For years I’ve written at length about Annex L (and its predecessor, Annex SL), and why it’s such a disaster for ISO standards and the development committees that slavishly support it. I thought I’d summarize my points, however, to make it easier to understand.
The issue is important, because ISO management system standards affect millions of companies worldwide, and have follow-on impacts in endless industries that assume such standards are the product of industry subject matter experts and international consensus. Annex L disproves both these key points.
Despite the fact that ISO TMB is taking away the only job they have and usurping standards-writing responsibilities from them, Annex L’s sycophantic supporters will decry this as “fake news.” To preempt this knee-jerk (and wholly false) claim, I’m providing the following arguments with justified reasons or evidence.
So without further delay, here are the key points on why Annex L is so toxic:
|Reason||Information Based On|
|Despite comprising over 30% of the ISO 9001 standard, and similar level of content for other ISO standard, Annex L is not written by official technical committees nor subject matter experts.||Based on word count analysis of published standard vs. Annex L text, and official ISO procedures.|
|Annex L is written by the ISO Technical Management Board which, per ISO’s own procedures, cannot write ISO standards. It is a management body only, not a standards writing committee.||Based on published ISO facts, and Consolidated ISO Supplement|
|TMB is not required to ensure participation by national delegates, developing nations, or anyone at all. It answers only to the ISO executive.||Based on ISO Rules of Procedure, ISO TMB Rules of Procedure and Consolidated ISO Supplement|
|The use of the TMB to write standards violates ISO’s own rules of procedure, which dictate that Technical Committees shall perform this activity.||Based on ISO Rules of Procedure, ISO TMB Rules of Procedure and Consolidated ISO Supplement|
|The TMB committee that writes Annex L is largely unknown, and its participants intentionally hidden. There are no requirements that these authors be subject matter experts in any field, whatsoever.||Based on published information on ISO TMB, and ISO TMB public website|
|There are no known quality management professionals on the TMB committee, despite the Annex L text being inserted into ISO 9001.||Based on published information on ISO TMB, and ISO TMB public website|
|Text written by the TMB under Annex L is mandatory, and cannot be edited nor even voted on.||Based on official TMB memos to Technical Committees, Consolidated ISO Supplement|
|TMB allows some committees to have “input” during development of Annex L, but only a handful (less than 10 committees out of hundreds). This input is nonbinding, and TMB routinely ignores it.||Based on public statements by leaders of Annex L committee, TC 176, and others; also, official TMB memos.|
|Committees who wish to deviate from Annex L text must request permission to do so; TMB has so far rejected such requests. Committees who revolt face complete dissolution by the TMB, which reserves the powers to do so.||Based on official TMB memos to Technical Committees, Consolidated ISO Supplement|
|Annex L text is never officially voted on. Once it is inserted into a standard, the entire standard is voted on (up or down) but not the Annex L text itself.||Based on ISO 9001 voting records, official TMB memos to Technical Committees, ISO rules on standards approval|
|Standards committee members are prohibited from commenting on Annex L text; any comments received related to Annex L are automatically deleted, and not considered during voting.||Based on ISO 9001 voting records, official TMB memos to Technical Committees, official statements by BSI Secretariat to TC 176.|
|The use of Annex L violates all six principles of standards development under the WTO Technical Barriers to Trade regulations. WTO cannot enforce this, however, since ISO is not a nation, and WTO can only impose sanctions on nations||Based on WTO TBT regulations.|
|The use of Annex L undermines the entirety of the ISO standard development process; through Annex L, the ISO TMB has usurped the role of writing standards from the representative ISO Member and their technical committees, and reduced the committees to mere rubber stamp bodies.||Based on ISO Rules of Procedure, standards development marketing materials, Consolidated ISO Supplement.|
|The few known authors of Annex L are nearly all private consultants who agree to sell ISO’s talking points in exchange for selling Annex L related consulting services later. This violates ISO’s rules on equal distribution of interest groups in the development of standards.||Based on public domain evidence of known Annex L committee members.|