Volume 6 · Issue 12 · December 2001

Contents

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. What’s more, the US TAGs may be ready to take further steps if the DIS is elevated without resolving the objections discussed below.

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 JWG’s 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.

"ISO’s rules say only comments submitted with ‘No’ votes are to be addressed, which doesn’t mean we won’t be reviewing all the comments submitted, but the JWG leadership doesn’t 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 comments–or when the closing plenary is to begin–they 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 19011–and for which it has submitted proposed solutions in the US comments–before ISO 19011 will have US approval. The two issues are:

1. 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.
2. 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 program’s 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 19011’s 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:

1. 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."
2. 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 FDIS."

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," admitted Johnson.

"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 day–a Saturday–because they hadn’t 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 I’m 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 from Vancouver:

1. 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.
2. 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 play–internal and second-party as well as third-party audits. Even the current DIS is much improved over its predecessors. It’s 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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