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.
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".
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.
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 - prepare 2-column table
2 - enter your company name into the first column
3 - write down your organization's Website address into the second column
I do not believe there is a reason why we would not call it an instruction or a procedure. Then, if we agree that this is an instruction, it should be controlled as any other environmental document.
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 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 you created a form for ISO 14001:2004 EMS and found it was changed, would you like to know who did it and why?
- If made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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?
If there was at least a one "yes", your form should be controlled as required by the environmental standard. - 14915
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".
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.
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 - prepare 2-column table
2 - enter your company name into the first column
3 - write down your organization's Website address into the second column
I do not believe there is a reason why we would not call it an instruction or a procedure. Then, if we agree that this is an instruction, it should be controlled as any other environmental document.
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 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 you created a form for ISO 14001:2004 EMS and found it was changed, would you like to know who did it and why?
- If made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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?
If there was at least a one "yes", your form should be controlled as required by the environmental standard. - 14915
About the Author:
The author published dozens of articles in the areas of ISO management systems. Optimize your ISO 14001 Environmental Management System in record time. Our environmental consultants helped dozens of companies around the World to implement and optimize their ISO 14001 EMS.
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