Annex SL was a massive violation of ISO principles because Tyrion Lannister killed his father with a crossbow on a toilet, not with a lightsaber on the Death Star. Stick with me on this.
Publish or Perish.
ISO is a publishing house. That’s literally what they do: they publish books that we just happen to call “standards.” ISO itself doesn’t write the books, they leave that to authors selected by member nations. In fact, ISO is disallowed from intruding on the process by which members select their delegates.
So ISO is just a facilitator, to help the authors work on their given subject matter within a controlled environment that ensures the resulting standards don’t become illegal barriers to free trade, and that they are developed under international expectations. They are supposed to ensure that standards consider the needs of developing nations, for example.
But ISO can’t inject itself into the creative process, since the motives of ISO — as a publisher — are vastly different from those of the various standards committees. For example, a Technical Committee dedicated to creating a new standard for soy-based printing ink shouldn’t have to abandon its work because ISO doesn’t want to promote expensive new inks which would drive up its own printing costs.
But with Annex SL, ISO breached the firewall that exists to prevent such conflicts of interest, and forever changed how it would be perceived. ISO is no longer an objective, impartial facilitator: now, standards bodies and member nations are subservient to ISO’s commercial interests and the whims of its financial accountants.
Imagine Grapes of Wrath with Car Chases …
Let’s take a different scenario. Bantam Books, a publishing imprint of Random House, publishes the wildly successful series of fantasy novels by George RR Martin called “A Song of Ice and Fire,” better known as “Game of Thrones” for its TV adaptation. The books are massive, 12-foot thick monstrosities, and Martin is famous for writing very, very slowly. As frustrating as it might be for the accountants at Random House, there’s nothing they can do to speed Martin up, and even though their revenue will skyrocket whenever he publishes a new entry in the series, they have to wait. They also can’t tell Martin what to write.
Random House also publishes a series of science fiction novels for the Star Wars franchise. Two separate franchises, two separate genres, two separate sets of authors. The public understands that there is no reason to expect these two book series to be remotely similar in any way.
But imagine if the ISO model was followed by Random House. In such a scenario, Random House’s accounting department would develop a master rule book that was imposed on all its published authors, without their permission or input, in which Random House could demand anything they like of their authors. They could force George RR Martin to write a new book every six months, or have him replaced with an author who could; Martin would lose all his rights to Game of Thrones.
Next, Random House could decide on doubling their revenue by doing a “crossover” between its Game of Thrones and Star Wars franchises, in the hopes of getting one set of readers hooked on the other set of books. Perhaps they demand that Martin have the Lannisters wield lightsabers, and for Castle Black to be protected by Wookiees. So, in a contract with Martin, they demand he incorporate these plot points or — again — he gets replaced by someone who will. The decisions are made with the point of increasing Random House’s revenue, with disregard for the readers of the books or its authors.
… Or To Kill a Mockingbird on the Planet of the Apes
This is what ISO has done with Annex SL. Created by the bureaucratic oversight body called the Technical Management Board (TMB), a handful of un-elected ISO functionaries decided to impose a mandatory set of guidelines on all the Technical Committee authors, for the purposes of greasing the wheels of ISO’s standards sales machines. ISO has been trying to create an “integrated” standard model for decades, making the argument that this would benefit companies who adopt more than one management system standard at a time. The argument is a red herring, since ISO has never published any figures showing an international swell of interest in such integrated management systems (IMS), and — based on ISO Survey Data — the number of organizations that have implemented an IMS is infinitesimally small. (Consider that the total number of US organizations certified to both ISO 9001 and ISO 14001 cannot be greater than 6,586, since that is the number of ISO 14001 certificates issued.) ISO counters this argument by saying “certification isn’t a metric of standard adoption” since companies may adopt ISO standards without certifying to them; but this is unproven, and ISO has never provided any data to back it up.
In reality, ISO believes that “harmonizing” standards will boost the sale of those standards; that’s their business model, and their sole reason for existing. With the various attempts at harmonization, including Annex SL, we see just how much chaos ISO is willing to throw into the market, too, proving they are not doing this for some altruistic purpose designed to help standards users. Instead, they are willing to alienate entire industries (such as automotive, aerospace, pharma and more) and jettison all ISO principles of transparency and usefulness in order to sell standards.
So, again: the argument that Annex SL and harmonization was intended to help standards users is completely false.
And despite the talking points, Annex SL doesn’t just impose structure or formatting conventions. Like forcing George RR Martin to incorporate laser-wielding TIE Fighters in the siege on Winterfell, ISO has imposed content on its TCs, demanding that certain words and concepts be included no matter if they are utterly unrelated to the subject under standardization, or if they contradict the subject entirely. The minute the ISO TMB told every management system standard Technical Committee to include “risk and opportunity” they effectively forced the authors to alter their plot to suit ISO’s sales goals.
Willing Dupes
Worsening matters is how ISO rewards “company men” who then go around the world repeating ISO’s talking points that the entire thing was done for the benefit of users, and that Annex SL was adopted under consensus. The latter point, they argue, is evident in that TC 176 (for example) did not oppose the imposition of Annex SL, and went along with it. They fail to tell anyone that the decision was moot — TC 176 could never have refused Annex SL to begin with, lest they be disbanded. So the fact that they went along with a mandatory requirement is meaningless.
Furthermore, TC 176 also did very little consulting with its members on Annex SL before announcing that it was mandatory. So those in TC 176 who are now giving webinars boasting about the benefits and origin of Annex SL are just acting as volunteer salesmen for ISO’s publishing machine. None of us should fall for the trick.
The entire thing would be problematic for ISO, since it violates WTO regulations which mandate such standards must be voluntary and developed by consensus. The imposition of Annex SL by the unelected TMB is proof that ISO violated these regulations in deference to its commercial interests. But I say the thing “would be” problematic because ISO enjoys a special relationship with WTO: they have no idea what ISO is doing, because no one is paying any attention. Because ISO cronies — such as the certification bodies — have nearly airtight control over anything that gets published about ISO, it’s impossible to get anyone’s attention on the matter. The CBs ultimately control who talks to the WTO, who gets published in the quality press, and the talking points that get promoted. It’s not an accident that TC 176’s recent webinar merely parroted ISO press releases.
At some point, though, ISO and the CBs (through the IAF) are going to be investigated for fraud, with possible sanctions imposed and perhaps even a few criminal complaints. They can only abuse world economies for so long before nations and the World Bank take notice.
Perhaps these pressures are the reason so many ISO and CB talking heads are taking early retirement?
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 35 years’ experience implementing ISO 9001 and AS9100 systems, and helps establish certification and accreditation bodies with the ISO 17000 series. He is a vocal advocate for the development and use of standards from the point of view of actual users. He is the writer and artist of THE AUDITOR comic strip, and is currently writing the DR. CUBA pulp novel series. Visit www.drcuba.world
