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.
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 - 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, let's imagine that we were given a two-column form, only being asked to complete it. The first column title was "You company name" and the second column "Company's Website". Needless to say that following this procedure we would enter our company name and our Website address in the table. It means that we interpreted the table as an "instruction".
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 you revised one of your ISO 14001 forms, would you like your users use the latest revision?
- 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. - 15275
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 - 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, let's imagine that we were given a two-column form, only being asked to complete it. The first column title was "You company name" and the second column "Company's Website". Needless to say that following this procedure we would enter our company name and our Website address in the table. It means that we interpreted the table as an "instruction".
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 you revised one of your ISO 14001 forms, would you like your users use the latest revision?
- 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. - 15275
About the Author:
Mark Kaganov is a recognized author who published dozens of articles in the areas of ISO management systEnvironmental Management System. To optimize your ISO 14001 management system, check out our environmental consulting program. Quality Works consultants can save you time on developing or optimizing your ISO 14001 Environmental Management System.
