Bureaucracy, Meet Catastrophe II: How the ISO Certification Scheme Justifies Inaction in the Face of Evil

The Russian invasion of Ukraine has provided a glaring, indisputable look at how the International Organization for Standardization (ISO) and its certification scheme actors act with inhuman disregard for decency and moral obligation. As each day of the invasion goes by, we wait for these bodies to follow the actions of so many governments, private companies, and NGOs, and stop selling products and services in those countries. But we keep waiting. And waiting.

Not only ISO.  The IAF has invoked a (largely imagined) “neutrality policy” to justify its inaction. ILAC has remained silent altogether, while also citing “neutrality policies” behind closed doors. IAF regional bodies, like APAC, continue to operate as if it were just another Monday, pointing to their Mutual Recognition Agreements (MRAs). Accreditation bodies like UKAS and ANAB have issued tepid statements, but fell short of stopping revenue-generation activities in regions or with countries under sanctions. The IAQG issued a statement claiming it would suspend AS9100 certifications in Russia and Belarus, but (as of this writing) never actually did so.

Meanwhile, Russia has bombed a maternity hospital, targeted a nuclear facility, and is committing nearly daily atrocities. The rest of the world has reacted, cutting off Russia’s economy, imposing and cross-honoring sanctions, and ejecting Russia from key committees and posts. Commercial companies have responded likewise, pulling their businesses from Russia, while recognizing that the invasion represents an international horror the likes of which the world has not seen in generations.

The contrast is stark: images of slaughtered civilians, the victims of an unprovoked invasion, compared with the muted and — dare I say it? — dull proclamations by so-called “leaders” sitting in carpeted offices, drinking cappuccinos, appearing entirely and wholly soulless.

And it’s not just the invasion of Ukraine. The logos and “official marks” appear on certificates issued to companies responsible for human trafficking, heroin smuggling, genocide, environmental disasters, plant explosions, international bribery scandals responsible for toppling entire governments, forensic data falsification, and endless deadly product releases.

So why does this happen? How can the individual, human beings behind ISO, IEC, ILAC, IAF, the IAF regional bodies, and accreditation & certification bodies pretend nothing is going on? How are they able to switch off their souls, and ignore their role in enabling wholesale humanitarian abuse?

Policies As Reality Buffers

Many such organizations just remain silent, hoping the spotlight will fade. But for those organizations which have released statements on the war, their inaction is justified by citing “policies” or “procedures.” to them, this is the go-to, get-out-of-jail-free card.

Take ANAB, for example, VP Lori Gillespie (who also acts as IAF’s Vice-Chair) leaned into a dated IAF Informative Document ID3, entitled “Management of Extraordinary Events or Circumstances Affecting ABs, CABs and Certified Organizations.” That document was written in 2011, and has nothing to do with either the Russian invasion specifically, or adhering to international sanctions in general. Gillespie also quoted “ANAB accreditation rule AR9”, Certified Organizations Business Continuity and Disaster Recovery, an equally out-of-context document. Neither document was remotely applicable for current events, but Gillespie’s brain cannot process any scenario that she can’t put into the framework of a “procedure.”

Gillespie, one presumes, was born of parents. A mother gave birth to her. She wasn’t grown in a lab or assembled from parts. She comes from a prototypical, corn-fed, midwestern, suburban, cookie-cutter mold, and is famous for nothing but a bland personality and apparent inability to earn enough respect from her peers at ANAB to win her the CEO seat. She’s tolerated the disrespect of a revolving door of aggressive, male superiors for decades, but shuffles on. A dutiful soldier, a dutiful bureaucrat. If this were Fritz Lang’s Metropolis, she’d be piling into that elevator with the rest of them, head down, shuffling dutifully.

But Gillespie breathes. And eats. And has a family. So she must be human. So why can’t she “see” the images on TV that the rest of us do? What dysfunction allows her to wake up in her prototypical, corn-fed, midwestern, suburban, cookie-cutter house and then do work that actively support the Putin regime? How could the VP of ANAB forget that the first “A” in that name stands for “American” and not “Authoritarian?”

Prior to the Russian invasion, I might have dismissed it as someone “on the spectrum,” where a common symptom is “rigid processing.” Gillespie has never shown the ability to see the bigger picture, nor understand how quoting a procedure in a given moment may not only be bad practice, but is often socially inappropriate. A mother mourning her dead baby doesn’t give a shit if Gillespie has a “procedure.”

