Today a friend of mine, who does some work with TC 176, wrote asking my feedback on making minor word changes to 9001. He specifically noted 9001:2000’s struggle with “product” and “service,” and hinted that some simple terms may yet again be up for grabs as part of the upcoming 2015 revision. He asked me what value, if any, was to be had in such changes.

Normally I’d fire off a quick email about it, but the question presented such a perfect example of what is wrong with TC 176 and its ISO 9001 development process, I knew it needed a more considered response. Thus, this.

My friend’s specific concern was the impact on users of ISO 9001, a remarkable question in itself because it is almost never raised by anyone on any of the TC’s, WG’s, TG’s or other otherwise alphabetized committees within the 9001 development complex. It was heartening to see someone, after over a quarter of a century, asking what the impact would be on what must appear to be insignificant wordsmithing by the authors.

Here’s the short answer: it’s a huge problem.  A huge, expensive problem.

Butterfly Effect

In Lawrence of Arabia, Claude Rains’ character Mr. Dryden says, famously, “Big things have small beginnings, sir.” These obsessions with fiddling with minutiae, while ignoring consequence, are like cutting a pie improperly from the center: by the time your knife reaches the edge, you realize the slice is far too big, or far too small.

For its 2008 revision, ISO elected that the 9001 standard would have no new requirements, and only wording changes performed for clarity.  Consider, as well, that it took them eight years to make those minor changes, three years over deadline. This is proof that the TC 176 tinsmiths love tinkering, and more so, talking about tinkering. One thing will always be true about standards authors: they love to hear themselves saying nothing.

So the first expense incurred is that of the development process itself. Development time costs ISO a bit, but costs member nations a lot more, as they have to foot the bill for meetings, transportation, etc. Volunteers from all of the world pay their own way to attend meetings, flying in airplanes and taking trains and driving rental cars and eating hotel food. Now, granted, a lot of these guys are independently wealthy or otherwise funded, but it’s nevertheless a huge waste of money if the sole purpose is to change the phrase “monitoring and measurement equipment” to “monitoring and measurement devices.” Eight years for that?

That brings us to the second point: outlandish costs which eventually punish the ISO 9001 user organizations. The change in clause 7.6 (“equipment” to “devices”) is a great case in point.  I cannot reliably tell you the number of times that my clients have had certification body (CB) auditors write findings because the company did not update that single word in their Quality Manual. This has led to often contentious debates during audits, between the CB auditor who insists there is a difference in the words (“devices include equipment, but not the other way around!“) and the clients who sit there, dumbfounded, trying to comprehend why their expensive audit time is being chewed up with such an absolutely nonsensical, wasteful debate.

Likewise the ages-old argument of “continuous” vs. “continual” improvement; hint: no one cares about plateaus, and it’s certainly not worth writing nonconformities over.

Auditors weren’t the only ones making things bad for users of the 2008 amendment. Consultants sold the public a bill of goods, saying that additional training could be needed to address “the new requirements” of ISO 9001:2008, even as ISO insisted there weren’t any.  US TAG leaders spoke at for-fee dinner events, to explain the new, non-required requirements (or something). Jack West, Charles Cianfrani and Joe Tsiakals wrote three editions of ISO 9001:2008 Explained, because it apparently took that many editions to tell the public there was no change in requirements since their last tome, ISO 9001:2000 Explained. CB’s insisted companies needed to “update” their documentation to comply with the new wording, even though there has never been a requirement to align a company’s QMS documentation with the standard, and in fact it says so right in clause 0.1. And the AB’s failed to properly police the whole thing, lest they upset their revenue stream.

No One Expects the Spanish Inquisition

So bad was the problem, at least one incident made its way through the complaint process all the way to ANAB … sort of. After SGS auditor Ernest Blanchard wrote a nonconformity that a client had “failed to implement ISO 9001:2008” because the language of the QMS was not exact (“equipment” was still referenced, rather than “devices”), a complaint was filed with SGS to have the nonconformance dropped. SGS initially refused, so it was escalated to SGS senior management. That resulted in the now-infamous angry voice mail message by SGS certification manager Zachary Pivarnik, who classified the complaint as “an inquisition.” That resulted in Oxebridge filing a complaint against SGS with ANAB, citing 11 violations of ISO 17021, including accusations that Mr. Pivarnik grossly violated objectivity and the rules for processing complaints with his crazy, off-the-hook rant. (Seriously, how does this guy still have a job?)

Because Mr. Pivarnik had injected himself into the debate, the client and I made an attempt to move the discussion to SGS’ Impartiality Committee, but Mr. Pivarnik simply — and incredibly — refused. ANAB was called in to rule on that, and sided with SGS, saying a CB does not have to grant anybody access to its impartiality committee, making the whole thing sort of pointless. ANAB also refused to rule on the fact that Mr. Pivarnik was now part of the complaint, and therefore was not eligible to conduct the corrective action; they just ignored that point altogether.

