The International Organization for Standardization is subject to the World Trade Organization’s “Agreement on Technical Barriers to Trade” (TBT), a legally binding international agreement that dictates voluntary standards must be developed on the principles of openness, consensus, transparency and efficiency. ISO alleges to comply with TBT, and to date the WTO agrees; if that changes, the WTO would sanction ISO and its standards would be seen as violations of international trade law. Typically such disputes are made against nations, not international organizations, so it’s interesting to think how the WTO would enforce the regulations on ISO; but we may find out soon enough.
There are multiple — and seemingly endless — examples of ISO processes, policies, and practices that show it hasn’t remained in compliance with TBT, and is probably overdue for international sanctions. The shift of responsibility of standards development to the non-elected Technical Management Board is one such move. But the problem exhibits itself in other ways, too.
For ISO 9001, ISO’s Technical Committee 176 alleges to provide “official interpretations” of clauses in 9001 when requested by stakeholders or the public. According to the official TC 176 site on the matter:
ISO/TC 176/SC2 provides a service to give formal interpretations of ISO 9001… The interpretations provided will only seek to clarify the principles behind identified requirements in the standard; they will not provide guidance on how the requirements should be applied to an organization’s particular situation.
Such requests must go through the appropriate national member body, which in the US would be the US Technical Advisory Group to TC 176, or “TAG”. The process presumes that the TAG forwards the request for interpretation to ISO’s TC 176, which then discusses the matter and develops a consensus interpretation. It then publishes the results in an updated document on official interpretations, which is also available to the public at that official ISO page.
There’s one wrinkle, though. TC 176 has effectively abandoned the activity, and stopped processing requests for interpretation in 2011. The downloadable “List of Formally Approved Interpretations” file shows that it was last edited in February 2011 by Charles Corrie, TC 176’s long-standing Secretary, and BSI functionary.
When questioned, TAG Administrator Jennifer Admussen seemed to imply there’s an updated list hidden behind some firewall, away from the public:
The [outdated] interpretations link you forwarded is on the public side, but the secure WG eCommittee site is active, so I’ll defer to [TC176’s] SC2 or WG22 to provide additional details.
Of course, no one at TC 176 SC2 or WG22 ever provided any feedback, and hasn’t for the past nine months. Even if correct, it would be a ridiculous situation: the point of official interpretations is to publish them for consumption by the public, not to maintain them behind an “ISO members only” secret site.
The question came up when, on July 5th 2014, I formally requested an interpretation on the ISO 9001 requirements for a quality policy. I submitted the request to US TAG leadership, which was acknowledged as received by Admussen. Then, nothing.
In January 2015, some seven months later, I sent a request for an update, and again received a reply from Admussen, hearing nothing from the TC 176 leadership.
I checked the ISO eCommittee site and your request for interpretation is currently being balloted and will close on January 30th, so you should expect to receive the results after it closes.
The Official Interpretations document remains untouched since January 2011, and there has been no notification of any ballot result, which should have occurred six weeks ago.
This is not new. Another request for interpretation submitted by me in 2005, regarding whether or not ISO 9001 mandates internal auditor qualifications, was never processed at all by TC 176. Here’s a screenshot, showing the official request form and its submission date:
The fact that Admussen was personally involved in an attempt to get a speaking engagement by me scuttled also raises questions on whether or not the various bureaucrats apply a political filter to the process, but the evidence would suggest they don’t process anyone’s requests. Still, these are the dangers when the US TAG engages in dirty politics to protect their hand-picked leaders; it raises suspicions that shouldn’t be there in the first place, and adds more fuel to the argument that ISO — and the US TAG — are violating WTO regulations.
Presumably ISO would have us believe the fantastic tale that it has received not a single request for interpretation from anyone in the world since 2011, and that the normal process for handling such issues takes between nine months (in the case of my latest request) to ten years (in the case of my 2005 request.) Obviously, that’s a bit much to fathom.
More likely, the TC 176 is not processing such requests, out of a combination of incompetence and paranoia. ISO has repeatedly made it clear that despite marketing language claiming an interest in consensus and openness, it’s internal policies and procedures stand in opposition of those principles. This latest issue with the request for interpretations is only one small example.
If you’ve submitted a request for interpretation to any ISO TC, and had it ignored, feel free to contact me. ISO’s violations of WTO regs are being reviewed by experts and international trade lawyers, and every little bit of evidence helps.