But autism spectrum doesn’t explain it, because Gillespie isn’t alone. Anne Caldas at ANSI, Charles Corrie at BSI, Sean Maccurtain (formerly) of CASCO, Lorri Hunt of US TAG 176, Tim Lee of IAQG, Graeme Drake of APAC, Martine Blum of EA, Sergio Mujica of ISO, Emanuele Riva and Elva Nilsen of IAF, Jackie Burton of UKAS, Sheronda Jeffries of QuEST Forum, Nigel Croft of (well, … everything) — they all exhibit the same behavior. A profession may attract a certain sort of dysfunctional person, but this is far beyond this. These people can’t all be on the spectrum.

The representative of certification body URS, Kristel Pitcher, gave a truly Gillespian response when I asked URS to commit to ceasing all certifications in Russia and Belarus. Instead, Pitcher wrote, “we are acting inline with varying instructions from our Accreditation Bodies, Scheme Owners (UKAS, SMMT, IAQG …) and of course Government Sanctions.” Now, in reality, they aren’t doing that, but the reliance on vague, unnamed “instructions” makes it impossible to fully challenge her on the point.

No, this is something far worse than a spectrum disorder. At least those on the spectrum can point to a biological origin for the condition, and can seek treatment. The heartless cruelty of ISO scheme actors is elective. “Procedures” become a reality buffer, something which can put distance between the person’s emotions and real-world horror, while providing a seemingly rational justification for the one thing all bureaucrats seek: doing nothing.

Eichmann In All of Us

But how is this possible? People like Riva and Gillespie and Gantley are not victims of bureaucracy, they are normal people who learned to survive within them. To do that, they have developed the ability to temporarily toggle off portions of their brains that normal people use for making moral decisions.  Only through this ability can they succeed in the bureaucracy. Those that can’t operate such a toggle cannot succeed, or aren’t attracted to bureaucratic work in the first place.

In his essay “Bureaucracy as Violence”, Jonathan Weinberg quotes from David Graeber’s book, The Utopia of Rules:

“Bureaucratic knowledge is all about schematization”—it means “ignoring all the subtleties of real social existence and reducing everything to preconceived . . . formulae”. Bureaucrats apply “very simple preexisting templates to complex and often ambiguous situations”; they close their eyes to rich social reality, and confine their attention to a tiny, arbitrarily selected subset of the relevant facts.

Weinberg and Graeber are hardly alone in identifying bureaucracy’s ability to justify evil. David Impellizzeri wrote, in his 2019 thesis “Bureaucratic Modernity and the Erosion of Practical Reason“:

The rationalization of society and action in the (late) modern world requires that an increasing number of human activities and domains be explained in allegedly neutral, ‘rational’ terms and without reference to morally substantive ends. Ultimately, this entails a form of epistemic reductionism that elevates instrumental rationality to the exclusion of practical reason and probabilistic ways of knowing. Bureaucratic modernity signifies a decrease in choices that can be legitimized in public on some basis other than calculative-methodological-procedural thought.

Or, recall Hannah Arendt and the “Banality of Evil“:

Arendt found Eichmann an ordinary, rather bland, bureaucrat, who in her words, was ‘neither perverted nor sadistic’, but ‘terrifyingly normal’. He acted without any motive other than to diligently advance his career in the Nazi bureaucracy. Eichmann was not an amoral monster, [Arendt] concluded …. Instead, he performed evil deeds without evil intentions, a fact connected to his ‘thoughtlessness’, a disengagement from the reality of his evil acts. Eichmann ‘never realised what he was doing’ due to an ‘inability… to think from the standpoint of somebody else’. Lacking this particular cognitive ability, he ‘commit

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crimes under circumstances that made it well-nigh impossible for him to know or to feel that he [was] doing wrong’.

Arendt dubbed these collective characteristics of Eichmann ‘the banality of evil’: he was not inherently evil, but merely shallow and clueless, a ‘joiner’.

And so these people are simultaneously the product of the bureaucratic structure, and its creators. Imagine some sort of inverse ouroboros, where the snake vomits its own tail, becoming ever larger and larger.

None of this alleviates their culpability, mind you, but it does help explain it.

