While all in the quality service sector and in industry recognize the inconvenience and anomalies that can be created by differing interpretations of standards (ISO 9001, QS 9000 & 14001) am I alone in expressing concern about "Interpretation Committees"?

I read with some dismay that national standards bodies (ANSI in the USA) are to make interpretations of ISO 9000, referring back to an international sub-committee of ISO TC 176 where necessary. (This is an escalating trend following the US TC 207 sub-tag group for ISO 14001 interpretations and the IASG group for QS 9000 interpretations). Since QS 9000 comprises essentially contractual requirements and has some unusual twists, an interpretations committee may well have been justified to assist with the fast-track process. But when it comes to international standards, I for one, want to be in on these processes! In the grand scheme of things, one person's input may not count for much, but who gives the authority to a handful of people on a financial implications for everyone working with the standards?

Up to this year, it was my understanding that the requirements and interpretations of international standards were established through a meticulous, international consensus-building and public comment process. The wording of international standards produced through this process are no accident and, in some cases, are deliberately vague to accommodate a wide range of users and/or international acceptability. Furthermore, a second opportunity (and even a third in the case of the ISO 14001 Annex A) is for the standards writers to explain the intent and application of the standards through related "guidance standards".

Most would agree that international standards should be evolutionary and, following final publication, it is certainly time for the standards-writers to take feedback from users (implementing organizations, consultants, auditors and other interested parties). In my view, however, that feedback should be used to strengthen future versions of the standards and, before hasty interpretations are made, the additional material (which they inevitable contain) should be subject to the same international review process with all interested voices heard - Design/document control !!! ???
;)

For those who may still be missing the point here, please consider the following:

1) The established process has already worked (largely successfully) for the 1994 revision of the ISO 9000 series standards.

2) Small groups are invariably heavily influenced by one or two "special interests"

3) The profiles of individuals on committees are frequently those of people some distance from the reality of making the standards work in practice, (i.e. Theorists rather than Practitioners)

4) Different national committees will quickly generate conflicting interpretations

5) The registrar community has been down this route in the past - as soon as interpretations are committed to text, the exception to them arises. (No small group has the ability to foresee how a generic standard may be used in practice.)

6) Following 5) above, interpretations have to be revised (to the disdain of all)

7) Following 5) above, in many cases, interpretations of interpretations become necessary

8) Interpretations need to be controlled and widely distributed in a timely fashion. Someone is going to end up paying the costs associated with this. If interpretations are frequently issued, invariably not all parties will be up-to-date.

9) Interpretations have to be considered for the next iteration of the standard in any case

And I'm sure that debate among the group will add significantly to this list!!!

In summary then, if anyone putting these "interpretations committees" together happens to read this, please add my name to your list of candidates Not to mention 20 or 30 thousand other "practitioners" worldwide) so that we can stay within the bounds of a consensus process.

John Brookes
SGS ICS Inc., Rutherford, New Jersey

Disclaimer: The views represented above are my personal concerns and in no way reflect the position or opinion of my employer or any associated company.

--------------------------snip---------------------------------

From: "JBSGS - aol.com"
Subj: RE: COMMENT:Interpretations/Bigelow

I thank Mr. Bigelow for his quick response and input on this issue. However, it does little to alleviate my concerns, or those of group members who e-mailed me privately with their support.

I believe three points from the posting require further clarification.

1) Mr. Bigelow writes..

"interpretation ... obtaining broad user inputs, and also obtaining "expert" inputs (ie those involved with the writing of the standards)."

Although I agree there is "expertise" amongst the standards writers, they should not consider themselves "experts". Despite the efforts of ISO/ANSI etc. to achieve representative input from "interested parties", the profile of technical committee membership reveals a heavy bias toward representation from larger organizations in the manufacturing sector - not necessarily representative of the interpretations needed for ISO 9000 today. Compound this by the fact that representatives (and/or their employing organizations) on an interpretations committee would have to devote further resources to the activity and there is an increased probability that "special interests" and self-serving individuals will prevail. "Expertise" within such a committee should extend beyond Technical Committee membership to include those who have first-hand experience of working with the standard from different angles across a broad range of industries in the "real world". Lastly, in the grand scheme of things, even with a broader membership base, the "expertise" of any handful of people is inevitably very limited.

****************

2) (Bigelow) "You mention that registrars are interpreting the standards today. That is one of the reasons we are putting an official process into place. Registrars shouldn't have to provide interpretations."

