The ISO Technical Management Board (TMB) is responsible for the development of the Annex SL content and “high level structure” requirements that must now be used by all ISO Technical Committees (TCs) when drafting ISO management system standards. This has caused some to question how the TMB, which is not comprised of the same consensus representation as the TCs, can draft standards such as ISO 31000 on risk management, or dictate content to all other TCs in their work.

ISO policy, as well as international regulations such as those of the World Trade Organization, require that standards be developed in a transparent manner, to ensure proper user and stakeholder participation, and to prevent barriers to free trade.

The TMB is subject to a number of controlling ISO documents, including the TMB Rules of Procedure, which are publicly available. A review of the Rules of Procedure show two sections that are relevant to the transparency of TMB work. These are Clause 3 “TMB members’ contributions to ISO technical work” and Clause 4 “Transparency and communication of TMB work.”

Oxebridge has analyzed the language of the Rules and discovered that a majority of the language acts to limit or restrict concepts normally considered related to transparency. In conducting this exercise, the common understanding of transparency used was a moral position derived from openness, communication and accountability.

Using a color coding system for the words in Clauses 3 and 4 of the Rules of Procedure, the contrast is immediately apparent. To conduct the analysis, the language of the clauses was inserted into a single document of a single font, font size and line height. The language was then analyzed and color coded using the following conditions:

  • Language that promoted openness, communication or accountability was coded green.
  • Language that limited openness, communication or accountability was coded pink.
  • Language that restricted or prohibited openness, communication and accountability was coded red.


Analyzing the word count, Oxebridge discovered that of the 645 highlighted words, 68% — more than two thirds — were either limiting or restricting of common principles of transparency.


Oxebridge is currently investigating whether the TMB and its imposition of Annex SL have violated ISO rules or WTO regulations preventing technical barriers to trade.




ISO 17000 Series Consulting

Why we report on these topics

Since 2000, Oxebridge has worked to improve ISO and related certification schemes by identifying problems and then proposing solutions. We report on issues affecting standards users because so few other news outlets do. Our belief is that in order to fix the problems in these schemes, we must first understand the nature and breadth of those problems. Our reporting aims to do just that. Elsewhere on the Oxebridge site you will find White Papers and other articles proposing ideas to correct these problems.


Available Tools

Oxebridge SWAG