Auditing numerous companies of different sizes in various industries, I found that control of forms is one of the notorious issues with maintenance of ISO 14001:2004 EMS. Various businesses, by odd reasons, treat forms in a different way than other instructions, leaving them not controlled.
Per ISO 14001:2004, clause 4.4.5, Control of documents, "Documents required by the environmental management system and by this International Standard shall be controlled." Let's see if a form qualifies to be a "document" that "shall be controlled".
Tables and table-based forms are frequently used as lower-level documents. Often, it is not needed to write a conventional instruction with the purpose, scope and instructions if a simple table can do a job. One of the typical non-conformities that companies get during their audits of their ISO 14001 environmental management systems is against forms that are not part of the environmental documentation system.
When questioning the validity of a not controlled form, I often hear: "This is just a form." It always escapes me, for what reason should a form be different than any other document! How would we know if we need a form if it is not referenced in our EMS documentation structure? After all, if you are not managing forms by assigning document or part title or No. and decide to revise them, how can you be certain that you use the latest revision? At best it would be difficult. In practice it would be impossible. Well, precisely what is a form? A quick quiz will help answer this question. What would you call a list of directions telling us to:
1 - make a table with two columns
2 - write down your business name into the 1-st column
3 - write down your organization's Website address into the second column
There is no doubt; most of us would call this three-line direction a procedure or an instruction. So, if this is an instruction, it shall be controlled per ISO 14001 Standard.
Now, what if we were given a two-column table where the first column was titled "You enterprise name" and the second column "Internet address". We were asked to complete the form. Easy to imagine, we would enter our company's name and our URL in the table. It means that we interpreted this table as an "instruction". If it walks like duck it is a duck! OK, most like a duck
If we concur that the first three-line instruction written in English was a "real" instruction that "shall" be controlled, the other, empty form, resulting in the same output, must also be an instruction! Shouldn't this type of an instruction be controlled also? I believe it should!
It appears that the puzzlement about forms and their control originates from the fact that forms serve 2 functions. Not completed forms are instructions in tabular language. After a form is filled out, it becomes a record. Records, as we know, do not have a document number, or a revision level. Records are controlled by different processes. Remember this and treat your forms as instructions controlled by your document control procedure. Actually, there is a simple test you may take when you are thinking about not controlling a form.
- If in the past you developed a form for your environmental system and found it had been changed, would you want to know why it was done?
- If you updated your "the best in the world" EMS test form, would you like users to know about your change?
- If you were absent, (a journey to Russia, let's say) would you like folks to find your form just by looking at a reference to it in your ISO 14001 environmental management system?
If there was at least a one "yes", your form should be controlled as required by the environmental standard.
Per ISO 14001:2004, clause 4.4.5, Control of documents, "Documents required by the environmental management system and by this International Standard shall be controlled." Let's see if a form qualifies to be a "document" that "shall be controlled".
Tables and table-based forms are frequently used as lower-level documents. Often, it is not needed to write a conventional instruction with the purpose, scope and instructions if a simple table can do a job. One of the typical non-conformities that companies get during their audits of their ISO 14001 environmental management systems is against forms that are not part of the environmental documentation system.
When questioning the validity of a not controlled form, I often hear: "This is just a form." It always escapes me, for what reason should a form be different than any other document! How would we know if we need a form if it is not referenced in our EMS documentation structure? After all, if you are not managing forms by assigning document or part title or No. and decide to revise them, how can you be certain that you use the latest revision? At best it would be difficult. In practice it would be impossible. Well, precisely what is a form? A quick quiz will help answer this question. What would you call a list of directions telling us to:
1 - make a table with two columns
2 - write down your business name into the 1-st column
3 - write down your organization's Website address into the second column
There is no doubt; most of us would call this three-line direction a procedure or an instruction. So, if this is an instruction, it shall be controlled per ISO 14001 Standard.
Now, what if we were given a two-column table where the first column was titled "You enterprise name" and the second column "Internet address". We were asked to complete the form. Easy to imagine, we would enter our company's name and our URL in the table. It means that we interpreted this table as an "instruction". If it walks like duck it is a duck! OK, most like a duck
If we concur that the first three-line instruction written in English was a "real" instruction that "shall" be controlled, the other, empty form, resulting in the same output, must also be an instruction! Shouldn't this type of an instruction be controlled also? I believe it should!
It appears that the puzzlement about forms and their control originates from the fact that forms serve 2 functions. Not completed forms are instructions in tabular language. After a form is filled out, it becomes a record. Records, as we know, do not have a document number, or a revision level. Records are controlled by different processes. Remember this and treat your forms as instructions controlled by your document control procedure. Actually, there is a simple test you may take when you are thinking about not controlling a form.
- If in the past you developed a form for your environmental system and found it had been changed, would you want to know why it was done?
- If you updated your "the best in the world" EMS test form, would you like users to know about your change?
- If you were absent, (a journey to Russia, let's say) would you like folks to find your form just by looking at a reference to it in your ISO 14001 environmental management system?
If there was at least a one "yes", your form should be controlled as required by the environmental standard.
About the Author:
The author published dozens of articles in the areas of ISO 9001, ISO 13485 and ISO 14001 management systems. You can develop your ISO 14001 Environmental Management System in record time. Our environmental consultants helped dozens of companies around the World to implement and You can develop their EMS.
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