Sunday, January 18, 2009

ISO 14001:2004 - Managing Forms and Tables

By Mark Kaganov

Do you control your forms within your ISO 14001 environmental management system? If you do - great, if not - consider it! One of the divisive topics with interpretation of ISO 14001:2004 and other standards is control of forms. Various organizations treat forms differently than other EMS documents and do not control them.

Clause 4.4.5 of 14001:2004 Standard requires: "Documents required by the environmental management system shall be controlled." Now, let's investigate if a form qualifies to be a "document" that "shall" be controlled per the requirement of the standard.

Very often, companies use form templates for tests, master lists and other purposes. Frequently, it is not necessary to write a typical, instruction with all distinctive components, such as the purpose, scope, references, etc., if a simple table can assist us in achieving the same objective. Very often companies get non-conformities from their registrars during certification audits because their forms are not controlled.

Often, being asked about not controlled forms, my clients reply: "We do not control forms, why?" I always wonder why a table form should be treated differently than any other instruction or a procedure. If a form is not controlled, how would we know that we need it for our EMS? If it is not controlled, it cannot be referenced within one's management system. If your forms are not controlled, how would you know that you use the latest revision of it? I guess all these questions lead us to a point where we should consider controlled forms! Let's see is a form qualifies to be a real document. A short test will help answer this question.

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

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

This example demonstrate that our first three-line instruction in English (that obviously needs to be controlled), serves the same function, producing the same result, as our form. Therefore, the form as an instruction and "shall" be controlled as well.

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 made changes to your environmental form, would you like personnel on the floor use the latest rev.?

- 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?

Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices. - 14915

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