The Three Failures of Bureaucracies

There are many research papers written on the topic of bureaucracies, and how authority figures are often willing to surrender their humanity to serve their particular machine. The most famous is likely the Milgram Experiment, which has been heralded, debunked, and re-bunked more times than Bigfoot sightings. The Yale experiment purported to show people would surrender their morality when directed to do so by an authority figure; the intent was to understand “whether Germans were particularly obedient to authority figures as this was a common explanation for the Nazi killings in World War II.” Subjects were directed by a superior to apply an electrical shock to a victim, and did so with surprising regularity. Simply Psychology summed the results thusly:

Ordinary people are likely to follow orders given by an authority figure, even to the extent of killing an innocent human being.  Obedience to authority is ingrained in us all from the way we are brought up.

People tend to obey orders from other people if they recognize their authority as morally right and/or legally based. This response to legitimate authority is learned in a variety of situations, for example in the family, school, and workplace.

Dipping further into the pop psychology punchbowl, we’d likely find other possible explanations for this behavior: Stockholm Syndrome, cult programming, PTSD, abuse, imposter syndrome. Any number of these might explain reasons why supposedly reasonable, normal people would yield themselves to assisting in, or overlooking, horror.

A far better explanation can be found in a 2006 paper published in the International Journal of Public Sector Management, entitled “Bureaucracy, Meet Catastrophe: Analysis of Hurricane Katrina Relief Efforts and Their Implications for Emergency Response Governance,” by Margaret B. Takeda of Univ. Tennessee Chattanooga, and Marilyn M. Helms of Dalton State College (Georgia). In it, the researchers identified three “failures” exhibited by bureaucracies, which — in that case — had exasperated the Katrina disaster response. The three failures are identical, however, to what we see unfolding in the ISO certification scheme, crippling organizations from recognizing horror and continuing to act as if nothing is going on.

The first failure, the researchers report, is the fact that bureaucracies rely on “decentralized knowledge and centralized decision making” (emphasis added):

Bureaucratic management systems rely heavily  on  group  decision  making  because  roles are formalized and information is highly codified, creating a system  in  which people are “experts” in their limited role in the process. This creates a necessity for knowledge sharing via meetings and other communication tools. While this knowledge sharing helps to reduce uncertainty, it also requires large  amounts  of time  and effort.  The heavy reliance on knowledge sharing hinders the system’s ability to take swift and decisive action.

As we enter the second month of the Russian invasion of Ukraine, we can see how the bureaucracies weighing down the ISO certification scheme have crippled organizations’ ability to respond to events occurring in real time. For example, IAF Chair Riva insisted that the IAF could only act upon instructions of its members, and had to convene multiple meetings to even begin having a conversation about what the organization might do. Riva lost weeks, waiting to coordinate meetings with members from around the world.

ILAC hasn’t come out with any statement at all because of that organization’s inability to organize meetings populated by the necessary representatives. Other organizations, like the thousands of certification bodies around the world, are “awaiting instruction” from their ABs, who are equally crippled by the need to issue any decision through a formal, lengthy meeting process.

Rejecting External Information

The second failure is “ignoring ‘outside of the system’ information.” Here the authors may well have written their report in 2022, related to the ISO certification scheme bodies, rather than in 2006 for hurricane Katrina (emphasis added):

Bureaucratic management relies on the process of socialization, which refers to a system in which individuals acquire positive, affective, and evaluative orientations toward aspects of a system, while acquiring the necessary knowledge and skills to operate effectively within the system. In bureaucratic systems, socialization can lead to a high level of understanding of the system, which in turn causes individuals to adhere to the system’s “local” framework of norms, values, and assumptions. Because socialization facilitates a commitment to the system it can lead to an inability to properly consider relevant outside information when facing an  unusual  event.  This inability to properly consider relevant outside information consists not only of a reluctance to analyze outside information, but also includes a disdain for accepting assistance from actors outside of the system and an aversion to using activities which are not already part of the system.

Repeatedly, Oxebridge and others have not only implored ISO, ILAC, IAF and others to take action, we provided roadmaps on how to do so. I personally provided Gillespie a roadmap on how ANAB could navigate the sanctions while ensuring ANAB retain its reputation; she ignored that entirely. IAF likewise ignored advice provided to them, while other bodies appeared outright contemptuous. Those that responded appeared irked that someone “outside their system” had even contacted them in the first place.

