Do you control your forms within your ISO 14001 environmental management system? If you do - great, if not - consider it! One of the divisive topics with interpretation of ISO 14001:2004 and other standards is control of forms. Various organizations treat forms differently than other EMS documents and do not control them.
ISO 14001:2004, element 4.4.5, instructs an organization to control documents required by the EMS and the standard. While some companies often try to justify not controlled forms, let's find out if forms are the same as "documents" and if they also should be controlled.
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.
Often, being asked about not controlled forms, my clients reply: "We do not control forms, why?" I always wonder why a table form should be treated differently than any other instruction or a procedure. If a form is not controlled, how would we know that we need it for our EMS? If it is not controlled, it cannot be referenced within one's management system. If your forms are not controlled, how would you know that you use the latest revision of it? I guess all these questions lead us to a point where we should consider controlled forms! Let's see is a form qualifies to be a real document. A short test will help answer this question.
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
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, 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 appears that the puzzlement about forms and their control originates from the fact that forms serve 2 functions. Not completed forms are instructions in tabular language. After a form is filled out, it becomes a record. Records, as we know, do not have a document number, or a revision level. Records are controlled by different processes. Remember this and treat your forms as instructions controlled by your document control procedure. Actually, there is a simple test you may take when you are thinking about not controlling a form.
- 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 updated your "the best in the world" EMS test form, would you like users to know about your change?
- 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. - 15246
ISO 14001:2004, element 4.4.5, instructs an organization to control documents required by the EMS and the standard. While some companies often try to justify not controlled forms, let's find out if forms are the same as "documents" and if they also should be controlled.
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.
Often, being asked about not controlled forms, my clients reply: "We do not control forms, why?" I always wonder why a table form should be treated differently than any other instruction or a procedure. If a form is not controlled, how would we know that we need it for our EMS? If it is not controlled, it cannot be referenced within one's management system. If your forms are not controlled, how would you know that you use the latest revision of it? I guess all these questions lead us to a point where we should consider controlled forms! Let's see is a form qualifies to be a real document. A short test will help answer this question.
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
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, 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 appears that the puzzlement about forms and their control originates from the fact that forms serve 2 functions. Not completed forms are instructions in tabular language. After a form is filled out, it becomes a record. Records, as we know, do not have a document number, or a revision level. Records are controlled by different processes. Remember this and treat your forms as instructions controlled by your document control procedure. Actually, there is a simple test you may take when you are thinking about not controlling a form.
- 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 updated your "the best in the world" EMS test form, would you like users to know about your change?
- 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. - 15246
About the Author:
Mark Kaganov is a recognized author who published dozens of articles in the areas of ISO management systems. 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 EMS.
