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".
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 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 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. - 16492
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".
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 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 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. - 16492
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 ISO 14001 EMS.
