Volume 6 · Issue 12 · December
Only 3 Votes of DISapproval But Comments Show DIScontent
ISO/DIS 19011 Obtains 90%+ Approval; Elevation Uncertain
On October 31, 2001, balloting of the Draft International
Standard (DIS) on environmental auditing (EA)/quality auditing
(QA) concluded with more than 40 votes of approval and 3 votes
of disapproval. Japan and Singapore joined the United States
in casting the only votes of disapproval among the participating
member bodies (P-members) to ISO Technical Committee (TC)
176 Subcommittee (SC) 3, responsible for QA standards, and
TC 207/SC 2, responsible for EA standards.
For TC 176/SC 3, 43 P-members voted to approve the DIS, 3
voted to disapprove and there was 1 abstention (Portugal).
For TC 207/SC 2, 40 P-members voted to approve the DIS, 3
voted no and there was also 1 abstention (Hungary).
Despite greater than 93% approval rates, the future of ISO
19011 remains uncertain following the balloting on both the
US and international levels, with the potential for a second
DIS and/or US rejection of the final product.
Part of the uncertainty arises from the fact that this is
the first time the United States has voted to disapprove of
a draft of ISO 19011, Guidelines for quality and/or environmental
management systems auditing, in a formal vote. This is
despite the fact that the US Environmental Auditing/Quality
Auditing Liaison Group, which is made up of members of the
auditing subgroups of the US TAGs to TC 176 and TC 207, has
had the same objections to parts of the draft since the first
Committee Draft (CD).
The US Liaison Group has generally agreed in the past to
keep the drafting process on schedule while working to address
the issues during the drafting and revision work sessions.
Being that ISO 19011 has now reached DIS status, the Liaison
Group felt that it was time for the United States to formally
disapprove of further movement until its concerns are resolved.
Whats more, the US TAGs may be ready to take further
steps if the DIS is elevated without resolving the objections
Normally, a vote of approval of more than 93% on a DIS would
mean that it is headed for easy final approval and publication.
However, ISO/DIS 19011 also received more than 120 pages of
comments. Although the US proposed rewrite of Section 7, Competence
of Auditors, takes up approximately 15 pages in the comments
template, a majority of the 120 pages of comments came from
P-members that voted to approve the DIS.
Initial indications are that half or more of the comments
are technical in nature, not editorial, which is unusual at
the DIS stage. Typically, the DIS ballot allows for comments
of an editorial nature only, because it is presumed the document
has evolved to a point wherein all serious technical issues
have been resolved.
"The ballot results represent a conundrum, because the
vote results and the comments tell two different stories,"
remarked Gary L. Johnson, Environmental Engineer at the US
Environmental Protection Agency, a representative of the US
Technical Advisory Group to TC 207 and a US Delegate to the
Joint Working Group on Quality and Environmental Auditing
(JWG), which is responsible for drafting of ISO 19011.
Johnson, who received the set of comments along with the
other US delegates at the end of November 2001, added, "And
there are almost as many comments on the DIS as were on the
CDs that preceded it."
When the JWG meets January 14-18, 2002, in Vancouver, Canada,
to review the comments submitted on ISO/DIS 19011, the JWG
must address the comments submitted by Japan, Singapore and
the United States with the goal of increasing consensus.
Under ISO rules, the JWG does not have to address the comments
submitted with the votes of approval, since those P-members
indicated approval of the DIS as-is. However, as previously
reported, the JWGs leadership agreed that comments submitted
with votes of approval would be reviewed and addressed in
Vancouver because of the significant revisions contained in
ISO/DIS 19011 and the lack of time at the last JWG meeting
to properly review the proposed DIS prior to its elevation.
This may account for the large number of comments on the
DIS with the votes of approval, although there is no guarantee
that these comments will be addressed. According to Johnson,
the minutes of the meeting in Sydney, Australia, at which
ISO 19011 was elevated to DIS stage, omitted mention of the
agreement by the JWG leadership to address comments submitted
with "Yes" votes.
"ISOs rules say only comments submitted with No
votes are to be addressed, which doesnt mean we wont
be reviewing all the comments submitted, but the JWG leadership
doesnt have to do so," explained Johnson, who added,
"With 120 pages of comments to review in 5 working days,
I would count on two things. First, it will be difficult to
review and address all the comments. Second, it is hard to
imagine that, if we did address many of the comments, we would
be able to elevate ISO 19011 to FDIS [Final Draft International
Standard] stage without an opportunity to review and approve
the revised DIS."
