by Christopher Paris
ISO 10002 provides guidance on the processing of customer feedback and complaints. It’s a worthwhile standard, and if applied properly can dramatically improve an organization of any stripe. The standard really hits home the importance of seeking out such feedback, even when it’s “negative”:
The information obtained through the complaints-handling process can lead to improvements in products and processes and, where the complaints are properly handled, can improve the reputation of the organization.
The handling of complaints … can enhance customer satisfaction. Encouraging customer feedback, including complaints if customers are not satisfied, can offer opportunities to maintain or enhance customer loyalty and approval, and improve domestic and international competitiveness.
When I read this, I am reminded of what got me so excited about working with ISO standards over two decades ago. I recognized what such standards were saying as common sense, but I knew such concepts needed to be written down and published in order to have them universally accepted. I saw these as a real tool that would improve companies, which would result in economic growth for the companies themselves, for their local economies, and even for their employees. There is no downside.
The authors of ISO 9001:2000 understood this, in theory anyway. By attempting to embed the 8 Management Principles, which include “customer focus”, “involvement of people” and “continual improvement”, they set the framework for quality systems which would rely on feedback — sometimes negative — to drive improvement. These principles have since propagated into not only end user standards like ISO 9001 and AS9100, but the standards governing Certification Bodies, Accreditation Bodies and training organizations as well.
Some reject this notion, however. The irony is that those ignoring the wisdom of ISO 10002 are the very organizations and persons responsible for ensuring the reputation and worldwide acceptance of ISO management system standards: the certification/accreditation bodies, consultants and trainers. For the CB’s, AB’s and trainers, they are almost all governed by accreditation standards that require proper complaints handling, usually in line with ISO 10002.
And, of course, these are the same bodies policing everyone else, insisting they obtain feedback to pursue continual improvement.
Worse than ignoring the importance of negative feedback, they go to great lengths to discourage it through the creation of roadblocks that run counter to their marketing spin, among other techniques.
Human Nature
We have a tendency to reject criticism in the United States. We see it as an affront to our security, and despite a lot of talk of Asian cultures (China, Japan) being obsessed with “saving face,” Americans take this far more seriously. Foreign policy, economics and lawmaking are routinely governed not by what will best serve the public or the world, but by what will have the least impact on reputation or power.
It’s no surprise then that the microverse of QMS certification should be the same. But it is nevertheless frustrating, and worth shining a light on, in the hopes that certification users will say “Enough!” and push back. Change on the national geopolitical scale is tough, but getting QMS certification players to change is very, very doable.
But first the various players need to own up to the problem, acknowledge they don’t actually have all the authority they think they do, and then end their imagined power trip.
Certification Bodies
Registrars, or “certification bodies”, are some of the worst offenders. This won’t come as much surprise to ISO 9001 or AS9100 end users, but the statement will nevertheless result in looks of shock and raised eyebrows by CB representatives. Whether those reactions are practiced and insincere, or really the result of total ignorance, is irrelevant. It’s telling.
In 2003, Oxebridge filed a complaint against the powerful registrar BSI, alleging that its Senior VP for Marketing had violated accreditation rules when he sent a letter to ISO 9001 certified clients offering a discount for BSI training services. The complaint was written in a courteous manner, and cited exact requirements which Oxebridge felt BSI was in violation of.
Rather than accept this “feedback” as an opportunity to reduce risk to its accreditation, and just “tweak” its marketing language a bit to comply, the BSI VP threatened a lawsuit, and then called me personally and threatened to “bury me” — physically! Needless to say, a short while later he was no longer employed by BSI, and (yes) the company revised their marketing approach.
Intertek threatened legal action after four years’ of Oxebridge client data showed their satisfaction ratings to be lower than NSF. Perry Johnson Registrars lawyers threatened Oxebridge after we ran articles on the market confusion caused by the various “PJ” consulting and auditing companies, all of which have nearly identical names.
After their “Six Sigma Black Belt” contacted me for “improvement opportunities”, registrar UL reacted angrily to the resulting feedback (again, regarding blending of marketing language regarding auditing and consulting) and put Oxebridge on a “blacklist”, refusing to accept any new clients referred to it from us. UL later adjusted its website language anyway, but cut itself off from a free source of referrals — purely out of spite.
SGS North American Accreditation Manager Zachary Pivarnik left an angry voice mail on the Oxebridge phone system after we challenged one of their auditors findings, calling the complaint “an inquisition” even though the organization eventually agreed that the finding was without merit.
In November of 2010, I alerted Smithers Quality Assessments that their newsletter had implied (in one part) that an active upgrade from ISO 9001:2000 to 9001:2008 was required by clients, and elsewhere had the correct language that the transition was automatic. In the email I specifically indicated that this wasn’t a formal complaint, just a friendly heads-up. Regardless, Smithers’ VP Jeanette Preston spent part of an evening attempting to recall an internal email — which she had accidentally cc’d me on — where she called either Oxebridge or the complaint “a piece of work”. Realizing we are no longer in an era where you can recall emails, she later explained the phrase away, saying she was “giving a compliment for questioning our newsletter.”
