Nigel Croft’s ISO Coup Attempt

Nigel Croft just dropped a nuclear bomb in the middle of the ISO certification world, and it stands to affect every single user of ISO 9001 and all other “management system standards” (MSSs) published by ISO.

The super-short version is this: Croft is attempting nothing less than a coup, to seize control over every possible activity of ISO related to the development of ISO MSSs, stripping away power not only from the ISO technical committees that write standards, but from the ISO Technical Management Board (TMB) that had already begun to dismantle ISO’s procedures on consensus.

Bear with me, this is a complicated mess that requires us to pull out details from extraordinarily long, boring documents.

Annex SL Refresher

To understand any of this, you have to review recent history. (Skip this part if you already know about Annex SL.)

Previously, ISO standards were developed through a process that ensured consensus by ISO member nations and technical experts. Any given standard was to be written by subject matter experts formally delegated by countries of the world, and then voted on by ISO members before publication.  This process was codified by the World Trade Organization, which wrote rules for how ISO standards would be developed.

Technically, those WTO rules are still in place, but the WTO admitted it has no ability to enforce them. Furthermore, the ISO procedures dictating all of this are still in place, too, but have now been abandoned.

Now, ISO standards — and especially MSS publications like ISO 9001 — have “core text” written for them by the TMB. That core text, called “Annex SL,” is not written by technical experts or even subject matter experts, and represents generic text that may or may not be applicable to the subject of a given standard. The TMB hands the Annex SL text to every MSS technical committee and forces them to insert it. In the case of ISO 9001:2015, more than 1/3 of the text was Annex SL text, and not written by quality management experts or TC 176 members.

Originally, the HLS text was written up as Guide 83, but was abandoned at the draft stage after only 19 of 25 nations voted for it; over 140 nations never voted at all. ISO overcame that blockade by scrapping Guide 83 and releasing the rules as “Annex SL” of an internal ISO document called, informally, the “ISO Supplement,” which requires no international voting at all.

Now, the Annex SL text may not be edited, and votes on it are purely symbolic since changes cannot be made to it. All official comments related to any Annex SL text are discarded without review. This means, in a practical sense, that over a third of ISO 9001 was not written under the ISO/WTO rules for consensus, voting, subject matter expert review, etc.

The intent of this effort was, originally, to enable the TMB to dictate a common “high-level structure” (HLS) for ISO standards, meaning formatting and overall clause numbering conventions, etc. But quickly the TMB requested additional powers from the ISO Executive, to craft actual text of standards, and not be limited to only defining a style guide. ISO granted the TMB those powers, as a way to fast-track the sale of standards. When standards were developed by experts, this resulted in longer periods of debate, technical considerations, and more draft cycles. Now, with the TMB dictating text, the standards can be pushed onto the ISO webstore faster.

Back to the Present

With that out of the way, let’s see what Croft has gotten himself up to.

This month (May 2023), the ISO Joint Technical Coordination Group on MSS (JTCG), Chaired by Croft, issued three official deliverable reports. These are:

• N 717: TF 15 Final report to JTCG (May 3, 2023)
• N 1648: Recommendations from JTCG
• N 1649: Ballot on ISO DGuide 83 (E)

According to the first (N 717), in which Croft provides a historical summary, the JTCG was formed in “October 2021 to review the lessons learned with the implementation of Annex SL, and to make recommendations to the TMB for the future of ISO’s suite of MSS.” In this document, Croft admits his remit “was NOT to look at specific changes that might be needed to Annex SL or to The Harmonised Structure, but instead to consider the architecture and structure of the MSS portfolio as a whole and to make recommendations to address known and perceived issues.”

Keep that in mind, because Croft is about to completely ignore the “remit” he just reminded everyone of.

The N 717 document then highlights Croft’s ideas on how to fix various problems his task force uncovered, and it’s nothing less than a coup (emphasis mine):

However, the expanding landscape brings new challenges to which we need to respond, including…  stronger governance to avoid contradictions and inconsistencies between the advice contained in different documents produced by different committees, which frustrates users who expect ISO to provide a coherent self-consistent suite of documents.

It’s no surprise that an underqualified, self-promoting gadfly immediately leaned into fascism to solve his problems. That statement might have gotten buried, except that Croft then details his ideas for what “stronger governance” means, and quickly debunks that “remit” he claimed limited him.

For the problem of standards “proliferation,” Croft proposes the following:

• [At a standard’s] “proposal preparatory stage … TCs to provide JTCG with the basic proposal and establish liaison at the earliest stage.”
• “grant either JTCG or TMB/TF2 the right to reject/return a proposal if it is deemed unnecessary or unsuitable“
• “Provide member bodies with more information for approval ballot: JTCG to provide a summary of outstanding concerns and a preferred course of action with reasons.”

In these three initial proposals, Croft is attempting to insert his own JTCG group into the mix, allowing him to not only determine — over the input of actual technical experts, subject matter experts, and international delegates — whether a standard should move forward or not. Then, he will be empowered to arbitrarily reject the standard before any voting ever occurs. Finally, when voting must happen, the JTGC will be given astonishing power by being allowed to tell members how they should vote.

So while the TMB’s usurpation of power, stripping it away from actual Technical Committees and subject matter experts, was bad enough, now there is an internecine battle underway between the TMB and Croft’s JTCG. I’m told, however, that the TMB isn’t really fighting this, and they’ve already largely yielded, so Croft may get his way.

Things get much, much worse as we look at the other two deliverable reports.

Nukes Inbound

Document N 1648 discusses how the changes to Annex SL will be first circulated as ISO DGuide 83.  Now, this is, historically, a sideshow. Remember: when the original Guide 83 was first circulated with Annex SL, it was voted down, but Annex SL was implemented anyway. So this round of votes is likely to be just as pointless.

