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Annex SL Being Renamed, and Why That Proves It's Bad for Standards
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Christopher Paris
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7 May, 2019 - 9:49 PM
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Image EnlargerComes now the information from Dolf van der Haven that the controversial Annex SL was renamed as “Annex L.” This, you may recall, is the mandatory “high-level structure” ruleset published by ISO for which all management system standards (MSS) must comply, if they are to be published. Over one-third of ISO 9001:2015 was actually text mandated by Annex SL, and not developed by the world’s delegated quality representatives.

The rules get their name from their position in the much larger document called (in brief) the “ISO Consolidated Supplement” (which you can read online here.)¬†This document houses most of the rules governing ISO standards-making, with three primary sections: rules applicable to ISO itself, rules applicable to its sister organization IEC (the International Electrotechnical Commission), and then rules applicable to both. (Thus the word “consolidated” in the title.)

Keep in mind, no one can vote on the ISO Consolidated Supplement. It is a mandatory document, used to manage ISO activities behind the scenes. Rules published in it are not subject to any international oversight, not subject to ISO’s own standards development rules, nor those of the World Trade Organization. The Consolidated Supplement is treated as a purely “internal procedure” document, but ISO has been slowly moving more and more rules into it, in order to avoid international oversight. Members of TMB will tell you that Annex SL was voted on, and members of TMB will by lying. They submitted the text for some non-binding opinion polling, which is far different from official international voting.

It gets worse, If you have a problem with your nation’s standards development body (such as ANSI in the United States), you have formal mechanisms for reporting those problems and getting them addressed within your country. You have no such recourse with the ISO TMB, because they are not answerable to any government, anywhere on the planet. They don’t even have to tell you who is on it, and they typically don’t. Only a few stray leaked documents show who worked on the original Annex SL draft, and those were closely guarded.

Remember: an entire third of ISO 9001 was written by the TMB as part of Annex SL, including the entire clauses 4.1, 4.2 and 6.1 — where the bulk of the changes were found. And voting on that text was prohibited under ISO’s rules, so it was approved automatically, even though no one knows who wrote it.

You’re Next, IEC

The high-level structure rules got their name from their position at the end of the ISO Consolidated Supplement, as one of the annexes. Rules applicable to both ISO and IEC appear in the single-letter Annexes (A through K), and those applicable only to ISO appear in Annexes prefixed with the letter “S,” such as SA, SB, SC, etc. Previously, the high-level structure was located in this area, in the slot “SL.” That’s it.

Moving the HLS to Annex L shows just how serious ISO is about pushing its agenda to prevent standards from being made by delegated authorities, and written by the non-elected TMB instead. By moving Annex SL into the portion of the rulebook applicable to both ISO and the IEC, the HLS just got a serious upgrade in authority. Now, not only will the non-elected TMB be writing text for ISO standards, like ISO 9001 and ISO 14001, it will also be writing text for the IEC, too. 

The thing is, IEC is far more prickly about this, and a lot of people are likely to be very, very pissed that their authority has been stripped from them. There’s nothing they can do about it, of course, short of breaking free from ISO entirely. Good luck with that.

But it’s problematic, to say the least. IEC standards are, by their very nature, more technical, and address safety and performance characteristics of devices such as wind turbines, or test methods for electrical safety. Allowing the non-elected TMB to tinker with these texts is a recipe for disaster, literally. There’s a reason the IEC has held a “separate but equal” position alongside ISO, rather than subservient to it. The TMB just fired a shot across the IEC’s bow, letting them know their days of being independent are over.

The reason ISO is pushing this is to fast-track ISO and IEC standards development. ISO is a publishing company, and its standards only make money when they are available for sale, not when they are stuck in development committees. Using committees composed of delegates from 170+ countries of the world slows things down dramatically, costing ISO money. So ISO needed a way to get around the nations of the world. Enter TMB.

The nations of the world, meanwhile, are happy to continue to give ISO the role of standard developer so lawmakers can claim to voters that they “reduced taxes” by privatizing standards development. It actually costs countries more money in the long run, and leads to deadly disasters, but politicians remain removed enough to never be harmed by this reality. So you can’t expect any countries to stand up to the TMB and take back their rightful place at the table. Worse, countries like US and the UK are openly complicit, with their various standards bodies acting as simultaneous publishing companies, too, ensuring the conflict of interests remain intact. ANSI is never going to slow down ISO 9001 development, since it publishes ISO 9001 in the US.

And, hey, Brits: go see where you buy your standards from. Now imagine if they’d really like to slow-roll standards development to get them right, or if they have a vested interest in rushing them to print.

So while the rest of the world sees this “Annex L” thing as just a “renaming,” the change is actually far more menacing for those wanting to ensure that ISO/IEC standards — which affect hundreds of millions of companies across the entire planet — are written by delegated subject matter experts nominated by ISO member nations. Now, entire sections of text will be written by a tiny group of people — 35 at the last Atlanta meeting — who are answerable to exactly no one, and no nation.

It’s a good gig if you’re Nigel Croft, who is leading this up. Bad if you’re one of the other 7 billion people on the planet.

 

 

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