Organic to be sound and sensible

farmers have reported spending more time completing forms and maintaining records. A certain amount of records are essential to ensure organic farmers are meeting the organic standards, such as planting non-genetically modified seeds or raising dairy cattle on organic pasture. But, too much focus on paperwork can detract from farming activities that support organic principles, such as conservation and cycling of resources. - See more at: http://blogs.usda.gov/2013/04/19/organic-101-sound-and-sensible-approach-to-organic-certification/#sthash.eV7lihko.dpuf

farmers have reported spending more time completing forms and maintaining records. A certain amount of records are essential to ensure organic farmers are meeting the organic standards, such as planting non-genetically modified seeds or raising dairy cattle on organic pasture. But, too much focus on paperwork can detract from farming activities that support organic principles, such as conservation and cycling of resources. - See more at: http://blogs.usda.gov/2013/04/19/organic-101-sound-and-sensible-approach-to-organic-certification/#sthash.eV7lihko.dpuf

farmers have reported spending more time completing forms and maintaining records. A certain amount of records are essential to ensure organic farmers are meeting the organic standards, such as planting non-genetically modified seeds or raising dairy cattle on organic pasture. But, too much focus on paperwork can detract from farming activities that support organic principles, such as conservation and cycling of resources. - See more at: http://blogs.usda.gov/2013/04/19/organic-101-sound-and-sensible-approach-to-organic-certification/#sthash.eV7lihko.dpuf

farmers have reported spending more time completing forms and maintaining records. A certain amount of records are essential to ensure organic farmers are meeting the organic standards, such as planting non-genetically modified seeds or raising dairy cattle on organic pasture. But, too much focus on paperwork can detract from farming activities that support organic principles, such as conservation and cycling of resources. - See more at: http://blogs.usda.gov/2013/04/19/organic-101-sound-and-sensible-approach-to-organic-certification/#sthash.eV7lihko.dpuf

"Farmers have reported spending more time completing forms and maintaining records. A certain amount of records are essential to ensure organic farmers are meeting the organic standards, such as planting non-genetically modified seeds or raising dairy cattle on organic pasture. But, too much focus on paperwork can detract from farming activities that support organic principles, such as conservation and cycling of resources." writes the head of the US National Organic Program Miles McEvoy explaining the administrations ‘Sound and Sensible’ initiative*.

An article by Grace Gershuny in the latest issue (#146) of The Organic Standard, describes the background to this awakening. The new orientation was partly a result of a white paper by the IOIA  developed at the request of NOP. This in turn was prompted by the receipt of a memo on the subject of ‘Opportunities for the Organic Program - Practices, Not Paperwork’, submitted by Jake
Lewin, Chief Certification Officer of California Certified Organic Farmers (CCOF) in November 2012. CCOF says: 

“over the last 10 years we have observed the evolution of the accreditation system: concepts that were written into the NOP standards have driven some certifiers towards paper-heavy practices that may act as barriers to success for operations”

I will not go into the technical details here, just want to express my support for these efforts. I find a specially rewarding that in the letter from CCOF to NOP that triggered this development, Jack Lewin refers to my presentation at Biofach 2012. "The core of the problem is that through a reliance on third party auditing theory we have over emphasized process and paperwork instead of fundamental organic practices".


I have written many blog posts about this and related topics before:
Quality management is a management fad elevated to divinity
Organic certification - Is it worth it?
Where does the buck stop?
The danger of predictable procedures
Standards as tools for power
How quality Management can result in low quality....
What gives value to an eco label

*Five Principles of Sound and Sensible
Efficient Processes: Eliminate bureaucratic processes that do not contribute to organic integrity.
Streamlined Recordkeeping: Ensure that required records support organic integrity and are not a barrier for farms and businesses to maintain organic compliance.
Practical Plans: Support simple Organic System Plans that clearly capture organic practices.
Fair, Focused Enforcement: Focus enforcement on willful, egregious violators; handle minor violations in a way that leads to compliance; and publicize how enforcement protects the organic market.
Integrity First: Focus on factors that impact organic integrity the most, building consumer confidence that organic products meet defined standards from farm to market

Don't cry for ISO 9001

In 2011, global uptake of ISO 9001 falled. There is just above a million firms certified to ISO 9001 globally. There have been marked drops in the uptake in North America and Europe lately. In Europe almost 40,000 fewer companies were ISO 9001 certified 2011 compared to 2010. In North America the number dropped from a high of 61,000 (ISO 9001 was never that big in North America) in 2006 to just 37,000 in 2011.


