(Update: BSI has responded, click here.)
Lima PERU — Oxebridge Quality Resources International has filed a 15-page complaint against BSI’s UK office, alleging widespread and systemic conflicts of interest in its ISO 9001 and related management system conformity assessment services. Oxebridge has not ruled out a similar complaint for BSI’s US office.
While Oxebridge alleges multiple violations of at least seven clauses of ISO 17021:2011 — the standard under which BSI is accredited to provide conformity assessment services — the primary requirement in question is regarding the separation of consulting and certification services.
5.2.5 The certification body and any part of the same legal entity shall not offer or provide management system consultancy.
ISO 17021 defines “management system consultancy” as:
“Participation in designing, implementing or maintaining a management system.”
a) preparing or producing manuals or procedures, and
b) giving specific advice, instructions or solutions towards the development and implementation of a management system.
At the heart of the complaint is evidence that BSI provided certification clients with consulting services in the form of its Entropy™ software product, which BSI markets as an implementation tool, used to develop and maintain management systems such as those for ISO 9001, ISO 14001 and OHSAS 18001. Oxebridge asserts that the software, and related consulting by its developers, provide tools and specific methods for key management system requirements, such as document control, record control, management review, process measurement, internal auditing and corrective/preventive action.
Furthermore, it is apparent that BSI has certified users of its software. On its webpage, BSI presents multiple “case studies” for BSI Entropy™ software users. These include two clients for which BSI later provided certification services: Tra Tek and Web Industries. If correct, this means that BSI auditors certified management systems developed by BSI.
The BSI Entropy™ page clearly links certification with the usage of the software. On one page it includes two graphics, the first of which discusses how Entropy is used “to support certification”:
Beneath that, a graphic announces that the software “has helped BSI clients reduce… implementation time,” among other benefits.
This particular graphic is damning because ISO 17021 clause 5.2.9 prohibits a certification body (CB) from making any claims that a specific consulting service would result in certification being “simpler, easier, faster or less expensive.” The graphic, and other marketing statements by BSI, appear to violate three of those four requirements.
BSI also makes it clear that it is willing to certify systems which use the BSI Entropy™ software, and that they are not prohibited from doing so. On one page, BSI says it offers tools for companies “ready to work towards certification with us” (emphasis added) and then provides information on Entropy™ implementation software as one of its products.
Beyond the concerns with Entropy™, Oxebridge points out multiple instances where BSI is jointly marketing its consulting services with its certification services.
On one BSI page, the company links certification and implementation by saying “we’ll support you ever step of the way as you implement a standard all the way to certification.”
What Are They?
A way to give you all the quality certification help and guidance you need in one place. We developed the new range of toolkits using key products within the ISO 9001 portfolio to help customers considering implementing ISO 9001 into their organisation.
Making decisions about quality management is a big but important commitment. And that’s why our new range of toolkits lets you select a number of specific products without having to buy each one separately. Plus it’s an easy way to group all the tools you need together and support you wherever you are on the journey towards certification.
Our ISO 9001 toolkits bring together assessment services, standards and publications, training and an online tool. These are tailored to your organization to help your quality management systems, knowledge and competency through training and experience increased productivity and performance.
The “BSI ISO 9001 Self-Assessment and Project Planning Tool” overtly advertises that it can be used for ISO 9001 “implementation” (emphasis added):
This online system will help you set up your QMS, track progress and define responsibilities. With access to expert guidance, BSI Quality Management Self-assessment will help organizations implement ISO 9001 and monitor their compliance with its requirements.
This is the second time Oxebridge has filed a complaint against BSI for cross-marketing its training or consulting services with its certification services. In 2003, Oxebridge revealed that BSI’s then-Senior VP of Marketing & Sales, Ronald D. Mathis, had sent a letter to certification clients offering a discount for training services which appeared to breach the line into consulting. Mr. Mathis at first threatened Oxebridge with a lawsuit for using his name in its reporting, and in a later phone call made a physical threat to Oxebridge VP Operations Christopher Paris. Mr Mathis was removed from BSI for unspecified reasons shortly thereafter.
Oxebridge has filed similar complaints against UL and other certification bodies, with mixed results. “Generally, we haven’t had good luck in getting resolution to complaints of CBs also provide consulting,” Paris said. “The allowances by the accreditation bodies, such as ANAB and UKAS, are incredibly lax, and nearly always default onthe side of the CB, rather than the side of users, or that of maintaining the integrity of conformity assessment certifications.”
Paris thinks this time will be different. “To me, it’s a slam-dunk. It’s clear that BSI is certifying quality systems of its own making, and intentionally blurring the lines between its consulting and certification offerings. We’ll see what happens, but I fully expect this to land in front of UKAS and, perhaps, ANAB.”
Paris, and Oxebridge, have argued for a strict firewall between consultants and certification bodies, to comply with the requirements that certifications be issued without conflicts of interest. “It’s ridiculous to think a BSI auditor would write a finding against BSI software, and risk an impact on the revenue of software sales. It’s also ridiculous to assume that BSI would not audit other, non-BSI software with more scrutiny, if only because it’s less familiar.”
ISO 17021 prohibits “familiarity” from being a factor in a QMS auditor’s decisions; it also specifically calls out “financial pressures” as a potential conflict of interest.
“We, as consultants, cannot issue certifications; BSI should not be allowed to be in the consulting business,” Paris says.
A copy of the full complaint maybe downloaded here. (PDF – 850 kb.)
Graphics credits: screenshots taken from various BSI websites, and used under Fair Use allowance for the purposes of reporting. Lead graphic (c) Oxebridge.