For the decade-plus we’ve been running the ISO Whistleblower Reporting system, this has also been the case. ISO, CASCO, IAF, the regional bodies, ANAB and others routinely claim they cannot even accept outside information, as everything must come through committee. Charles Corrie, the BSI staffer and Secretary for ISO/TC 176, has become so famous for rejecting outside information, his stock reply (“ISO can only accept input from members and their appointed delegates“) that it’s now known as “The Corrie Effect.”

Of course, it’s a convenient dodge. ISO and their ilk accept input from friendly sources, like Sheronda Jeffries or Nigel Croft, regardless of whether they are providing that feedback as an official delegate of a given committee or member nation. Feedback that supports existing dogma is seen as “inside the system” information, and so is accepted with open arms; but even the mildest criticism is viewed as “outside the system” information, and rejected wholesale.

But for career, mid-level bureaucrats like Mujica at ISO, Gillespie at ANAB, Gantley at UKAS, or Riva at IAF, “inside the system” information is all they know. They can only operate when they have such information already fed to them, developed by someone else. And that “someone else” is always a committee of other bureaucrats who are merely processing more “inside the system” information, so innovative thinking can never truly enter the system. Those who thrive in bureaucracies only do so when developing an allergy to both criticism and external information, and then “role fixation” — as we will see below — hard-codes this into their belief system. Surrounded only by fellow bureaucrats who think the way they do, they reward each other for this dysfunction, never realizing it is a dysfunction.

But here’s a hint: if you’re justifying why you are supporting international war crimes and humanitarian abuse, you are dysfunctional.

Role Fixation 

Per Takeda and Helms, the final bureaucratic systemic failure is “escalation of commitment to failing courses of action.” This condition essentially explains how bureaucracies can continue to do the wrong thing, despite all outside evidence proving they are horribly, horribly wrong. (It’s also worth pointing out that in the original paper, the researchers relied on information from the book Kaizen by Kaoru Ishikawa.) Emphasis added:

The bureaucratic knowledge and information sharing structure engenders a high degree of commitment by organization members whose identity is synonymous to their role in the  organization. The roles are bound together by a codified system of decision-making. These roles have the potential to hinder the system’s ability to identify and to react appropriately when the system is following a failing course-of-action. Because people are so committed to their role (“role fixation”), even in a failing course of action, their commitment may escalate. This commitment may produce a loyalty that is considered “extreme”, resulting in behaviors designed to perpetuate the role (thus, the system) and not necessarily rational or functional given the circumstances facing the individual.

In short, bureaucrats like Gillespie and Riva and Nilsen have allowed their original personalities to be subsumed by their title and position. This is largely explained by the fact that, in most cases, these positions are the highest possible professional level they could possibly achieve.  The world’s most successful people are never bureaucrats, but instead are those working to break bureaucracies. They are creative thinkers, risk-takers, daredevils, or simple, quiet hard-workers. Bureaucrats are none of these things, and the bulk will languish in basement offices, disrespected and forgotten, until they retire or die. Occasionally, lightning strikes even for them, however, and they land a role on a standards committee or in the executive suite of a bureaucratic agency.

The Alan Daniels and Tim Lees and Nigel Crofts of the world know that they will never get another chance at having influence, and that it was dumb luck that won them it in the first place, so aren’t about to muck it up. Secretly, they know this is the pinnacle of their career, and — after having been disrespected for so long — the pendulum swings far to the other side, and they become flush with their own sense of accomplishment. To anyone on the outside, they are just dull bureaucrats doing dull bureaucratic things. But to themselves, they are rockstars.

And then they give themselves awards to reinforce this insecurity avoidance behavior.

Circular Firing Squads

There’s another angle, still. A 1989 paper entitled “The Hijacking of TWA 847: A Study of Bureaucratic Paralysis,” written by Whitley Bruner for the US National War College, describes how competing bureaucracies hindered a proper emergency response.

By [mid-1980s], the CT [counterterrorism] arena was becoming cluttered with competing organizational claimants to supremacy. In view of  President Reagan’s well-known disinclination to choose between bureaucratic rivals, little was done to clarify or to resolve a potentially dangerous situation.

On the one hand, the State Department insisted that, as the agency responsible for the formulation of foreign policy, it should assume the leading role in any terrorist incident. The CIA, on the other hand, argued that countering terrorists depended primarily upon sensitive human-source reporting, both for preemption and for reaction, and that sources and methods needed to be protected, something the State Department could not guarantee. Further, most technical CT countermeasures were under CIA control. Liaison with foreign intelligence services, whether at the site of a terrorist incident or for background insights into the terrorist group involved, was also a CIA prerogative. The CIA thus pushed, if not for supremacy in CT matters, at least for a significant degree of autonomy, outside State Department control.

