Read part 1 here.
The final “future concept” cooked up by the ISO TC 176 Task Force 4 is “ethics.” Spit your milk out now, because it’s not going to get any less hilarious as we delve into this.
Let’s pause for a minute and remind ourselves who is asking for ISO 9001 users to consider “ethics.”
This team includes Alka Jarvis, the former Chair of US TAG 176, the American delegation to TC 176. Jarvis rigged the election of her successor, Paul Palmes, who himself had lied on his resume by adding over 20 years of ISO-related experience he didn’t have. Jarvis refused to put a competing nominee on the ballot, to ensure Palmes was elected. Later, it was revealed that Jarvis and Palmes co-authored a book on ISO 9001, which they promptly began marketing using their “Chair” statuses. Then, Jarvis worked with conspiracy theorist and self-accredited certificate mill operator Daryl Guberman to have me banned from all ASQ speaking events, using her role as former TAG Chair to do so. When questioned about it, Jarvis said she had no role, until actual emails came forth revealing she had lied.
Also on the team is Lorri Hunt, who also worked with Guberman to affect the Oxebridge ASQ ban. Hunt, you may remember, is the TAG Leader who literally gave a presentation on how risk-based thinking would be “the biggest boon to consultants ever.” She then went on to sell her consulting services and seminars on, of course, risk-based thinking. She then falsely claimed sole credit for writing ISO 9001…. seriously.
Next you have Charles Corrie, the BSI bureaucrat who also single-handedly controls all of TC 176 activities as its official “secretary.” Corrie worked with ISO’s then-Legal Advisor Holger Gehring to threaten to sue Oxebridge — twice — for copyright infringement, due to its reporting on ISO standards. Gehring and ISO’s Wall Street law firm tried an unusual, and ultimately unsuccessful, tactic: to claim that even “discussions” about ISO standards were protected under their conversation, suggesting I needed approval from ISO for not only any written comment about their standards, but even spoken words. They dropped their threats after I threatened them with a trademark bullying lawsuit.
Still with me? There’s more.
Denise Robitaille is on the committee, of course. You may remember her as the ASQ and TAG functionary who went around soliciting $10,000-a-pop donations for an ISO event that was never actually held. Robitaille and ASQ then refused to explain where the money went, and ASQ was subjected to a formal IRS audit after I reported the scandal to them. ASQ never disclosed the fundraising by Robitaille on its official IRS tax forms.
So none of these people reside int eh pantheon of ethical gurus within our industry. The bulk are self-serving private consultants who work to make ISO 9001 as confusing as possible, so they can sell consulting services to confused readers later. They’re not even coy about it, either.
It’s therefore simultaneously troubling and hilarious that these same unethical shysters would inject “ethics” into the next set of ISO 9000 standards, but it’s at least consistent form on their part. Let’s look at what they are proposing.
Ethics, Integrity and Greed
Officially, the Future Concepts document refers to “Ethics & Integrity” — not just ethics. The document then appears to try and retcon how ethics and integrity would fit into ISO 9000 standards, rather than explain them first, and make the standards fit later.
For example, the document launches into a description of the concepts of “ethics and integrity” using typical words and phrasing we see in the standard and ISO press releases, in order to subtly program reader into believing the standards already comply with the concepts:
The context of an organization is impacted by ethical behavior as top management and leaders within the organization examine internal issues associated with culture, values, attitudes, knowledge and performance of the organization.
You can see they took the text of ISO 9001 clause 4.1 and 4.2 first, and then used that to back-fill their discussions on “ethics,” dropping in phrases from the standard such as “context of the organization” and “internal issues.” No other normal discussion on ethics would include these exact terms, so the ploy is obvious.
This is typical Charles Corrie and BSI language, trying to “market” a new concept as having already been in the ISO 9001 standard all along. You may remember how Nigel Croft invented “risk-based thinking” out of thin air, and then had his pals at BSI craft a press release saying “risk has been implicit in ISO 9001 all along,” which is patently false. (Prior editions of ISO 9001 included language explicitly staying the standard did not address risk.)
