Auditing numerous companies of different sizes in various industries, I found that control of forms is one of the notorious issues with maintenance of ISO 14001:2004 EMS. Various businesses, by odd reasons, treat forms in a different way than other instructions, leaving them not controlled.
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.
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.
When questioning the validity of a not controlled form, I often hear: "This is just a form." It always escapes me, for what reason should a form be different than any other document! How would we know if we need a form if it is not referenced in our EMS documentation structure? After all, if you are not managing forms by assigning document or part title or No. and decide to revise them, how can you be certain that you use the latest revision? At best it would be difficult. In practice it would be impossible. Well, precisely what is a form? A quick quiz will help answer this question. What would you call 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
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, 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.
I suspect that the confusion regarding forms used in ISO 14001 environmental management systems is based on the fact that forms serve two purposes. Blank forms are brief instructions written in tabular language. The same form, after being completed, becomes a record. Since records are not required to have a number, I presume this transposes on the source document - our blank table. Let's remember this and treat our blank forms as instructions letting the documentation control process govern them. There are a couple of easy tests you may take when you are tempted to use a form that has not been identified:
- Let's say that somebody changed your favorite form. Would you want to know why?
- If you revised one of your ISO 14001 forms, would you like your users use the latest revision?
- 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. - 15433
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.
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.
When questioning the validity of a not controlled form, I often hear: "This is just a form." It always escapes me, for what reason should a form be different than any other document! How would we know if we need a form if it is not referenced in our EMS documentation structure? After all, if you are not managing forms by assigning document or part title or No. and decide to revise them, how can you be certain that you use the latest revision? At best it would be difficult. In practice it would be impossible. Well, precisely what is a form? A quick quiz will help answer this question. What would you call 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
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, 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.
I suspect that the confusion regarding forms used in ISO 14001 environmental management systems is based on the fact that forms serve two purposes. Blank forms are brief instructions written in tabular language. The same form, after being completed, becomes a record. Since records are not required to have a number, I presume this transposes on the source document - our blank table. Let's remember this and treat our blank forms as instructions letting the documentation control process govern them. There are a couple of easy tests you may take when you are tempted to use a form that has not been identified:
- Let's say that somebody changed your favorite form. Would you want to know why?
- If you revised one of your ISO 14001 forms, would you like your users use the latest revision?
- 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. - 15433
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 environmental consulting program. Quality Works consultants can save you time on developing or optimizing your ISO 14001 Environmental Management System.