This N 1648 document then provides JTCG’s input on some related matters prior to having the members vote on the DGuide 83 “Annex SL” revisions. And here is where Croft drops his nuke (emphasis mine):

For TMB to require all ISO committees to issue an amendment of their (Type A) MSS within 1 year of the Appendix 2 revision, only to address the changes in the HS related to climate change. Committees may choose to include in their amendment the other changes in the HS that were included in the 2021 and subsequent versions of the Directives. The only exception is in case a revision is already underway and is scheduled for completion within 18 months of publication of the Appendix 2 revision, in which case an Amendment is not required.

This means that Croft is entirely stripping away the rights of Technical Committees to update standards when they feel it is necessary. He is arbitrarily violating the “5-year periodic review” period codified in ISO procedures. He would force ISO committees to update their standards outside the normal review cycle, just to add “climate change” so that Sergio Mujica has a shot at becoming the UN Secretary-General (and, presumably, so Croft can work on his staff. Heck, maybe Croft thinks he can twist his work at UNIDO into a credible candidacy for himself?)

Think of the consequences: users all around the world will be forced to absorb the costs of updating their documentation and systems to comply with the new standard, and then undergo costly (and worthless) “upgrade audits” by their certification bodies.

That single move will cost the world’s economies billions of dollars. Without any practical justification.

Croft wants to be sensitive, of course, and suggests that any such “amendments” be issued “free of charge” by ISO and other national standards bodies. But it’s not at all clear how that would work. Obviously, ISO cannot issue a new version of ISO 9001 for free, just because a single sentence was added (more on that below.) So would they just issue a one-page insert? And then users are responsible for knowing that the “latest” version of ISO 9001 is actually two documents? The core standard and the one-page addendum?

That’s confusing AF.

But let’s remember that ISO 9001:2008 was issued as an “amendment” and ISO most certainly did not issue that for free. It cost users about $150 to buy it, and they were then forced to update their systems or get major nonconformities — all for a document that ISO insisted had “no new requirements.” Croft is suggesting that “amendments” are different than full-blown revisions, but history shows us that (yet again) it is either wrong, or lying.

Regardless, we find that, finally, Croft has solved the final problem that TMB couldn’t tackle: what to do if Technical Committees followed procedures and asked the world if a given standard should — or should not — be updated. ISO only makes money when standards are updated, not when they sit unrevised for decades. As we saw with ISO 9001, the world voted nearly five times to maintain the 2015 version as-is, but ISO has pushed ahead to revise it anyway.

Croft — the same guy who came up with the term “risk-based thinking” and wrote the demonstrably false language that “risk has always been implicit in ISO 9001” — just cracked the case again. Now, it won’t matter what the world votes, since ISO will force a revision whenever Annex SL is updated. No votes, no consensus, no technical experts, no approval.

Just because “Dear Leader Croft” says so.

All This for One Single Sentence

As reported the other day, only one new “shall clause” will be added to address climate change. Within the final deliverable, document N 1649, ISO finally reveals how it intends on injecting “climate change” into ISO 9001 and all other management system standards. The following single sentence will be inserted into clause 4.1 “Understanding the Organization and its Context“:

The organization shall determine whether climate change is a relevant issue.

This will then be supported by one non-binding note in 4.2.

This is what I call a “non-required requirement.” These are statements inserted in the standard that contain the word “shall” — implying they are a requirement — but then contain a requirement that can be ignored if the reader so chooses.

And let’s face it: 100% of ISO 9001 users will decide that “climate change is not a relevant issue for our company,” just so they don’t have to worry about this clause. So it’s entirely meaningless.

Despite that, Croft intends on forcing a revision of ISO 9001 — and (again) every other ISO management system standard — just to add that one sentence. The cost, again, will be in the billions of dollars worldwide.

And remember that remit? Where Croft said his task force was “NOT to look at specific changes that might be needed to Annex SL”? Suddenly, Croft is doing exactly those things. His task force literally wrote the additional sentence in 4.1 and the note in 4.2. Look again at the image above. In it, Croft writes, “The TMB (through a dedicated Task Force in charge of implementing the TMB action plan) has
asked the JTCG to provide recommendations for the revision of the Harmonized Structure.”

Then, from the cover sheet (numbered N 77) to the N 1649 document:

That is the exact opposite of his stated remit. He is directly making and directing “specific changes to Annex SL,” and using his position to push them through.

Furthermore, Croft is usurping power away from Sergio Mujica himself! Mujica has stated over and over that only affected standards would be updated to address climate change — not all standards. Then, various ISO bodies have published official documents listing which of the ISO standards would be affected, and ISO 9001 is never listed as one of them.

Croft sees it otherwise. He wants them all updated, and to hell with any justification of whether something is on-topic or not. Clearly, “climate change” isn’t something a quality management system can tackle, and belongs in ISO 14001 for environmental management. But ISO won’t sell books, and CBs won’t sell audits, if they adopt that approach. So Croft, always a willing stooge for the CBs and ISO sales team, stepped up to throw the entire planet under the bus.

And let’s be very clear, here: Craft will be rewarded for this Faustian bargain he’s pushed on the planet. He’s ISO’s Golden Boy.

But for the rest of us, he will always be Public Enemy # 1, and the costs you will be facing related to this gross violation of ISO principles won’t be reimbursed by Nigel Croft.

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UPDATE 16 May 2023: ISO appears to be panicking over this post, as Sally Swingewood — the former BSI rep who took a job recently at ISO itself and now acts as Technical Program Manager — just posted a rebuttal to this article on LinkedIn. See here.

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UPDATE 18 May 2023. The original version of this said the first vote for ISO Guide 83 failed; in fact, it passed but only with the support of 19 out of 25 nations. I updated the article accordingly.