(Making the situation more ironic is the fact that Ms. Preston is the Director & Chair of the IAAR Membership and Bylaws Committee.)
Trainers
Training organizations, who are also subject to their own international accreditation standards requiring proper processing of feedback, are not immune from this arrogance.
In 2005, Oxebridge questioned whether the newly formed RABQSA auditor training organization could give automatic qualification to ASQ-certified quality auditors, since their accreditation rules required a documented “crosswalk” justification to validate such an arrangement, and ensure there was no conflict of interest. RABQSA CEO Michael Carmody angrily rejected the complaint entirely, and refused to take any action, although later the crosswalk document appeared anyway. (More on Mr. Carmody’s textbook-bad response in Part 2: Choking Dissent.)
Recently, AS9100 auditor training organization Plexus International fell in the spotlight when a class attendee claimed one of their trainers was advising students that AS auditors had the right to have clients complete certain paperwork for them. A Plexus trainer responded by denying the situation ever happened, citing an interview with the trainer herself and feedback from other unnamed attendees. When Oxebridge pointed out that another attendee at a different even entirely reported the same thing, from the same trainer, Plexus again denied the action, resulting in an escalation by Powell to the point of accusing Oxebridge of “libelous” action for failing to name our clients, and demanding retraction. (That’s not happening, and we take the false accusation of libel pretty serious.)
Accreditation Bodies
The “demi-gods” of the certification world, Accreditation Bodies (AB) oversee the registrars and training organizations. After the 2005 RABQSA / ASQ incident, Oxebridge filed a formal complaint with JAS-ANZ, pointing out that Michael Carmody was prohibited, under accreditation rules, from processing any complaint form a third party in which he was named as part of the issue. JAS-ANZ never responded to the complaint, never formally acknowledged it, and refused all attempts to address the matter.
As recently as yesterday the Americas Aerospace Quality Group, which (alongside the IAQG) is responsible for the deployment of AS9100 related standards activities, deleted a conversation thread on LinkedIn, which showed documented proof of multiple registrars failing to audit in accordance with AS9101D requirements. AAQG and Cessna rep William Blake wrote that users must only “utilize the OASIS feedback process to address any specific issues. Attempting to address them here WILL NOT drive change.”
It’s worth comparing Mr. Blake’s actions with the Management Principle of “involvement of people” which includes:
- People freely sharing knowledge and experience.
- People openly discussing problems and issues.
Consultants & Clients
Other consultants are a part of the problem. Because I am not a consumer of consulting services (being a consultant myself), and because I risk “bashing the competition,” I typically steer clear of any direct conflict with the other guys. I always say, there’s plenty of work to go around, and there’s no reason consultants should be bickering amongst each other.
But Oxebridge’s efforts are roundly derided by other consulting firms, and I speculate it’s probably because we are so successful. That’s not to say that they aren’t successful either, but if Oxebridge was a no-name outfit, we’d never be discussed at all.
The first release of this article included a link to a site where people could go and complain about Oxebridge, because I felt that was fair. The site owner inexplicably labeled it a “smear” (it was just a link!) and threatened a lawsuit within 48 hours of the story going live, demanding the link be removed. I removed it. 1 day later, he recanted, deciding that his site needed the hits after all (I am not putting it back up), but he included this telling bit in his email:
Looks as though Mr. Paris has too much time on his hands these days, to be dishing this kind of fluff to the public when he should be giving more pointed technical value-added help directly to contracted customers.
Although I am pretty sure this came from a very specific CB rep, the fact that another consultant would agree that defending clients is “dishing fluff” and NOT as “value-added help” is demonstrative. They’re all in bed, and people in bed are typically not working. Unless lying in bed is their work.
Either way, the criticism is strange, because it requires consultants to side with the CBs and their auditors — the very same people who are behaving so badly to their clients.
My question to these consultants (and it’s something for their clients to ask them, as well): why aren’t you fighting for your clients? Why wouldn’t you try to help your clients by making sure they get fair audits?
Likewise, clients share a lot of the blame. In following the myth that placating CB auditors will result in an “easier” QMS audit and certification, some company representatives go beyond merely keeping quiet during the actual audit, and instead vociferously defend the actions of CBs and ABs across the board, loudly and publicly. I am not sure what is to be gained with that, since it sets up a dynamic that is hard to come back from once a CB actually causes problems for that company.
But I think it’s important to note that not all the problems I am discussing come from the guys wearing the visitor’s badges during an audit; sometimes they come from the other side of the table, too.
Christopher Paris is the founder and VP Operations of Oxebridge. He has over 35 years’ experience implementing ISO 9001 and AS9100 systems, and helps establish certification and accreditation bodies with the ISO 17000 series. He is a vocal advocate for the development and use of standards from the point of view of actual users. He is the writer and artist of THE AUDITOR comic strip, and is currently writing the DR. CUBA pulp novel series. Visit www.drcuba.world
