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.
Very often, companies use form templates for tests, master lists and other purposes. Frequently, it is not necessary to write a typical, instruction with all distinctive components, such as the purpose, scope, references, etc., if a simple table can assist us in achieving the same objective. Very often companies get non-conformities from their registrars during certification audits because their forms are not controlled.
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 - write down your business name into the 1-st column
3 - put your business's URL into the 2-nd 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.
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 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 you created a form for ISO 14001:2004 EMS and found it was changed, would you like to know who did it and why?
- If made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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?
If you answered, "yes" at least once, your form is a definite candidate for being a part of your formal ISO 14001 documentation management system. - 15485
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.
Very often, companies use form templates for tests, master lists and other purposes. Frequently, it is not necessary to write a typical, instruction with all distinctive components, such as the purpose, scope, references, etc., if a simple table can assist us in achieving the same objective. Very often companies get non-conformities from their registrars during certification audits because their forms are not controlled.
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 - write down your business name into the 1-st column
3 - put your business's URL into the 2-nd 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.
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 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 you created a form for ISO 14001:2004 EMS and found it was changed, would you like to know who did it and why?
- If made changes to your environmental form, would you like personnel on the floor use the latest rev.?
- 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?
If you answered, "yes" at least once, your form is a definite candidate for being a part of your formal ISO 14001 documentation management system. - 15485
About the Author:
Mark Kaganov is a recognized author who 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.
