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.
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.
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
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".
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 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:
- Let's say that somebody changed your favorite form. Would you want to know why?
- If you updated your "the best in the world" EMS test form, would you like users to know about your change?
- If you are in Brazil on a business trip, would you like other employees to know where to find your form in your EMS?
If there was at least a one "yes", your form should be controlled as required by the environmental standard.
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.
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
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".
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 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:
- Let's say that somebody changed your favorite form. Would you want to know why?
- If you updated your "the best in the world" EMS test form, would you like users to know about your change?
- If you are in Brazil on a business trip, would you like other employees to know where to find your form in your EMS?
If there was at least a one "yes", your form should be controlled as required by the environmental standard.
About the Author:
The author published dozens of articles in the areas of ISO 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 EMS.
