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.
Repeatedly I discuss this issue with my clients. Regularly I hear the same answer “Why do I need control a form?” Honestly, I do not understand this! Why should a form be treated differently from any other document? How would one know that we need a form if it is not referenced in our ISO 14001 management system? If forms are not managed by your documentation system, and you decide to modify them, how can you be confident that you make changes to the latest revision? Anyway, what is a form? A short review will help answering this question. If we have a list of directions telling us to:
1 – prepare 2-column table
2 – note your organization’s name in the first 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.
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
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.
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 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.
Read more on ISO 9001 Standards at http://www.iso9001store.com
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