At press time, Johnson and the other members of the US Liaison
Group had not fully reviewed the comments submitted. Therefore,
it is presently unknown whether most of the P-members that
submitted comments agree with the US issues or have other
concerns with the DIS. What the Liaison Group members and
other JWG delegations received were two documents:
- The approximately 120-page comment template containing
all comments submitted in balloting on the DIS
- A smaller document containing only those comments submitted
by the P-members that voted against the DIS.
"This leads me to believe that the leadership may address
the comments submitted with the votes of disapproval first
and then deal with the other technical and editorial comments
as time permits," affirmed Johnson.
He described the JWG meetings as consisting of an opening
plenary meeting at which everyone is present, followed by
working group meetings where the JWG members divide up to
work on specific sections of ISO 19011. These working group
sessions are followed by a concluding plenary at which the
results of the working group sessions are presented to the
full JWG for review, discussion and approval or further direction
to the working groups.
What the working groups will do, if normal procedures are
followed, is receive directions at the full plenary and then
go off to address those comments on the DIS that relate to
their individual sections.
"For instance, the working group that has been drafting
Section 7 will discuss Section 7 issues during that opening
plenary, will obtain direction from the full JWG regarding
how they are to proceed based on the voting, the comments
and the discussion and then go off to address the comments,"
detailed Johnson. "Once they have addressed all the commentsor
when the closing plenary is to beginthey will present
to the full JWG a revised draft section that reflects efforts
to increase consensus."
US Issues, Proposals and Plans
As reported in recent issues of THE OUTLOOK, the
US Liaison Group has identified two key issues that need to
be resolved with ISO/DIS 19011and for which it has submitted
proposed solutions in the US commentsbefore ISO 19011
will have US approval. The two issues are:
- The guidance in Sections 5, Managing an Audit Program,
6, Audit Activities, and 7, Competence of Auditors, is
not appropriate for small to medium-sized organizations
conducting internal audits, only for large audit programs
and third-party registration applications.
- The majority of the DIS is oriented toward the typical
process of establishing and implementing a program of
audits and then carrying out effective audits as a part
of the established audit program. As currently presented
in the DIS, Section 7 is not consistent with that audit
process by both its title and organization. It provides
necessary guidance on an audit programs evaluation
and selection of auditors appropriate for specific audit
assignments and should therefore be reorganized to emphasize
that purpose and titled to reflect the content.
One solution provided in the US comments is a revision of
Section 7 that involves revision and reorganization of the
content to provide consistency with the structure of the other
sections of the DIS and to ensure Section 7 serves its full
purpose of offering guidance on the selection of auditors
for the full range of auditing activities, including internal
and external audits.
The US-proposed revision primarily involves reorganization
of existing text, with some content being placed into Practical
Help boxes, and the addition of limited new text to provide
more balance to ISO 19011s guidance for all types of
audits, not just third-party audits.
Two facts must be kept in mind when considering ISO/DIS 19011
and the US proposal and other comments:
- When TC 176 and TC 207 undertook to create a single
auditing guidelines standards to replace the three EA
and three QA standards, the scope of work established
for ISO 19011 specified a guidelines standard to meet
needs relating to first-, second- and third-party audits.
The six auditing standards in the ISO 9000 and ISO 14000
series are geared toward third-party auditing situations,
while the JWG was directed to develop ISO 19011 to include
the full range of audit types. For this reason, the US
proposal and other US comments seek to balance the third-party
auditing emphasis in the DIS with guidance on internal
and second-party audits. "The internal auditing market
is tremendous and there is a need there for guidance,
even in the United States where internal auditing of management
systems for ISO 9001/2 and ISO 14001 conformance is fairly
well established compared with developing countries,"
commented Johnson. "There is a need for ISO 19011
to address the need for internal auditing guidance, and
that is a US goal."
- The US Liaison Group has for the first time put forward
a proposal that maintains the content of Table 1, Illustration
of Indicators of Education, Work Experience, Auditor Training
and Audit Experience, within Section 7. Previously, the
US delegates have sought to eliminate Table 1 from earlier
drafts of ISO 19011 or relegate it to an Annex out of
concern that Table 1 would become established as a minimum
competency requirement for any and all types of auditing,
even though it is more appropriate to complex, third-party
audit situations. In the proposed revision to Section
7 that the US Liaison Group developed and submitted with
the US comments, Table 1 is placed within a Practical
Help Box within Section 7 to ensure the "illustration"
of competence is seen as an example but remains part of
the text of ISO 19011. Additional Practical Help Boxes
were incorporated to provide illustrations of competence
levels for internal auditors and for external auditors
of less complicated organizations. "There is no guarantee
we will be successful, but I think we have a good compromise
that makes Section 7 clearer and more value-added to the
user and retains Table 1 in the text, which is important
to some countries," declared Johnson. "We should
be able to walk the JWG through our produced replacement
for Section 7 and tweak wording as needed to address needs
of other countries."
