Friday, January 23, 2009

ISO 14001 - Environmental forms

By Mark Kaganov

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.

Per ISO 14001:2004, clause 4.4.5, Control of documents, "Documents required by the environmental management system and by this International Standard shall be controlled." Let's see if a form qualifies to be a "document" that "shall 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 - prepare 2-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, 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 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 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?

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.

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