In the absence of clarity from the standards writers, authors, consultants, registrars and others have indeed made both "sweeping" and specific interpretations of the requirements of ISO 9001/2/3 & ISO 14001. I do not wish to imply for one moment that that it is the job of registrars to interpret the standard, (As already said, we've been down that route and it is ineffective, creating more problems than solutions). The job of the registrar auditor is to analyze and evaluate OTHERS' interpretations of the standard as they apply to a particular organization. The interpretive variations are limitless, and I therefore question the value of interpretation committee outputs, i.e. either..

a) They're so vague that they add no value to the process

or

b) They're detailed to the extent that they become a burden for industry and micro-manage/usurp the professional skills, responsibilities and innovation of industry professionals, consultants and auditors.

Without question, bad interpretations and decisions regarding interpretations have been made by quality professionals in industry, consultants and auditors. In my professional capacity I have been at the sharp end of this for twelve years, but I do not believe that the situation (with ISO 9000 at least) is so endemic as to warrant the interpretation committee process now being promulgated as a (perceived) solution.

Nobody can question the market need for interpretation of the principles of generic management systems standards. Appropriate interpretation is the essence of an effective and efficient quality (environmental) management system. This is why there are so many consultants and authors out there. All I question is the "interpretations committee" mechanism and its ultimate value or cost.

***************

3) (Bigelow) "TC 176 decided that the right way to have the national bodies field the interpretations requests, propose national interpretations, and pass the request & interpretation on up to TC 176 international. These member body inputs would be aggregated and then an international interpretation adopted.

Given that "interpretation committees" appear to be imminent, I'm pleased to see Mr. Bigelow reports that ISO and TC 176 are considering consensus-building processes (within the TAG or Sub-TAG at least) and/or an internationalization of interpretations. Even such a limited process would, of course, be relatively slow if it were ever effectively implemented. The slower the process, the less value to real-world users of the standard and the stronger the argument for issues to be dealt with in the standards' next revisions. (The vicious circle recognized in Mr. Bigelow's submission)

Unfortunately though, the above statement is at odds with information I'm receiving from other sources (parent group, press and accreditation bodies). These sources say that issues will be raised to international level only "when considered necessary" and the need for/mechanism of any consensus-building process (if any) has not been established. In this scenario, presumably the interpretation committee makes a determination as to whether consensus-building or international interpretation is required??.

In summary then, it is a noble thing that is being attempted. I do not wish to derail the process IF the process outputs satisfy a genuine need and add value to one and all. I merely wish to raise awareness of the issue, forewarning of the pro's and con's of the approach being taken and the vast negative implications of (potentially) inept interpretations.

John Brookes
SGS ICS Inc., Rutherford, New Jersey

Disclaimer: The views represented above are my personal concerns and in no way reflect the position or opinion of my employer or any associated company.

------------------snip----------------------

From: "Bill Cox"

Regarding the question of whether national ISO interpretation committees is a good idea... Seems to me there is an analogy in the legal system .

First, we have the standards-writers (legislature).

Then, there are the implementing organizations - individuals and orgs. trying to interpret and follow (sometimes skirt) the law. Next there are the consultants (lawyers... ).

Then, the registrars (judges). What a mess *that* system is! The standards/laws are written in generic and obscure language, raising issues of interpretations in areas not even dreamed of by the lawmakers.

The lower courts (registrars) make their decisions, and there is an appeals process, ultimately to the supreme court. Similarly ISO registrars' decisions can be appealed first through their own management and ultimately to the accreditation body (a national body).

There is not really a current mechanism to get an international ISO/Geneva ruling, except perhaps through the tedious TC-176 process on a 5-year cycle. Meanwhile, law-abiding citizens are left to their own devices to do their best to understand and comply with the requirements. Then, look at the confusion raised by differences in laws and interpretations in different cities, states and countries. ISO 9000 has gone a long way in removing a lot of these discrepancies, but interpretations committees will move in the opposite direction, I fear.

So, what can we learn from this eerie analogy?

Bill Cox
TQM Consulting

--------------------snip----------------------

From: "Bill Cox"

Quoted from Brookes:

Most would agree that international standards should be evolutionary and, following final publication, it is certainly time for the standards-writers to take feedback from users (implementing organizations, consultants, auditors and other interested parties). In my view, however, that feedback should be used to strengthen future versions of the standards and, before hasty interpretations are made, the additional material (which they inevitable contain) should be subject to the same international review process with all interested voices heard - Design/document control !!! ???

