Annex SL is ISO’s power-grab which strips away the ability of ISO member nations and subject matter experts to draft ISO standards, and hands that power back to the ISO headquarters through its Technical Management Board (TMB). Any ISO member committee that is OK with this arrangement has utterly abdicated its responsibility.

The TMB developed Annex SL, obscuring its role only somewhat by assigning the drafting work to a “Joint Technical Coordination Group” (JTCG). The JTCG is an ad hoc group of ISO apologists with just enough international participation to make it appear that ISO was following its rules, but the committee is not an official representative body, and has no voting power anyway. The JTCG works simply to carry out the TMB’s mandate, while giving it some political cover.

Annex SL imposes mandatory content in ISO’s management system standards, without the participation or voting of member nations. That’s a violation of both ISO’s own rules as well as those of the World Trade Organization’s Technical Barriers to Trade (TBT) regulations, which insist standards are supposed to be written by experts and internationally appointed delegates.

As a result, a massive 30% of ISO 9001:2015’s text was not written by TC 176, but by the TMB. Think about that: almost a third of ISO’s flagship standard was not written by industry experts or representative delegates of the world. In fact, we don’t actually know who wrote it, because the TMB isn’t required to tell anyone anything.

Making matters worse, the leadership of TC 176 then forcibly rejected 100% of all worldwide comments on the Annex SL portions of ISO 9001:2015, claiming it was untouchable per ISO dictate. So the only slightly more than two-thirds of ISO 9001 was subject to actual voting. ISO never says this, though, in their marketing.

Now ISO is revising Annex SL, presumably after seething user criticism of it, despite how this will dramatically impact all the standards recently released based on its first draft. When the revision is released, all those standards — including ISO 9001:2015 — will be instantly out of sync. ISO doesn’t care. It gotta eat.

Internal emails now show that key US TAG 176 representatives have been given only seven days to provide their suggestions on how to revise Annex SL, and even that come with certain guardrails put up by — well, someone. My sources were given official guidelines on what could and could not be changed, but no one knows who drafted them, and (as I said) ISO doesn’t have to tell you.

Seven days! This assures low participation in the commenting activity, but still allows ISO to cynically claim, later, that “Annex SL was the product of stakeholder feedback!” It’s absolute and total bullshit, however.

Furthermore, the “commenting” is just symbolic. ISO member nations don’t have voting approval authority over Annex SL, since it’s not a standard. Instead, it’s published literally as an “annex” inside an obscure ISO operating procedure that must be followed by the various Technical Committees. Nations don’t vote on ISO’s internal procedures, obviously, so they don’t vote on Annex SL either.

There may be a symbolic vote later, but smart readers know the difference between a symbolic vote and a real one. The leaders of Cuba and North Korea have symbolic votes all the time, and we see how well that works out.

What we do know is that the architects of this move are now wrestling with Annex SL’s bungling of “risk.” Likely led by the same folks who came up with “risk-based thinking,” which is proving to be a nightmare during audits, rather than blame themselves, they now seek to blame Annex SL. They’re partly right, but only partly.

They are also trying to resolve the conundrum of the bat-crazy concept of “positive risk,” an unforced error that ISO finds itself in because it took the opinoin of a single risk expert — Kevin Knight of Australia — over, say, the dictionary. Knight, meanwhile, is still shilling for that organization whose founder pretended to be a woman online to “catfish’ men into their unaccredited training courses; so Knight’s practical application of risk management goes something like, “Is there a microphone or a camera? OK, I’m in!”

I’ve alerted the current TAG leadership, Chair Paul Palmes and former Chair Alka Jarvis, that the US must reject Annex SL outright, and TC 176 must reclaim its sole role as developers of content for ISO 9001. They must tell the TMB that they will not continue to abide by its power grab. I also told Palmes that giving people only seven days to comment reveals the entire thing is a sham, and doesn’t help the TAG’s already tattered reputation.

In the mean time, feel free to tell the TMB what you think of Annex SL, and call for its full and total withdrawal. Write to Sophie Clivio at TMB and Nigel Croft, who’s heading up the Annex SL revision process. Expecting your national member body to carry your views won’t work this time, as they are likely complicit in this mess.



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    About Christopher Paris

    Christopher Paris is the founder and VP Operations of Oxebridge. He has over 30 years' experience implementing ISO 9001 and AS9100 systems, and is a vocal advocate for the development and use of standards from the point of view of actual users. He is the author of Surviving ISO 9001:2015. He reviews wines for the irreverent wine blog, Winepisser.