Rather than process the complaint properly, ANAB’s Randy Dougherty took to resolving the matter through phone calls, a frustratingly common tactic, as it ensures no record of the issue, other than a quick entry on the ANAB website.  SGS issued a hastily written “Continual Improvement” report which did not address the original complaint at all, and still refused to admit that the Ernest Blanchard finding was unsubstantiated by requirements. ANAB accepted it within a shockingly fast 24 hours, in order to close the book on the complaint. The original issue — regarding issuance of ISO 9001:2008 nonconformities against requirements that didn’t exist — was never addressed. In SGS and ANAB’s minds, the issue would just go away when 9001:2008 became the default standard, and all transitions were completed. They never saw the big picture that every 5 – 8 years, we have to go through this all again, whenever TC 176 makes what appears to be a non-substantial change in synonyms.

So… because a few people at TC 176 thought changing “equipment” to “devices” made sense, in just this one case, the following were incurred:

  • CB expenses associated with the writing of a bogus finding, and the lecturing of the rationale
  • Client expenses associated with time to respond to bogus SGS finding 
  • Consultant expenses associated with time to file the complaint and assist the client
  • CB expenses associated with defending the bogus finding
  • AB expenses associated with moderating and closing the complaint
  • CB expenses associated with conducting (however off-focus) the CI action and resolution
  • Utter loss in faith by the client in all of the players: the CB, the AB and ISO 9001 itself.

But, Wait… There’s More!

A lone case? Not quite.

In another related incident, also (coincidentally) regarding SGS, auditor Bob Chickillo was discovered to have been giving a 90-minute “ISO 9001:2008 Training Module” to his certification audit clients, using audit time to do so. During the presentation, he would insist that clients needed to update their QMS to comply with 9001:2008, and would then train them on how, specifically, to do that. It was only after it was discovered that Mr. Chickillo had stolen a the presentation from rival registrar BVQi  and put his own name on it — in violation of intellectual property law — that he was shut down. SGS never admitted wrongdoing, no one ever stopped the auditor from using audit time to conduct training on nonexistent requirements, and clients were never reimbursed for the lost audit time.

ISO 9001 training provider Omnex sold a $149 “ISO 9001:2008 Auditor Transition” webinar, given by company founder Chad Kymal, claiming the course presented “the most comprehensive review of RABQSA, IRCA, key registrars, and ISO 9001 Technical Committee TC 176 requirements.” Bulk spam emails were sent to ISO 9001 end user organizations announcing the seminar series. I contacted Mr. Kymal multiple times, through emails and voice messages, asking him to give specific examples of the changed requirements, including those of “key registrars” and TC 176, and never heard back. Only Omnex knows how many companies paid for this, and so brazen are they, that even after alerting them that their marketing was bogus, if not criminally fraudulent, their advertising link for the webinar series remains in place even now. (Seriously, go see, in case you think I’m making this up.)

These are just examples I saw personally, and these don’t include the dozens of times I have had to edit client Quality Manuals to tweak the language to exactly align with whatever whimsical change TC 176 issues. Remember, I am just one guy with a small consulting firm. I can’t imagine the scale of the problem in the real world, multiplied over all those clients, over all those nations, across the entire planet.

Small beginnings, indeed, Mr. Dryden.

Purina 9000

Where ISO goes wrong is in its failure to consider the impact on users, and refusing to understand the certification process. The first of those failings can be remedied by ensuring greater participation by actual users of the 9001 standard, rather then relying on an aging population of retired execs and “high level thinkers” who have never worked a single hour under a system subject to their product. These men — and most of them are male — write books and give speeches and wear sashes, but have not a clue as to how their product is used. If any industry needed dogfooding, it’s this one.

By simply ensuring proper participation, this problem goes away. But ISO’s obsession with a flawed rule that every standard must be revised in 5 years, something they never actually achieve, ensures that the ultimate governor of standards development is the wall clock, not stakeholders or even common sense.

The second failure – to refuse to acknowledge certification – is more troublesome. ISO wants it’s cake while gorging on it. It wants to publish a standard targeted for certification, and will use certification numbers to spin its marketing in order to sell standards. But then it also wants to disassociate from certification, insisting that’s not the purpose of the standard and (especially when things don’t go well) reminding everyone it is not promoting certification, and has no role in it.

So the TC 176 authors never fully plug into the certification impacts of ISO 9001 revisions, such as the ridiculous SGS example above. Well, sorry, guys: your product is used for certification. Get over it. Embrace it. Understand your market, for God’s sake.

Once TC 176 gets this — and I mean truly and deeply “gets” it — then ridiculous tinsmith tinkering can be put aside so that those half-decades are used to glean better results. Let’s address the problems with the process approach. Let’s integrate some Lean, some advanced concepts. Let’s push the standard to result in improved product, not better adverbs. Let’s reach out and link to some truly useful related ISO standards, like those for risk management, configuration management and auditing, rather than attempt to go it alone. Let’s figure out how to involve the service sector without sacrificing the manufacturing sector, or vice versa. And for heaven’s sake, let’s bring document control rules into the post-mimeograph era, without stripping it so bare there are no requirements left.

Word-swapping will inevitably cost companies thousands of dollars in time spent updating documents and procedures, in auditors writing bogus findings when a client fails to do so, and in processing the inevitable complaints. Worse yet, it will further damn the legacy of TC 176 as an out-of-touch group that cares little for the considerations of their customers, the end users, and thus grossly contradicting the rules they are imposing on others.

We need for ISO 9001 to lead the advances in the quality sciences, not simply document them 20 years after the fact.

 

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