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.
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.
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 - enter your company name into the first 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.
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!
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.
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.
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 - enter your company name into the first 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.
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!
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.
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. Before you spent more time alone on developing your environmental management system, check out Quality Works Website to see how these products can help you avoid environmental problems
0 comments:
Post a Comment