Thursday, February 2, 2023

How could ISO 9001 stop climate change?

I was going to write more about systems thinking, but something has come up and I want to address it while it is still timely. Two weeks ago the leadership of TC176 SC2 (that's the subcommittee that writes the ISO 9001 standard) held an ad hoc meeting to discuss what impact the topic of climate change should have on ISO 9001.*

Image by Kanenori from Pixabay
You remember I wrote about this topic last fall in this post here. At the time, I argued that climate change is out of scope for ISO 9001, and that any attempt to shoehorn the topic into the standard would be bad for the ISO brand. Specifically, I think there is a meaningful risk that updating ISO 9001 to address climate change will either push companies to abandon ISO 9001 or else make them more cynical about the process of certification. Or both, of course. I have not changed my opinion in the intervening months. 

But my opinion is, to put it gently, not the only one on the table. So there was a meeting to talk it over.

What was proposed?

Under discussion were two proposals. Both were to add specific wording to the Harmonized Structure for ISO Management System Standards. That means that this wording would appear in management system standards across the board: not only ISO 9001 and ISO 14001, but ISO 20000, ISO 21001, ISO 22000, ISO 28000, ISO 29001, and obviously many others.** 

The first proposed change would add a requirement to subclause 4.1 as follows:

Today the clause reads:

4.1 Understanding the organization and its context

The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended result(s) of its XXX management system.

The proposal would add:

The organization shall determine whether climate change is a relevant issue.

The second proposed change would add a note to subclause 4.2 as follows:

Today the clause reads (with minor variation among standards):

4.2 Understanding the needs and expectations of interested parties 

The organization shall determine: 

— the interested parties that are relevant to the XXX management system; 

— the relevant requirements of these interested parties; 

— which of these requirements will be addressed through the XXX management system.

The proposal would add:

NOTE: Relevant interested parties can have requirements related to climate change.

What does the first one mean?

Image by Darwin Laganzon from Pixabay
The first proposal adds a "shall" statement. This is an explicit requirement. It is auditable. Every certified organization would have to comply.

Even so, this "shall" statement would not require that an organization actually do anything about climate change. In fact if the organization were (for example) a hamburger stand—and ISO 9001 is supposed to be applicable to hamburger stands, in case one wants to be certified—there might not be much meaningful that they could do. But they would have to "determine" whether climate change is a relevant issue for them. Since this requirement is auditable, they would have to keep meeting minutes showing the decision. 

Not everyone agrees with me that some organizations might find it hard to take meaningful action against climate change. During the discussion, some people argued that, "There is not one organization in the world that can determine climate change is not a relevant issue. This would de facto mean you have to address your influence on climate change, even without requirements from relevant parties (see 4.2)."

I disagree, and I think the people who argued this have confused two different questions. The problem is that the word relevant is ambiguous. So I think these people have conflated: 

  • Will the organization be affected by climate change? ... and ... 
  • Can the organization do anything about it?
I am prepared to agree that the answer to the first question is "Yes" for most people (and therefore most organizations). But for small organizations the answer to the second question is often going to be "No". And those organizations should be allowed to say so when they establish their Context.

What does the second one mean?

Chemical Engineer, Public
domain, via Wikimedia Commons
The second proposal simply adds a note. Notes are not auditable, so this would not impose any requirements on the certified organization. In fact, the note doesn't address the certified organization at all: what it tries to do is to read the minds of interested parties by describing what can be included in their requirements. But it is still up to the interested parties to explain their requirements to the organization. It is never the organization's job to tell their interested parties what they should want.

To be sure, as an objective statement of fact the note is completely true. Relevant interested parties can have requirements related to climate change! There is no question about that. Of course, they can also have requirements related to macramé antimacassars, so by itself that's not saying much. Still, it's a true statement that requires nothing from the organization which they aren't going to hear about anyway. In that sense the proposal is completely harmless, and it gets the words "climate change" into every standard that follows the Harmonized Structure without disrupting anything else. From a certain perspective that might look like a win for everyone. 

What was decided?

In a final sense, nothing was decided. What I mean is that there were no formal decisions to make any changes to ISO 9001 or any of the other standards based on this meeting. Lots more votes will be required, at multiple levels, before any changes are formally authorized. But the options were reviewed, and doubtless some suggestions based on this meeting will be forwarded on to the next one.

If you are involved in this decision process, please think about which position you most agree with. If you are on the receiving end of the output, you may find it helpful to know what is being discussed. I hope this helps.

__________

* Since this post, like my earlier one, reports on the deliberations of an ISO Technical Committee, and since I am a member of the American TAG 176 which forms a component of that committee, allow me to repeat the formal regulations that apply to this discussion.

  1. I'm not allowed to reveal the personal data of any other committee member. But that's fine, because I have no interest in talking about individuals. My topic is always the ideas and principles.
  2. I'm not allowed to reveal how any particular individual or National Standards Body voted. But that's fine too. See above.
  3. I'm not allowed to share any presentations or working documents. But I never planned to. If you find such materials anywhere on the Internet, they didn't come from me.
  4. am allowed to share my personal opinions, so long as I clearly identify them as such (and to be clear everything in the body of this post is hereby identified as a personal opinion), and so long as I don't criticize the committee. But that's fine too, because you should absolutely not take anything I say here as a criticism of the committee. I am confident that the committee will do the best it possibly can, given the parameters that it has to work within.

** I didn't even get past the 2xxxx's.   

     

2 comments:

  1. Be very careful putting any socially/politically charged language into the QMS Standard. The vast majority of business that are the users of this standard are in business to make a profit. If this language is mandatory, then I think there will be detrimental impact to certifications. Regulatory agencies better equipped to take this topic on. Stretching a QMS standard to include climate may have a boomerang effect.

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    Replies
    1. You won't hear any argument from me. In fact it sounds like you've read my post from last fall, where I argue something very similar: https://pragmatic-quality.blogspot.com/2022/10/can-iso-9001-stop-climate-change.html.

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