While within the ISO scheme there may not be a competitive struggle for supremacy, the opposite is true: one bureaucracy will inevitably suggest that a different bureaucracy must make a decision. We need only look at the case of URS: that company justified its own inaction by pointing responsibility at UKAS, saying they were awaiting their guidance. Meanwhile, UKAS has instead put the onus back on the CBs to comply, while issuing no such guidance at all. With both parties pointing the finger at each other, neither is taking concrete action (while both continue to profit from their relationships with Russia.)

We see this all the time as ISO points to IAF, IAF points to ABs, ABs point back to CASCO, and CASCO points back to ISO. Again, this is a classic bureaucratic dodge that enables the bureaucrats to engage in their true passion, getting paid for doing nothing at all.

Solutions

As always, I try to provide solutions to difficult problems, and not just point them out. In this case, it’s a complex, cultural problem that transcends the ISO certification industry. But the ISO scheme is not a government, it is not a national culture, and is run by private organizations led by a tiny handful of individuals. That makes the elephant much easier to eat.

The main thing that bodies like ISO, IAF and ANAB can do is remind themselves of this. They are not held to voters or shareholders. They can create and enforce rules governing the use of their marks, logos, certificates and name as they see fit. There’s literally nothing stopping them.

To that end, the bodies can avoid the bureaucratic tendency to demand a formal “policy” be produced to address a given crisis, and only then after a year-long process involving meetings of every possible stakeholder. Inviting varying opinions on a clearly one-sided moral issue like plague, invasion, or human trafficking only raises the possibility that very bad people will bring very bad advice to the table, and drown out weak-minded thinkers.

Instead, the bodies can institute immediate policies based on basic moral principles, and tell their members and followers to play along, or leave. I’ve examined the bylaws and association rules governing each of the bodies, and such an approach literally does not violate any such ruleset. They have the freedom to do this, right now.

But this must come with a second realization: the bodies must understand that there is little downside to doing so. Both IAF and ANAB are US-based companies, and terrified of litigation. (IAF has no in-house legal counsel, and relies on legal advice provided by ANAB, which it then borrows from “free” sources. That ensures they always get bad advice.) The risk is overblown. Would Russian Register really hire a US law firm to sue them in Wisconsin or Delaware? Are they going to spend money sending their executives from Moscow to the US to attend a trial? Would they want to undergo a discovery phase that might expose their records to even more of a spotlight? All while under oath? Hardly.

In truth, if ANAB or IAF were to invoke a “No Russia” policy tomorrow, there’s be nothing anyone could do about it. The only option left to pro-Putin hardliners would be to quit ANAB. In such cases, ANAB could politely — but publicly — list those certification bodies who abandoned ANAB because of its moral position, thus shaming the quitters. And, let’s face it, who would leave? Russian Register? Who cares?

The IAF even has more power. It’s not like there is some other global accreditation oversight body with exclusive deals with the nations’ governments worldwide. The only choice would be for an accreditation body to quit IAF altogether, and join the ranks of the certificate mills. Good luck with that.

ISO has even more power still. What nation would leave ISO if it decided to stop selling standards in Russia? Well, Russia might, but does ISO really want Russia running the show? What does it gain from that?

Some of the bodies have done this already. The accreditation body IAS led the field with an aggressive, public policy that saw it drop all activities in the region, without asking anyone’s permission. And they did so knowing that a huge number of their clients and auditors are Indians, and that India has been supportive of Russia to date. IAS showed both guts and leadership, and took the moral high ground. And, guess what? They didn’t go out of business the next day. If anything, they helped improve their reputation with the stroke of a pen.

And UKAS? Come on now…. they have a monopoly granted by the UK crown, for heaven’s sake. Literally, nothing bad can happen to them.

But to do either of these things requires the individuals to overcome their “three failures” and put ethics and morality ahead of their personal desire to succeed within the bureaucracy. they would have to show leadership and courage, two features that bureaucrats are not known for.

But it’s possible, indeed.

Until then, these organizations and the individuals managing them have blood on their hands. We need to be honest and tell them that, in the hopes that we can shake them from their sleepwalking, bureaucratic stupor, and welcome them back into the ranks of functioning human beings.