According to Johnson and John H. Stratton, a member of the
US TAG to TC 176 and its Task Group (TG) 19011 and a lead
US Delegate to the JWG, they and other US Liaison Group members
have made a limited effort to share the US proposal for Section
7 with other P-members to gauge their reaction and seek their
support. A preliminary scan of the full set of DIS comments
by Johnson revealed that many countries submitted comments
on Section 7, and the expectation is that the US proposal
may receive a positive response from many delegates in Vancouver.
The US delegates to the JWG plan to seek to have a discussion
of Section 7 included in the opening plenary session, since
discussion of the section has regularly been referred solely
to the working group, meaning that many JWG delegates are
not involved in the deliberations on the auditor competency
and audit management issues.
"By having the discussion of Section 7 done in plenary,
so everyone has a seat at the table and has a chance to hear
the full story in detail, the US delegates believe the US
issues and proposal will be understood by those who have only
received closing plenary reports and seen the US comments
in these templates," stressed Johnson. "I think
if it is given proper attention before the full JWG, we can
get things resolved, although that may require everyone to
see another DIS version before ISO 19011 gets elevated to
The Future and Potential Outcomes
Historically, the ISO standards development process makes
it improbable that the JWG will be able during the Vancouver
meeting to address all the comments that have been submitted,
revise ISO/DIS 19011 to resolve those issues found to be frequent
and significant in the comments and provide attendees with
the revised draft with suitable time to review it and determine
whether it should be elevated to FDIS. "I would be very
surprised to see an FDIS come out of the Vancouver meeting,"
"The JWG will go through the DIS clause-by-clause to
review and address the comments, and the working groups have
failed in the past to address all the comments on earlier
drafts. There was one instance where a working group broke
to attend the closing plenary session and then resumed work
the next daya Saturdaybecause they hadnt
had enough time during the week to conclude their efforts.
Clearly, many people had airplane flights to catch, but the
group met that Saturday and Im not sure even then the
work was done at the end of the extra day."
The US Liaison Group is prepared for the following two outcomes
- The JWG will make a concerted effort to address all
the comments submitted with the votes of disapproval and
any comments submitted on the same points with the votes
of approval, but with the expectation that a second DIS
will be necessary. The benefit of such an approach is
that maximum time will be available for revision work
to address all comments, rather than having to save time
so delegates can review the revised DIS and decide whether
to vote to elevate it. The danger is that ISO rules permit
voting on a second DIS but not subsequent substantial
revisions. Instead, if a second DIS were produced but
was not elevated to FDIS, the JWG would have to go back
to the first DIS.
- The JWG will set elevation of the DIS to FDIS status
as a definite goal of the Vancouver meeting and will make
every effort to increase consensus and address the comments,
but not at the expense of delaying release of ISO 19011.
There is an inherent risk in this approach. If many P-members
that voted to approve the DIS did so with the expectation
that their comments would be resolved satisfactorily before
elevation to FDIS and their comments are not resolved,
the actual consensus behind the FDIS may not be anywhere
as strong as in the balloting on the DIS.
With either outcome, the US delegates are prepared to recommend
a vote against a second DIS or an FDIS if the main US issues
are not resolved. "If Section 7 is not moved from where
it is now, both of the US TAGs will most likely vote No
on the FDIS or second DIS, and it will not be accepted in
the United States," advised Johnson. He indicated that
the United States may choose to develop a US auditing guidelines
standard if ISO 19011 does not satisfy US needs.
"Our vision of an auditing standard is slightly different
from ISO/DIS 19011, but we would always prefer to use an international
standard if it meets most of the needs of US auditors and
the organizations that rely on their services," concluded
Johnson. "The difficulty in reducing the number of comments
per draft with ISO 19011 points up the significant amount
of territory and number of issues the JWG has had to cover
because of the function this standard is expected to playinternal
and second-party as well as third-party audits. Even the current
DIS is much improved over its predecessors. Its just
not quite there yet."
THE OUTLOOK will provide a report on the developments
at the JWG meeting in Vancouver in upcoming issues.
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