Norco Herrington

Posts Tagged ‘environmental consulting’

One of the disruptive points with interpretation of ISO 14001:2004 Standard and other quality and environmental standards is control of forms. Many companies treat forms in a different way than procedures, instructions or other documents.

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.

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 - make a table with two columns

2 - note your organization’s name in the first column

3 - write down your organization’s Website address into the second column

Hardly anybody will argue that this three-line writing is in fact an instruction to make and complete this form. So if this is an instruction, it “shall” be controlled, right? The standard said so.

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!

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 there was at least a one “yes”, your form should be controlled as required by the environmental standard.