by whom and when; or the concession reference; or the replacement's delivery and inspection. The signature that closes the NCR is the person who verified the work, not the person who did it.

The five dispositions

Every nonconformity ends in one of five ways, and the difference between them is who has to agree.

• Rework. Redo the work so that it conforms to the original requirement. The contractor's own quality manager can authorise it. Re-inspection is against the original acceptance criteria and is recorded on the original form of record, not on the NCR alone.
• Repair. Make the work acceptable by a method that does not restore it to the original requirement: an epoxy repair to honeycombing, a patch to a membrane, a splice to a cable. Repair changes the product, so the designer, and usually the client, has to accept the repair method before it is done and the result after.
• Accept as is, under concession. The work does not conform and will not be changed. Only the party whose requirement it is can waive it, which means the client or the designer on their behalf. The request is made on a concession form with the technical justification, the concession has its own register, and the NCR cannot close until the concession is granted in writing. An NCR closed "accepted by site manager" for a departure from the specification is a concession nobody had the authority to give.
• Reject and replace. Remove and replace with conforming product or work. The supplier or subcontractor is told in writing, the rejected material is quarantined until it leaves site, and the replacement is inspected on arrival.
• Regrade or use elsewhere. The material or component is used for a purpose with a lower requirement it does meet. Needs the designer's agreement to the new use and a record of where it went.

The disposition is the decision the NCR exists to record, and the authority column is the one an auditor reads. A register in which every disposition is rework signed by the site manager is either a very simple project or a register that is not recording what actually happened.

NCR, corrective action, concession: three records

The NCR controls the instance. The concession request records the client's agreement to accept a departure, where that is the disposition. The corrective action request records the analysis of why the nonconformity happened and what was changed to stop it recurring. Not every NCR needs a corrective action: one under-supported cable tray is corrected and closed. A pattern of them, a nonconformity that cost more than a threshold the procedure sets, a repeat of something already corrected, or anything detected by the client rather than by the contractor, should trigger one. The procedure should say what triggers it, so the decision is not left to how the quality manager feels that week.

The corrective action then has its own life: root cause analysed, action defined with an owner and a date, action implemented, effectiveness verified after an interval, closed. The effectiveness check is the step that is skipped most often and the one that matters most; a corrective action closed on the day the toolbox talk was given, with no check that the problem stopped, is a form.

The register

The NCR register is the list; the value is in what can be counted from it. Number, date, project, subcontractor, element, category of nonconformity, detected by, disposition, corrective action reference, date closed, days open. From those columns: nonconformities by subcontractor, by category, by month; the share detected by the client; the average days to close; the number open more than thirty days. That is the data behind the monthly quality report and the management review, and it is the data that identifies which subcontractor gets audited next and which activity needs a quality alert. A register that records only number, description and status can tell you how many NCRs there were, and nothing else.

How long to keep them

NCRs and concessions are kept for as long as the inspection records they relate to, which for most construction work means twelve years from practical completion and fifteen for dwellings, matching the limitation periods on the contract. Corrective action records need to be available for at least a full certification cycle; six years from closure is a reasonable rule. The retention schedule in the quality system should say so in those terms, because a general "keep for six years" rule will destroy the NCR file while the defects claim is still live.

Why NCRs are closed wrongly

• Closed on rework, not on re-inspection. The subcontractor says it is done; nobody checked. The NCR closes on the date the check sheet for the re-inspection is signed, not before.
• Concession by the wrong person. The site manager accepts a departure from the specification. The client finds it at handover.
• No requirement quoted. The NCR says the work is unacceptable; the subcontractor asks against what; the argument replaces the disposition.
• Raised against a person. The NCR names the operative. The subcontractor's response is about the operative and the cause is never found.
• Not raised. The quality manager fixes it quietly to keep the register short. The register then shows no problems on the project that had the most, and the corrective action that would have prevented the next one is never triggered.
• Raised without containment. The nonconforming material is recorded and left on the rack; it is installed the following week.
• No link to the record of the work. The NCR exists; the inspection record for the element still shows a pass. Every form of record that can produce a fail should carry an NCR reference box, and the NCR should cite the record.

The NCR as a good sign

Clients and auditors who know what they are looking at do not read a full NCR register as a bad project. They read it as a project where the inspections are finding things, the dispositions are being decided by the right people, and the causes are being addressed. The project with the empty register is the one they worry about. Raise them, number them, quote the requirement, contain the problem, get the right authority on the disposition, re-inspect, and count them.