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.
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 - prepare 2-column table
2 - enter your company name into 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".
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!
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:
- 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 made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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 there was at least a one "yes", your form should be controlled as required by the environmental standard. - 16747
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 - prepare 2-column table
2 - enter your company name into 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".
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!
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:
- 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 made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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 there was at least a one "yes", your form should be controlled as required by the environmental standard. - 16747
About the Author:
Mark Kaganov published dozens of articles in the areas of ISO 9001, ISO 13485 and ISO 14001 management systems. Before you spent more time alone on developing your environmental management system, check out Quality Works Website to see how these products can help you avoid environmental problems
