Wednesday, August 13, 2008

Document Dilemmas Part 1: To Control or Not to Control...

...Ahh, but this is really the question: "Do I have to control all my EMS documents?"

If I had a dime for every time I heard it,
I might be able to buy a gallon of gas!

This question reminds me of a nonsense riddle my grandfather, Scoop, used to tell: "What's the difference between an orange?"

And, no, I didn't forget the
"and what" part...

Done scratching your head?

The correct answer, according to Scoop, is: "It must be a bicycle because a vest doesn't have any arms." Yeah, grandpa was funny like that, and, come to think of it, this traumatic childhood memory probably goes a long way toward explaining why I drink so much now...

Nah... I drink becau
se I audit!

Anyway, this riddle is obviously absurd, and can only result in an absurd answer. Not surprisingly, it has a lot in common with that first question about document control. (Yes, there was a point to this blog besides a stroll down memory lane.)

The standard is actually very clear about document control (I know, I was shocked too). It's right there in the first sentence of element 4.4.5: "Documents required by the EMS and by this International Standard SHALL be controlled."

Not much wiggle room there...
But just in case there is still confusion, let's break this high-falutin' language down into what I like to call "Okie-speak" (in other words, the no-BS version):

If you create, have or use a document, ANY document, you gotta control it.


GASP!!!***SPLUTTER*** ##CHOKE## ----WHEEZE--- &^%$%#@*!?

Surely she doesn't mean EVERY document! Why, that would be impossi
ble! She's describing a nightmare world!!! What a crackpot!!

She is obviously clueless about the extreme difficulty we have in controlling the few, elite documents that we have chosen for such a high honor! This is outrageous!

I knew it: bloggers can't be trusted, there is no accoun
tability. She can just say anything she wants!!!! This is utter horsesh--


Sorry, I stepped away for a second - had to freshen my drink. Hopefully you did too - after all those peanuts, I bet you're thirsty!. OK, let's continue down this path of "utter madness."

Maybe you have nowhere else to go and nothing else to do, or maybe you are tipsy enough not to be offended by my extraordinary philosophy on document control. Whatever the reasons you have stuck with me, you may nonetheless still be skeptical. Good for you, you're still reasoning - that means you can't possibly have alcohol poisoning! But wipe the drool off your chin and rest (hopefully in an upright position) assured that I am not alone in this interpretation. See TC 207 COI 99-03.A7.

Had too many Harvey Wallbangers or Moscow Mules to remember what the #$%& TC 207 is? read Dr. Strangeaudit... to find out more.

Believe me, when I was an ISO newbie back in the day (well after Scoop and well before auditing), I felt that document control did nothing but create a red tape nightmare. This philosophy was based in my gripe that I had enough worries what with the EPA breathing down my neck, and all the laws I had to follow, etc., etc, wah, wah, wah.

No amount of whining can change the fact that document control is an essential key in effective business management, regardless of the type of system. But no matter whom I talk to, it seems that the number one reason people don't want to control a document is because...

\/\/\/\/\/\/ DRUM ROLL PLEASE \/\/\/\/\/\/


But after hundreds of audits, and more than a few attempts to revamp inherited systems, I can clearly see the root cause of the problem, and it ain't the standard folks. Just like Charlton Heston said in Soylent Green: "It's people!"

The standard requires very simple controls. WE create these document control nightmares ourselves - Freud would have a field day with us on this one!

Most document control methods are overly complex and, in reality, more an attempt to create a loophole for document control rather than to actually control a document. To read more on this fascinating (and probably highly inflammatory) subject, check out the next installment in the Document Dilemmas series - Ultimate Document Smack Down!!!

But this post still needs some perspective, some seasoning, or as Emeril might say, some BAM! So here comes the heat - you may want to get out of the proverbial kitchen here, unless, like Hillary Clinton, you are very comfortable there.

For the quality gurus out there who stumbled across this blog while surfing for S&M sites, think of it this way:
You wouldn't use an uncalibrated piece of equipment to collect data about the management system - you're certainly not allowed to by the standard - it might help you to imagine the standard wearing a lot of shiny, black leather and carrying a whip. So, think of document control as a form of calibration. You can't use an uncontrolled (uncalibrated) document. And if you did, you would get a spanking for being naughty (and not just because you like it).

Since environmental folks surf for bestiality sites (it's more "natural"), they wouldn't see this blog unless I renamed it "Show Me the Sheep" or something. But even if they did, the above example wouldn't register with most of them who usually aren't as well-trained (I'm not even sure most of them are potty trained) in the finer points of calibration. I am speaking from experience (ESPECIALLY the potty trained part).

But that's OK. I just pull on my Depends and remember that the primary purpose of document control is to ensure everyone has access to current, consistent and accurate information. So here's an example the "bunny huggers" can understand: If you control the procedure for hazardous waste management so that it gets revised when the accumulation time limit changes from 180 days to 90 days, you won't have to trade cigarettes with your cell mate to get your diapers.

OK, perhaps the spiciness has left a bad taste in your mouth. Let's switch gears. It's late as I finish this up, last call has come and gone, the kitchen's closed, and I'm in the mood for some warm milk, cookies and a nice bedtime story. So here goes...

es, Virginia, there is a Santa, and yes, you must control all your documents - even your Christmas wish list. Otherwise, Santa might leave you a door mouse instead of a doll house because he didn't know which revision was correct.

Let's stop here and continue the story another night...

Till then, sleep tight and don't let the auditors bite....

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