Also for the rather new ISO 22000 standard there seems to be little interest.

I will not shed any tears over this as I consider the systems being hyped and sometimes even counterproductive. See my earlier posts on the matter.


Quality management is a management fad elevated to divinity
How quality Management can result in low quality....
What gives value to an eco label

Read the whole ISO 2011 survey here 

And check Dilbert's view here:
Dilbert explanation 1
Dilbert explanation 2

Update: 26 February: It seems like all companies implicated in the horse meat scandal in Europe have had their ISO 9001 certificates...

 

Quality management is a management fad elevated to divinity

Every second shipment was delayed and the invoices were never correct. Those were the experiences I had as a client of one freight-company in Sweden in the late 1980s. What was special with this company? They were pioneers in the implementation of an ISO 9000 certified quality management system. 

When I first implemented a quality management system some 23 years ago, it was new and fresh, and seemed like a good idea. I mean, who could possibly oppose a focus on quality, and approaching quality in a systematic way through a management system? The approach really suited my personality of an introvert system designer. Just write down how things should be done; do; check that it is working and revise if it isn’t; then repeat the cycle. However, over the years I have grown more and more cynical about the use of such systems, and in particular how the belief in them is like a dogma that can’t be questioned.

What is a QMS

There are many definitions of quality management systems (QMS). It can be ‘A set of coordinated activities to direct and control an organisation in order to continually improve the effectiveness and efficiency of its performance’. Alternatively, it can be “A system by which an organisation aims to reduce and eventually eliminate nonconformance to specifications, standards, and customer expectations in the most cost effective and efficient manner.’  The latter is at least a bit more modest about what a QMS can deliver, or should deliver.

In my view, the time is overdue to challenge this management idea, to expose it as just another fad, loaded with jargon and promoted by a hoard of consultants (including myself), certification bodies and accreditation bodies who earn their living from it. My objections to it are based on two different issues; on the one hand it is based on some erroneous principles or assumptions and on the other hand, even if it were useful, the positive effects are not big enough to justify the energy spent. What I am discussing here is quality management as a management principle. Clearly, I have no objections to quality, how could I? After all, quality is anything you define. I also have no objections to ‘management systems’, how could I? All organisations are managed according to one or the other system, documented or not, good or bad. But those who have spent weeks writing manuals and training staff etc know what I am talking about, the quality management system (QMS).     

Proudly certified!

The main standard for quality management is the ISO 9000 standards. ISO 9000 was first published in 1987.  It was based on the BS 5750 series of standards from the British Standards Institute. However, its history can be traced back some twenty years earlier to a US Department of Defense standard in 1959, which was aimed at ensuring bombs go off at the target and not in the hangars or in the factory – a laudable effort (not for the targets, though). The concept of the ISO 9000 has spread into a wide range of other standards, such as the ISO 14000 series for environmental management, the ISO 22000 for food quality management and the ISO 65 for certification bodies and ISO 17011 for accreditation bodies.

Despite its rapid uptake in various industries quality management is not a proven method. Agreed, there are many reports and statement from quality managers, and consultants and certification bodies about how good quality management is. However, very little peer-reviewed research has been conducted that evaluates whether the system delivers what it promises to do, that is, consistent quality. And there has been even less work done to prove that it delivers general management benefits, which proponents claim most often. One study in Australia and New Zealand did look at the effect of ISO 9000.¹ The central finding of the project was that ‘on average ISO 9000 certification has little or no explanatory power of organisational performance.[1] Another study reports that ‘However, surprisingly no significant difference is found with respect to defective part production and manufacturing cost between the two groups [those who had a QMS and those that hadn’t].’[2]

We are told to put quality first, but what does that really mean? Is quality more important than following the law? How does it relate to workers’ safety, the environment or, the most obvious factor in organisations, profit? The quality management culture is based on the fact that there are special quality manuals and a special quality system. But organisations are not managed by these kinds of manuals, and controllers and financial departments work with a different logic. Where does that really leave quality management? Instead of acknowledging the contradictions and different interests in an organisation, QMS proponents spread the illusion that the QMS is the most important part of the management system, which is at best delusional.   

The starting point in the development of a quality system is, almost exclusively, the standard itself, and all the issues required by the standard. This is in itself a very bad starting point. ‘Planners of quality systems, guided by ISO 9000, start with a view of how the world should be as framed by the Standard. Understanding how an organisation works, rather than how someone thinks it should, is a far better place from which to start a change of any kind’ says British management consultant, John Seddon.