-----------------------------------

Mr. Brookes,

First of all, thank you for your contribution... as an individual of course, but nonetheless one who works for a major registrar. Secondly, you've got it just right. IMHO the QS-9000 interpretation process is a building disaster... one that ISO doesn't need. I won't reiterate your points...you've already given about all the reasons I could come up with.

Bill Cox
TQM Consulting

-------------------snip--------------------------
From: "Jim Bigelow"

As a member of ANSI Z1, the US Tag to TC176, and the US committee that is developing a US interpretations process, let me address some of Brooke's concerns on Interpretations for the ISO9000 family.

ISO Geneva asked TC176 to develop a pilot interpretations process and test it for 2 years at the international level. It is my understanding that ISO has not done this before. TC176 decided that the right way to have the national bodies field the interpretations requests, propose national interpretations, and pass the request & interpretation on up to TC 176 international. These member body inputs would be aggregated and then an international interpretation adopted.

We are in the process of developing a US pilot and we are comparing notes with the Canadian and Australian member bodies which already have processes in place.

One of our concerns are the tradeofsf between providing a timely interpretation, also obtaining broad user inputs, and also obtaining "expert" inputs (ie those involved with the writing of the standards). We don't have all the answers yet (and maybe not even all the questions), but one consideration is to ballot the draft interpretations through ANSI A1 and/or USTagTC176. This would obtain fairly broad industry and user input.

Our goal is "simply" to interprete the standards in the family, not to rewrite them or add requirements or guidance that wasn't there at all. You mention that registrars are interpreting the standards today. That is one of the reasons we are putting an official process into place. Registrars shouldn't have to provide interpretations.

Hope this helps some.

Jim Bigelow

--------------------------snippo---------------------------------

From: "Jim Bigelow"

Jack West is chairing the USTag TC176 committee that is deveolping a US ISO 9000 family interpretations process. After I forwarded him some of the discussion we having been having, he sent me the following message. I'm posting it to the discussion group so all interested parties can read it. Jim Bigelow

RE: Re: COMMENT:Interpretations/Cox

Sender: JWest

In a message you forwarded to me dated 97-01-10 22:06:34 EST, somebody writes:

<<From: "Bill Cox"

Regarding the question of whether national ISO interpretation committees is a good idea...>>

JIm,

I think, from what I see, the discussion on interpretations is getting out of hand. Don't these guys know that we are not talking about establishing an Interpretation Committee; at least not one that is independent of the standards writing bodies. Don't they realize that under the ANSI system, technical committees already have the responsibility to interprit their documents. Don't they know that we get asked questions as to meanings? I am a great believer in discussion and I agree with a lot of the points but most of what I have seen is just a bunch of frustration about the realities of any standard. I would ask what these guys propose as a solution to the following:

-First, AQQC and the member of its Standards Group frequently get asked for interpretations. Currently there are only informal means to provide these answers.

-Second, by not having a process for interpretations, the Standards Group cold be said to actually be failing its responsibility to ensure that interpretations are rendered in a consistent manner.

-Third, I know of nobody who wants a legalistic, bureaucratic process for getting questions answered; yet some degree of consensus is necessary. Given this, some degree of formality would seem to be necessary.

-Fourth, there is very little in the way of process for ISO/TC176 to actually get specific feedback as to things that need to be changed. Individual participants and national delegations have opioions; some grounded in fact tohers in opinion. A formal interpretations process could---if properly constituted---be part of a solution to fill this real gap.

None of the above addresses the clear need for a process in which registrars can get consistent interpretations. In face, individual registrars will always have their own opinions as to how clients should implement the standards. Also interpretations as to how to apply the standards in a particular industry may vary. The International and National bodies really cannot answer these types of issues unless they are posed in completely generic terms.

The legal system analogy may sound nice but we need to recall that the ISO system is essentially voluntary. While registration may be a condition of market participation (in a very few cases, it really is), even the participation of an organization with a particular registrar is quite a matter of choice (at least this is generally so in the US).

We should always be open to dialog and debate. In fact, what we need is constructive input! A forum conducted outside the TAG to TC 176 process is OK but it is absolutely worthless unless the participants are willing to summarize their input and get it to TAG leadership.

By the way how do you get to the UW Stout discusison group? I have tried (some time ago) to get there from their UW Stout home page but with no success.

Regards,

Jack West
Vice Chairman, US TAG to ISO/TC176

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