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.

Tables and table-based forms are frequently used as lower-level documents. Often, it is not needed to write a conventional instruction with the purpose, scope and instructions if a simple table can do a job. One of the typical non-conformities that companies get during their audits of their ISO 14001 environmental management systems is against forms that are not part of the environmental documentation system.

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 – enter your company name into 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.

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 agree that our first three-line instruction in English was a “real” instruction, or a document that needs to be controlled, the second, blank form, resulting in the same output, must also be an instruction and then shall also be controlled!

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:

- Let’s say that somebody changed your favorite form. Would you want to know why?

- If made changes to your environmental form, would you like personnel on the floor use the latest rev.?

- If you were absent, (a journey to Russia, let’s say) would you like folks to find your form just by looking at a reference to it in your ISO 14001 environmental management system?

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