QMSs are based on a view that people perform better when told what to do, rather than when they are given freedom and motivation. They exaggerate the use of written instructions at the expense of social interaction and continuous problem solving. This degrades people to automata, a development that risks the quality in their work and ultimately the performance of the organisation.

Even good systems take considerable time and energy to implement. Consequently their implementation competes for resources and attention, resulting in less energy and attention orientated to other (real) problems within the organisation. In addition, QMSs discriminate against small firms as they are more costly to implement while the potential benefit is even less than in a big firm.

While a well functioning QMS might be good for operations, they are often badly designed and implemented, and thus are likely to do more harm than good. An organisation with shelves full of files telling people what to do and how to do it, with a workforce that disregards the policies, is worse off than a company with very few policies, which are vigorously enforced and promoted, and grounded in the organisation’s culture. Many organisations implement a QMS because they ‘have to’ – as a result of demands from the clients or from other outside parties – and not because they see the value of them. Again a very bad starting point for good implementation.

And finally, there are the audits of quality management systems. The actual quality of the product or service is not included in an audit or assessment. Auditors look into systems, procedures and organisational structures, and very little at implementation. Increasingly, audits look at ‘meta-systems’, that is the systems used to develop and maintain the system, for instance, internal audits. Here it follows the footsteps of financial audits, which also has gone from checking the actual books, stocks and assets to auditing the system. This has been well analysed, and criticised, by Michael Power in the book Rituals of Verification. Power says that most effort is actually spent on making the systems auditable, and not on making them reliable.

In the organic sector, where I have a lot of first hand experience all from farming to accreditation of certification bodies, conformity assessment has moved towards focusing on ‘auditable performance’. Quality management is enforced all along the food chain, from the accreditor to the farms; every level expects the next level to implement a QMS. QMS in accreditation demands QMS in certification, which in turn demands QMS on farms. On the farm level this is not as yet formulated in demands for fully fledged QMS, but the tendency to enforce QMS style demands on farms and even more on food processors is clear. Real control is rarely made – this was pointed out in a recent report by the European Court of audits of the EU control systems, and it was pointed out by the Swedish Food Authority some years ago. It is clear that audits don’t address, detect or prevent fraud to any larger extent. When blatant mistakes are made – if the mistake is even detected – the “corrective action” is mostly to insist on more quality management policies or written procedures, which are actually counterproductive.

In certain situations a QMS can be useful, even very useful, for organisations, but that does not imply a QMS is good for all organisations. Nor does it suggest that a functioning QMS contributes to the integrity of the system in general. Instead they should be seen as one of many tools organisations use to manage themselves and the service they offer; a tool that suits some much better than others because all organisations differ in size, culture, resources and stability.

Footnotes:

1. The Business Value of Quality Management Systems Certification. Evidence from Australia and New Zealand,  Samson, D. Terziovski, M. Dow, D. Journal of Operations Management Vol. 15, No. 1, 1997, pp. 1-18

2. The impact of ISO 9000 quality management systems on manufacturing, Tufan Koc, Journal of Materials Processing Technology Volume 186, Issues 1–3, 7 May 2007, Pages 207–213

Swedish article about the quality management craze:
Update: 22 January, I have another article about quality management published in Svenska Dagbladet (Swedish).

How quality Management can result in low quality....

"In 2004, a new FSC [Forest Stewardship Council] accreditation standard was introduced in order to bring FSC’s certification system in accordance with ISO’s international standards for certification. Now after 6 years there is clear evidence that this ISO-fixation is undermining the integrity of the FSC system, by shifting the focus away from improving field performance to evaluating systems. Stakeholders, however are not interested in systems, but verification that good forest management is happening and that claims are really trustworthy."

writes Peter Feilberg, CEO of NEPCon in a recent post.  

I concur in his critical view on the ISO "quality management systems approach".In theory it sounds good, but the reality is quite different. 


Micheal Power has written a book: The Audit Society: Rituals of Verification which draws largely from financial audits. His conclusions are largely that the audit explosion is driven by vested interest and a failed attempt to minimize risk by focusing systems rather than actual performance. (a review of the book can be found on http://www.developmenteducationreview.com/issue11-review2 )

I have myself criticized the ISO inspired development of organic certification for almost twenty years now. And it is certainly an area I have a lot of insight in. I have helped a handful organic certification bodies to get accreditation and helped another handful to install "quality management systems". I have also worked as an auditor for the same period of time. I summarised some impressions of the accreditation process in a Leader in The Organic Standard November 2009

How valuable is accreditation?
A survey on accreditation, recently conducted by TOS, shows that there is considerable discontent with how accreditation systems are operated. In particular, respondents criticised national accreditation bodies within the EU for their high fees, the poor correlation between fees charged and work done, bad service and the low level of competence. Compulsory accreditation for organic certification bodies is fairly new in the EU system. The EU has maintained a policy of national monopoly in accreditation. The logic behind this policy is that if there was competition between accreditation bodies, a super accreditation system would be needed to monitor them – another body that determines which are reliable. Many question the wisdom of this monopoly. A critical voice in the TOS survey described the EU model as having ‘only God above the accreditors and God doesn’t care a lot about accreditation’.