So BSI is at it again, this time with “ethics.” In a justification statement for adding “ethics” to ISO 9001 and ISO 9004, look at this trope:
Reference to ethics and integrity is made by inference in ISO 9001 and explicitly stated in ISO 9004. Few would argue that ethics and integrity are not components in addressing external and identifying internal context to determine the organization’s culture and values.
See the part about “few would argue”…. ? BSI and ISO are already crafting a legal defense, rather than making their case. “Few would argue” that ISO 9001 is wholly off the rails, but you don’t see them taking action on that fact.
The Future Concepts document then points to IATF 16949 and AS9100, which have both incorporated weak references to ethics in their standards. Clearly TC 176 felt left behind, not having thought of this sooner. It then goes on to quote Baldridge, EFQM, and UK Business Excellence, too.
The next part is shockingly out of touch, however, and clearly written by BSI, not by anyone on TC 176. Again, I warned you to spit out your milk first:
The auditing community has consistently held high levels of ethical behavior to be paramount. The recently revised ISO 19011:2018 includes integrity as the foundation of professionalism and trustworthiness. This includes performing work ethically, with honesty and responsibility; only undertaking activities if competent to do so; remain fair and unbiased in all dealings; and being sensitive to any influences that may be exerted on judgment.
To which I say… oh my fucking god. Did they seriously just write that?
This is like the Mafia Don claiming to be a good citizen because he gives free apples to the homeless, so let’s ignore the fact that he just ordered the murder of 50 guys encroaching on his heroin smuggling territory.
Remember, this is the industry where an auditor literally gave training presentation on how to hypnotize clients during audits — without their knowledge! — to make them more compliant to auditor suggestions.
Few would argue (see what I did there?) that the CB auditing community is one of the most unethical, corrupt and cynical machines on the planet. Oxebridge readers know this already, so I don’t need to rehash it, but have a look at this list of ongoing investigations into CB misbehavior, incompetence and unethical dealings.
Furthermore, calling out ISO 19011 for anything is a red herring. That standard is only recommended, and not hardcoded as a requirement in any accreditation standards. A CB or AB auditor can ignore it entirely and still be in full compliance, which is exactly what they do.
The Future Concepts document then cites the Auditing Practices Group, which is also a wholly un-supported organization with wholly un-supported “opinion papers” on how audits should be performed. Their publications are non-binding, and all come with huge disclaimers indicating that they are not to be construed as actual auditing rules or required practices. In short, they are bullshit.
But let’s get to the meat of the matter. What will this mean for ISO 9001 itself? How will this appear in the standard, how will yo uimplement it, and how will auditors tackle it?
How This Impacts ISO 9001, Specifically
The Future Concepts document suggests it will be embedded into the following ISO 9001:202x clauses:
The main impact of ethics would be introduced as part of the context of the organization in clause 4.1 and subsequent risk-based
thinking and planning. Leadership in clause 5.1.1 as this sets the tone for ethics and integrity. Additionally, awareness in clause 7.3 to ensure the ethical behavior and attitude of integrity permeates the organization’s culture.
Putting aside that ISO is still not done tinkering with fucking “risk-based thinking,” the thing that has caused ISO 9001 to have the greatest drop in certifications in the standard’s entire 30+ year history, it appears they intend on hammering “ethics” into those clauses. This means that during the identification of “issues” — which ISO has still not explained properly — you will be asked to consider some amorphous, vague “ethical” concepts.
Next, the already un-auditable clause 5.1.1 on “Leadership” will be branded with the new “ethics” marketing, making the clause even more un-auditable. What, your CB — the guy who sits in the conference room for four hours and leaves the audit early but still bills you for an 8-hour day — is going to suddenly start grilling the CEO on their morals? Their church-going practices? Whether or not they stole money that month, or inappropriately patted the ass of the new Human Resources Director?
