There is a frustrating rule on the books that is crippling ISO 9001 adoption rates, which serves no useful function whatsoever, and must be changed. This is the prohibition against using ISO 9001 certification marks on product, as defined in ISO 17021:

8.4 Reference to certification and use of marks

8.4.1 A certification body shall have a policy governing any mark that it authorizes certified clients to use. This shall assure, among other things, traceability back to the certification body. There shall be no ambiguity, in the mark or accompanying text, as to what has been certified and which certification body has granted the certification. This mark shall not be used on a product or product packaging seen by the consumer or in any other way that may be interpreted as denoting product conformity.

The purpose of the rule was that there was never any misunderstanding that ISO 9001 denoted quality management system certification, and not a product certification. What this has led to, however, is a counterproductive obstacle to marketing ISO 9001 to consumers, which has contributed to the lack of awareness in the public as to what, exactly, ISO 9001 is. It is also likely to be causing more harm than good, as I will discuss.

And the thing is, the problem is so easily rectified. The rule needs only two words deleted to make it feasible, such as:

This mark shall not be used on a product or product packaging seen by the consumer or in any other way that may be interpreted as denoting product conformity.

Just by removing the words “or” and “other,” it would free companies up to put the mark on products, provided they ensure it is done so while indicating the QMS is certified, not the product. Since most registrar marks already include the phrasing “ISO 9001 system certification” this requires no extra work on the part of certification bodies nor accreditation bodies. The client organization would instead have to go out of their way to violate the rule, by intentionally adding language to their logo by saying “ISO 9001 certified product.” There’s little risk of that happening, and there’s zero incentive.

Leggo My Logo

The rule is haphazardly enforced anyway. Recently, a client of mine asked SGS if they could put their logo (with the accompanying ANAB mark alongside) on tags attached to their product, next to the CE mark logo, the latter of which is allowed. SGS responded that, no, they could not, and attached a document detailing their policy along with ANAB’s rules on the matter.

But perhaps, then, someone can explain this, spotted in a hardware store?

plumbing2

… or this, which appeared on a mattress tag?

mattress

.. or any of the other thousands of products one sees, all over the world, with official CB logos on them, including that of SGS? How about this:

 highway

It’s for a state toll system. Since under ISO 9001, the term “product” includes “services,” does putting the logo on the toll receipt constitute “product”marking? Or would this only be prohibited if the logo were painted on the actual highway tarmac itself? I have also seen a big, two-foot tall SGS logo — in 3D carved letters — on the side of a dentist’s office  (sorry, I didn’t photograph it.) If dentistry is a service, does putting the logo on the building constitute marking “the packaging”? Or is it only a violation if the logo is placed on people’s teeth? Or the dentist’s forehead? As you can see, the rule is ludicrous when one tries to interpret it, so people just don’t.

And here’s the rub: to get around the rule, all a company need do is simply use any of the billion generic “ISO 9001 certified” logos that one can find from a simple Google search, and slather them on product all day long. Since the CBs can’t enforce those, the company can use a logo that says nearly anything, without the proper oversight of the CB rules. The restriction thus pushes companies into intentionally not using a proper logo, and has the side effect of not promoting their CB. It’s a self-inflicted wound.

Unlike my certificate mill friend Daryl Guberman, who tries to twist this situation into a tinfoil hat conspiracy theory that somehow justifies buying his bogus, self-accredited ISO 9001 certs, most people and companies can understand context. If you mark something with an ISO 9001 logo that clearly states the quality system, not the product, is being marked, that’s usually sufficient. Those that are going to get confused will do so no matter what you do, so why dumb down the rules for everyone? By ISO’s thinking, people are so stupid they may accidentally buy bleach when the package says “chocolate” so we shouldn’t bother marking things at all.

Good Intentions Gone Awry

fairtrade

There’s another problem: the rule is not having the desired effect, but may in fact be resulting in the opposite. By refusing to allow products to be tagged with system certification marks, the only marks the public ever see are product certification marks. This means that when they do see an ISO 9001 logo used properly — whether on a website, truck panel or billboard — they just assume it means a product certification anyway, because they have no idea what a “system certification” is. If the marks were allowed on product, this would slowly educate the consumer on the concept of system certifications, while promoting the value of ISO 9001 itself. Imagine if instead of ISO 9001 being driven by prime customer mandate, it was driven by the public. That’s a 7-billion strong source of free advertising that ISO is throwing away.

Meanwhile, other industries are schooling ISO on how it could be done. Consumers are aware of some of the most half-cocked certifications out there, purely because cool logos are being put on products. Coffee is sold as “Fair Trade” certified, which is a certification granted to the producer, not the coffee bean itself, but caffeinated hipsters don’t really care about the distinction. “EnergyStar” rated electronics are sought over non-rated products, but the public probably has no idea that it means something entirely different for a TV than a washing machine. A new food label touting “Non-GMO Verified” is hoodwinking the public, since it basically means “food made the way we’ve always made it, but with a new label.”

If the public can be sold on strange and dubious certifications, then imagine what could be done by starting the education process of the public on the notion of serious. accredited QMS certifications.

The change would have to be carried out by ISO’s Committee on Conformity Assessment (CASCO), which authors the ISO 17021 standard. Lobbying them as an individual would have no effect, so the change must be driven from stakeholders closer to the process: ideally the CBs themselves, through such groups as the IAAR or from a single huge CB, such as BSI. 

In summary, the rule is self-limiting and pointless, as it:

  • is inconsistently applied,
  • is not having the desired end result, but may in fact be having the opposite,
  • could be altered with little effort, and nearly no chance of confusion by the public,
  • is only enabling the growth of unaccredited certifications, and
  • is hurting the promotion of ISO 9001 to the most important demographic: the consumer.

Let’s get this fixed, ISO!

(This Open Letter has been sent to all members of the IAAR, who have significant sway with ISO/CASCO; I have asked them to spearhead a push to change this rule. CASCO Secretary Sean MacCurtain received a preliminary notice, but just responded with the usual ISO line that all changes have to go through approved member bodies, and a cut-and-paste defense of the rationale for keeping the rule in place.)

About Christopher Paris

Christopher Paris is the founder and VP Operations of Oxebridge. He has over 30 years' experience implementing ISO 9001 and AS9100 systems, and is a vocal advocate for the development and use of standards from the point of view of actual users. He is the author of Surviving ISO 9001 and Surviving AS9100. He reviews wines for the irreverent wine blog, Winepisser.

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