ethicsAccredited Certification Bodies (CBs) rank highest in Google searches related to QMS consultation and implementation, despite rules prohibiting registrars from offering such services.

By searching using terms such as “ISO 9001 implementation” or “ISO 9001 help“, first page Google results include hits primarily from BSI, which is now the subject of a high-level complaint filed with the International Accreditation Forum. BSI has been investigated multiple times for breaking the firewall between consulting and certification, and each time their associated Accreditation Body — ANAB in the US and UKAS in the United Kingdom — found no violations.  In the past decade, BSI’s “implementation” work — which, Oxebridge argues, clearly breaches the line into consulting and documentation preparation — has increased, not decreased, despite the complaints.

Other accredited CBs whose pages show up in such searches include LRQA, NSAI, ACS Registrars, SAI Global and NQA-USA.

Some of the results are not directly linked to a registrar, but instead have hidden connections. One result resolves to an official ISO document on implementation of ISO 9001:2008 published by ISO TC/SC2, which is chaired by Charles Corrie of BSI. One of the only “independent” consulting firms that appears in the search results, Overman & Associates, includes a link to BSI on its page.

For ISO 9001, the word “consulting” does not appear to be used by the CBs, but for related management system standards, this is not the case. BSI appears in the first page results of a search of “ISO 13485 consulting“, and represents the top two hits on Google for “ISO TS 16949 consulting.”

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BSI also wins the first two results in a search for “AS9100 implementation,” with registrar SAI Global in the 9th position. BSI has the first two entries for “ISO 14000 Implementation” as well.

For ISO 22000, the food safety standard, the results are different. A search for “ISO 22000 consulting” results in first-page hits from Intertek, NQA-USA and Bureau Veritas, and no results at all from BSI.

Multiple Revenue Streams

Accreditation rules prohibit CBs from offering consulting, in the form of providing “specific solutions” or preparation of documentation.  ISO 17021 specifically defines management system consultancy as “participation in designing, implementing or maintaining a management system.” Nevertheless, CBs have pursued consulting work because while certification offers long-term revenue derived from ongoing certification fees, consulting provides a “quick hit”, high value initial payment, often three times the fee for first year certification services. By offering both, CBs can dramatically increase their profits.

Accreditation Bodies such as ANAB and UKAS derive their funding from fees paid by their CBs, thus creating a conflict of interest whereby it is against their interests to enforce the rules; de-accrediting a CB would result in an immediate drop in AB revenue. By some calculations, a single CB client may represent up to 10% of a given AB’s annual revenue.

In order to get around rules prohibiting consulting, CBs avoid words that are specifically prohibited.  In the case of BSI, they provide documents branded as “training modules” to avoid the term “documented procedures.” UKAS has assessed and approved this approach, even though the resulting documents meet the definition of a “documented procedure.”

BSI procedure for control of nonconforming product is branded as a "Training Module," not as a documented procedure. UKAS has ruled that such "templates" are acceptable, even though they are identical to offerings by consultants.

BSI-provided procedure for control of nonconforming product is branded as a “Training Module,” not as a documented procedure. UKAS has ruled that such “templates” are acceptable, even though they are identical to offerings by consultants.

The site for registrar SAI Global’s consulting services openly declares that it will create “develop, approve and implement”  management system documentation. Nothing on the page indicates that SAI Global cannot certify the results of its consulting offering.

Consultants as “Business Partners”

Accreditation bodies including ANAB, InMetro, SCC and UKAS have adopted a “blind eye” approach when dealing with accredited CBs that partner with specific consultants in exchange for referrals. Such programs include those of registrars such as NQA-USA, EAGLE and BSI. Typically, a consultant can receive a favorable listing from the registrar in exchange for delivering clients to the CB.

The practice is also prohibited under ISO 17021, but is not enforced.

Showdown Looming

The issue is likely to be raised in court, where the distinctions between definitions will be tested. The practices may well be illegal under UK law, while US law appears to be silent on the subject. But failures by ANAB to enforce ISO 17021 are being explored as a potential violation of Federal Trade Commission antitrust rules, and separately as attempts to defraud the Federal government, since ANAB-accredited certification is frequently included in government contracts. Oxebridge is beginning to push the Government Accountability Office (GAO) to have ISO 9001 removed from all US contracts until the problems are corrected, on the basis that requiring ANAB accreditation may represent a violation of Federal Acquisition Rules. Similar conversations are being held with the US General Services Administration (GSA) and NASA. Oxebridge is petitioning the US Congressional Committee on Science Space and Technology to testify on the failings and to push for improved oversight by ANSI.

Other industries have long since banned the practice of allowing auditors to simultaneously provide consulting. The Enron scandal of 2001 was largely the result of consulting by Arthur Andersen auditors, an activity branded as “reckless.” Enron shareholders lost $74 billion in the aftermath of the financial disaster, and thousands of people lost their jobs.

Various states’ Departments of Transportation have similar prohibitions against inspectors also having worked as consultants on projects for which they are bidding or inspecting.

During a recent AS9100 audit witnessed by Oxebridge, an auditor with NSF-ISR openly declared “the age of auditors being prohibited from consulting is over.”