One of the disruptive points with interpretation of ISO 14001:2004 Standard and other quality and environmental standards is control of forms. Many companies treat forms in a different way than procedures, instructions or other documents.
ISO 14001:2004, element 4.4.5, instructs an organization to control documents required by the EMS and the standard. While some companies often try to justify not controlled forms, let's find out if forms are the same as "documents" and if they also should be controlled.
Organizations use forms and tables within their environmental, quality, H&S and other management systems. Often, instead of preparing a traditional instruction or a procedure with all the sections, such as scope, purpose and process description, a simple form can provide this information. Frequently registrars issue companies non-conformities for their not controlled forms of their EMS.
Repeatedly I discuss this issue with my clients. Regularly I hear the same answer "Why do I need control a form?" Honestly, I do not understand this! Why should a form be treated differently from any other document? How would one know that we need a form if it is not referenced in our ISO 14001 management system? If forms are not managed by your documentation system, and you decide to modify them, how can you be confident that you make changes to the latest revision? Anyway, what is a form? A short review will help answering this question. If we have a list of directions telling us to:
1 - make a table with two columns
2 - note your organization's name in the first column
3 - enter your company's URL into the second column
Hardly anybody will argue that this three-line writing is in fact an instruction to make and complete this form. So if this is an instruction, it "shall" be controlled, right? The standard said so.
Let's look at another example. Somebody gave us a two-column table and asked us to fill it out. The first column has a title of "Your business name" and the other column "Business URL". I bet most of us would enter our business name in the 1st column and our URL in the second one. Does it mean that we treated the blank table as an "instruction"? I'll tell you a secret: we did!
If we agree that our first three-line instruction in English was a "real" instruction, or a document that needs to be controlled, the second, blank form, resulting in the same output, must also be an instruction and then shall also be controlled!
It seams to me that misunderstanding concerning blank tables and forms is because forms serve two purposes. Blank forms are short directions written in tabular language, but when a form is completed, it becomes a record. Procedures and other documents are controlled differently than records. Let's realize this difference and treat not completed forms as any other procedure or instruction controlled by our documentation management procedure. If you want to have a not controlled form with in your EMS, consider answering three questions:
- 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 on vacation in Japan, would you like folks to be able to find your EMS form just by finding a reference to it within your Environmental management system?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices.
ISO 14001:2004, element 4.4.5, instructs an organization to control documents required by the EMS and the standard. While some companies often try to justify not controlled forms, let's find out if forms are the same as "documents" and if they also should be controlled.
Organizations use forms and tables within their environmental, quality, H&S and other management systems. Often, instead of preparing a traditional instruction or a procedure with all the sections, such as scope, purpose and process description, a simple form can provide this information. Frequently registrars issue companies non-conformities for their not controlled forms of their EMS.
Repeatedly I discuss this issue with my clients. Regularly I hear the same answer "Why do I need control a form?" Honestly, I do not understand this! Why should a form be treated differently from any other document? How would one know that we need a form if it is not referenced in our ISO 14001 management system? If forms are not managed by your documentation system, and you decide to modify them, how can you be confident that you make changes to the latest revision? Anyway, what is a form? A short review will help answering this question. If we have a list of directions telling us to:
1 - make a table with two columns
2 - note your organization's name in the first column
3 - enter your company's URL into the second column
Hardly anybody will argue that this three-line writing is in fact an instruction to make and complete this form. So if this is an instruction, it "shall" be controlled, right? The standard said so.
Let's look at another example. Somebody gave us a two-column table and asked us to fill it out. The first column has a title of "Your business name" and the other column "Business URL". I bet most of us would enter our business name in the 1st column and our URL in the second one. Does it mean that we treated the blank table as an "instruction"? I'll tell you a secret: we did!
If we agree that our first three-line instruction in English was a "real" instruction, or a document that needs to be controlled, the second, blank form, resulting in the same output, must also be an instruction and then shall also be controlled!
It seams to me that misunderstanding concerning blank tables and forms is because forms serve two purposes. Blank forms are short directions written in tabular language, but when a form is completed, it becomes a record. Procedures and other documents are controlled differently than records. Let's realize this difference and treat not completed forms as any other procedure or instruction controlled by our documentation management procedure. If you want to have a not controlled form with in your EMS, consider answering three questions:
- 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 on vacation in Japan, would you like folks to be able to find your EMS form just by finding a reference to it within your Environmental management system?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices.
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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