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.
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.
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 - draw a two-column table
2 - note your organization's name in 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, 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 concur that the first three-line instruction written in English was a "real" instruction that "shall" be controlled, the other, empty form, resulting in the same output, must also be an instruction! Shouldn't this type of an instruction be controlled also? I believe it should!
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 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 are in Brazil on a business trip, would you like other employees to know where to find your form in your EMS?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices. - 15359
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.
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.
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 - draw a two-column table
2 - note your organization's name in 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, 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 concur that the first three-line instruction written in English was a "real" instruction that "shall" be controlled, the other, empty form, resulting in the same output, must also be an instruction! Shouldn't this type of an instruction be controlled also? I believe it should!
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 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 are in Brazil on a business trip, would you like other employees to know where to find your form in your EMS?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices. - 15359
About the Author:
Mark Kaganov is a recognized author who 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.
