The ‘context’ of Context has changed

In December 2016, I published a LinkedIn article about the new requirements in ISO 9001:2015 for an organisation to look inwards and outwards to interested parties and their needs and expectations. ISO 9001 is now being revised and will include any revisions to the new harmonized structure (the current preferred term, previously known as the high-level structure, Annex SL, Guide 83 etc., etc.).

The next edition of the world’s leading management system standard (MSS) will incorporate all the changes in the new TMB clauses plus any additions that TC 176 wants to make. In the interim, there is one change that users of ISO 9001 will have to start to consider long before the next edition is published, planned for 2025. In January 2024 ISO wants to incorporate an amendment to all MSS for users to incorporate in their management systems. The details of how this will be implemented across the affected standards and the organisations certified to those standards are not yet public.

The text of the amendments is, however, known and the context for the change to ‘Context (ahem) is covered in an ISO/TMB/JTCG page describing the change, here.

Focusing solely on the users of ISO 9001, I thought it might be helpful to provide some practical examples of how a user can use their existing processes and cover the new requirement.

Taking from the JTCG page, the two additions to the current text in Clause 4 for MSS will be:

4.1 Understanding the organization and its context:

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

4.2 Understanding the needs and expectations of interested parties

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

Notes are not requirements in MSS and therefore are not subject to audit. The new note may help to influence how the organisation chooses to operate in future. More later.

All organisations using ISO 9001 now have to ensure that they ask this question when addressing their context. If you already use strategic planning tools such as PESTLE analysis, then you will already be considering the Environment, including climate change, when determining your mid and long-term plans. In this case, you will likely be able to satisfy any external assessment that the new requirement is already being met. If an auditor has any concerns, it is their responsibility to identify any weakness in your approach or the implementation and to convince you that their concerns are both relevant and factually correct. Anything that starts with ‘I think …’ does not result in a nonconformity.

If your current strategic planning process does not consider climate change then you have a little more work to do and it starts with asking the question: ‘Why do I think that climate change is not relevant to my organisation?’ If the answer to the question is ‘I don’t know.’ Or if the answer doesn’t sound plausible then it is worth getting the team together that did your original research, ask them the same question and get them to make the case for any changes to your strategic plans.

At the end of this process, you should have a story to tell your external auditor and perhaps some evidence of a change of direction or tactics. The areas of relevance to you are typically in the area of supply and distribution networks. Any disruption to either network through transport disruption is likely to affect your ability to meet your commitments to supply customers and distributors. Similarly, if your operations are in areas that could be affected by extreme weather and/or rising sea levels this could affect employees’ ability to travel to work. This could be part of your strategic assessment.

If you are confident that climate change is not relevant to your approach to managing quality then you should be able to clearly explain this to an external auditor. Often the reason for a lack of relevance is either the organisation’s customers or users are not expressing their opinions on climate change or the organisation cannot influence its supply network for reasons of relative power. This topic is covered in Porter’s Five Forces of Competition.

Taking the customer side of the interested parties and noting the Note in clause 4.2, if your customers or end users are not pushing you for action on climate change then it is entirely appropriate for you to say that this is why you are not doing something with your quality management system about climate change. If you have no significant influence on your supply and distribution networks then that, too makes climate change not relevant to your approach. As an example, if you are buying raw materials or components from a supplier larger than you, you will be unable to influence their behaviour. If you are a small supplier to a high-street retailer then you will be unable to affect the resilience of their supply chain.

There are many concerns that the new requirements for climate change will affect the third-party certification processes. These concerns can be broken down into these two areas:

• Auditor competence - how will auditors be able to determine whether an organisation has done enough to satisfy the new requirement in ISO 9001 (for example)? Do they need to understand the causes and effects of climate change to be able to evaluate the effectiveness of systems for each of the organisations that they are assessing? All CBs will need to understand the new elements of context that climate change brings. There is an argument that many third-party auditors do not understand enough about an organisation’s context as it stands and this will create another layer of incompetence.
• Scope creep - does the addition of climate change give auditors the freedom to audit other areas of environmental management? All CBs will have to spend more time and effort in ensuring that auditors ‘stick to their lane’ when auditing a quality management system. Again there is much anecdotal evidence of auditors following trails into areas that are not covered by their audit scope and spending time evaluating an organisation’s occupational health & safety, information security, etc. system. All the time not spending that time in auditing the quality system as the organisation and its customers would expect.

Whatever your view of the rights and wrongs of a requirement for climate change being added to a quality management system standard we must ensure that this particular change does not adversely affect the climate that users of ISO 9001 enjoy! At the same time, we can look forward with hope to the contribution of a greater awareness of the subject among the quality fellowship.

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