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 - make a table with two columns
2 - write down your business name into the 1-st column
3 - write down your organization's Website address 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".
This example demonstrate that our first three-line instruction in English (that obviously needs to be controlled), serves the same function, producing the same result, as our form. Therefore, the form as an instruction and "shall" be controlled as well.
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 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?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices.
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 - make a table with two columns
2 - write down your business name into the 1-st column
3 - write down your organization's Website address 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".
This example demonstrate that our first three-line instruction in English (that obviously needs to be controlled), serves the same function, producing the same result, as our form. Therefore, the form as an instruction and "shall" be controlled as well.
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 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?
Just one "Yes" to the questions above indicates that your form is definitely a candidate for documentation control practices.
About the Author:
Mark Kaganov published dozens of articles in the areas of ISO 9001, ISO 13485 and ISO 14001 management systems. If you need help with developing your EMS, check out environmental consulting program. Quality Works consultants can save you time on developing or optimizing your ISO 14001 EMS.
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