Controversially, the EU has never been able to explain why a single monopolistic accreditation body is more reliable than competing ones. Admittedly the accreditation bodies have a certain self control, peer-review, in the International Accreditation Forum. But it is hard to understand why the EU policy can accept the  relevance of peer-review on the accreditation level and not on the certification level? All the arguments for maintaining an accreditation monopoly can be applied just as well to certification, making accreditation itself redundant. There is one question that was never asked, and which the TOS survey did not answer: ‘is there value in the accreditation?’. Such a question has many facets. One is whether accreditation is of direct value to the development of the organic market. Most likely the answer to this is ‘no’. Consumers have no understanding about these issues, and the fact that the certification body is accredited is of no relevance in the marketplace.

Regarding competition between certification bodies, in situations where accreditation is not compulsory, accreditation might bestow a certain market advantage. This would not be towards consumers, but towards the clients, who might want to know that their certification body is reputable and reliable. IFOAM accreditation has its main function here. If accreditation improves the credibility and reliability of the certification process it might have long-term positive effects. But in reality does it? We do not know. It is obvious that some kind of supervision of certification organisations provides a certain guarantee against direct fraud, but it is an untested assumption that accreditation is the most efficient process. Other untested options include direct control by the authorities and a peer-review system, or even much simpler measures such as increased transparency in the certification process.

One aspect that influences the reliability and usefulness of accreditation are the norms that are the basis for accreditation. The norms currently in use, such as the ISO 65, have been developed with quality management systems as models. However, it is not difficult to find ISO 9001 certified companies that offer very poor services or produce inferior products, and it is not difficult to find ISO 14001 certified companies that are damaging their environment. It is also not at all hard to find ISO 65 accredited certification bodies that are doing a bad job and whose certification decisions are dubious. The TOS survey indicates that part of the problem might be the competence of the accreditation bodies to interpret the norm. But the problem is probably deeper than that. The adoption of the quality system model in organic certification has hardly led to a measurable increase in reliability. At least thereis no research to support the claim – admittedly there is also no research that points to the contrary. While a quality management perspective and procedures certainly can be valuable, there are three disadvantages. First, these systems are resource-intensive, and to design, implement and maintain such a system would take a lot of resources away from other necessary work. Secondly, attempting to correct everything by stressing the system and the procedures disregards the human factor. It expresses a view of humans as automata. But we are not that, and real people simply do not always follow procedure. Sometimes they cheat and other times they have a bad day. Finally, a quality management perspective takes the focus away from what is actually happening and emphasises the written plans and procedures. The accreditation process is mainly designed to identify missing policies or procedures and not to detect faulty certification decisions, or sloppy inspections. The focus on the quality management system needs to be put under scrutiny, and those that promote it should come up with evidence that it delivers what we want at a reasonable cost.
(from The Organic Standard)

What gives value to an eco label

ISEAL, recently came out with an interesting report, the ISEAL 100 survey. In it we can read the views of 100 "thought-leaders" on environmental and social standards. One chart that struck me was this.

So the view of the users (i.e. companies) of these systems is that most important to create trust in a standard is: verification processes, including accreditation and third-party certification (55%);
a standard document at just the right level (science-based, comprehensive, practical) (38%);
a credible multi-stakeholder standard-setting process that has the support from all relevant parties – NGOs, producers, companies (35%),
a transparent governance model (32%);
and being able to show impacts (11%).

I found this discouraging and it strengthen my view that the people involved in the "sustainability industry" (folks that are environment, CSR managers, employees of certification and standardization bodies, consultants like myself, international NGO or international organisations) are losing the grip of what is important, the impact. The "worst" case is the ISO "management" standards (ISO 9000, ISO 14000 and ISO 22000), but their thinking has spread all through the systems. In some cases this is just a result of more or less intentional green-washing, but in most cases, I believe it is a result of application of the same kind of industrial, standardized and simpleton thinking that brought us the problems which were to be solved.