Control of forms for ISO 14001 EMS
at Thursday, January 29, 2009
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".
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.
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 - put your business's URL into the 2-nd 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 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 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 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 you answered, "yes" at least once, your form is a definite candidate for being a part of your formal ISO 14001 documentation management system.
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.
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 - put your business's URL into the 2-nd 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 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 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 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 you answered, "yes" at least once, your form is a definite candidate for being a part of your formal ISO 14001 documentation management system.
About the Author:
The author published dozens of articles in the areas of ISO 9001, ISO 13485 and ISO 14001 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 EMS.