Finally, they intend on demanding that “ethics” become a part of the company “culture,” a concept that ISO really can’t seem to get its head around. As I wrote in Part 1, the head of TC 176 SC 2 — the committee that literally writes ISO 9001 — insists you can’t put “culture” in the standard, but meanwhile the real bosses (at BSI) are claiming you not only can, but you will. They can’t even get their own story straight on this.
Finally, BSI hedges its bets and gives ISO some cover as far a legal liability goes. Buried near the end of the chapter on Ethics, BSI writes:
It is not expected that adding ethics and integrity to requirements would yield a great number of nonconformities.
This means that if your company is found later to have been involved in criminal scandals or any other unethical brouhaha, they can justify why the auditors didn’t find it. In short, they don’t really intend on auditing this at all anyway, an admission on TC 176’s part that it is un-auditable.
The end result will be more of what made ISO 9001:2015 so loathsome and impossible to audit. This adds needless complexity to the standard, thus increasing costs for implementation and training. It then offers no return on investment: the paper admits that auditors are unlikely to write findings, but can you be sure? Thus, the anxiety and confusion heading into audits will be increased, something a standard should never intentionally do.
Furthermore, a lot of companies are not particularly ethical to begin with. Sure, they talk a good game — look at what BSI wrote above about “high levels of ethical behavior [are] paramount” within its auditing community — but in reality, the companies know they are not really ethical. CEOs and executives are going to recoil at the “politically correct” actions of TC 176 here, and sales of ISO 9001 standards and certifications will decline further.
Now remember, back in 2013 I started warning ISO that htis would happen if it pursued the inane “risk-based thinking.” I published a widely circulated “Public Call” white paper calling on ISO to reverse course on risk-based thinking, writing:
Based on the convergence of these key four factors – lack of management principles, negative early user feedback, alienation of major international sectors and two decades of ISO Survey data showing declining interest – it is clear that ISO TC 176 must change course on ISO 9001:2015.
ISO didn’t do that. Instead, they threatened to sue me. They ignored the common-sense suggestions, and now ISO 9001 saw the biggest drop in certification sin history, right on target. (Early, actually.) Oh, and their Legal Advisor isn’t working there anymore.
So let’s be clear. There is no chance at all that ISO will listen this time. It’s not even worth publishing another Public Call document begging them to. TC 176 is entirely infested with private consultants, like Jarvis and Hunt and Paul Simpson, and they cannot “hear” anything that disagrees with their entrenched view. They represent everything that is bad in the quality profession (refusal to acknowledge data, rejection of customer feedback, closing off complaints, etc.) and yet they hold the reins.
There is no nudging them off their path towards the cliff.
The perfect storm awaits. ISO 9001:2015 was already a train wreck, resulting in dramatic losses worldwide. The COVIC-19 pandemic has led more companies to drop their ISO 9001 certifications, because of the IAF’s refusal to initiate a one-year pause on all audits, or to promote wholesale remote auditing. The final nail in the coffin will be TC 176’s insistence on repeating its failures, by adding in more nonsensical, un-auditable “feel good” requirements to a standard that is intended, first and foremost, to provide requirements for objective third-party audits.
I had predicted previously that in the US we would drop below 10,000 certified companies by 2022. That was before COVID. At this rate, we may hit that by next year (although I suspect ISO will stop reporting certification date entirely, leaving us to guess.) And the US won’t be alone. We can expect drops in major bellwether countries like UK, Germany, France and Italy to see similar numbers.
ISO has some diversification in standards that may allow it to survive while its flagship falters. Sales in related standards such as ISO 45001, ISO 31000 and others, may slightly uptick, but the overall losses will remain. Because it’s a non-profit, we can’t see their books, but it likely won’t be good. So long as the execs get paid, it really doesn’t matter how well they perform.
Part 3: The Notorious B.I.G. — the ISO 9001 Brand Integrity Group — also has some, erm… thoughts.