The International
Organization for Standardization knows and understands its role: through the
development of standards through a steadfast commitment to consensus, the
organization creates a voice of equality for all its member countries, and establishes
a basis to promote non-barrier trade.
The organization is so committed to the concept that it framed its logo
identification not as a mnemonic by as the Greek root ISO for “equal”. Old stuff but worth repeating, in part
because sometimes this commitment to equality is not always so apparent, unless
excluding developing countries and regions is fully compatible with ISO
equality.
But back to being more positive,
recently an important committee known as ISO CASCO circulated a new document entitled “Conformity
Assessment for standards writers: Do’s and Don’t’s”. Before I continue, a moment of explanation is
in order. When ISO committees write
documents they fall into two main categories; the ones that provide information
on best practices, methods, procedures, and the other ones that provide statements
that can be understood as rules or expectations. The first group are called informative documents, and the
second are called normative documents.
Meeting requirements in
normative documents is known as being in conformance,
and formally demonstrating that conformance is being met both to the word and
spirit is called conformity assessment. So ISO CASCO is the committee that oversees
the rules of creating normative documents and oversees the rules for
organizations that do conformity assessment.
In general there are two
types of business organizations that do conformity assessment; one group calls
itself Certification Bodies, and the other group calls itself Accreditation
Bodies. There are definitions that
distinguish between these two groups (one group says that it measures not only compliance,
but also competency and states that the group only measures compliance), but in
my experience, when boots are on the ground, it is pretty difficult to see real
differences between how the two actually do their assessments differently. One group says that it perceives what it does
is assures a higher level of quality, but from my perspective and experience
that is pretty iffy.
Most importantly for the
present discussion, both AB’s and CB’s are represented on ISO CASCO which means
they are both third party participants in standards application. In order to be seen as not representing one
group over the other, ISO CASCO has created its Neutrality Principle. It is
very important to know and understand what the neutrality principle states and
means.
The Do’s and Don’t’s
document states: “The “neutrality principle” means that the content of the
standard shall not state a preference for a form of one type of assessment over
another. In other words, the standard
must be written so it can be applied by any of the following: - (a) a
manufacturer or supplier (b) a user of purchaser or user and (c) an independent
[third] party. “ This is very
clear. It says that a standard has to be
written in a way that its application is seen to be neutral for all and
exclusionary to none, on the assumption that the assessment is done
competently.
What this says to the
laboratory community is that a document like ISO 15189 can be adopted by any
laboratory, and that laboratory user can assess whether or not it is adopting
the rules in the documents. This is
separate from the process of accreditation.
If you believe in Quality you can apply the document. If you believe that external assessment
improves the degree of compliance, then you can invite an independent third
party to made an assessment over and above adoption.
This is very important to
understand, especially for small laboratories in countries that do not
legislate accreditation because it reinforces the point that a laboratory can
(and I think should) adopt 15189 at its own pace, and when it is ready make the
second decision based on finances and commitment and business advantage as to whether
it sees advantage in having a competent third party do an independent
assessment about the degree of compliance.
But here is my concern; the
third iteration of ISO 15189 is about to have its final vote before formal
adoption, but it contains the sentence “This international standard is not
intended to be used as the basis for certification of laboratories”.
So exactly how does that
mesh with the words and the spirit of ISO CASCO neutrality principle?
Words or rhetoric?
I think it is more than just words and it's important to consider these things.
ReplyDeleteI absolutely agree with you. This is incredibly important because having 15189 as a map towards clinical laboratory quality has proven to be absolutely invaluable. To have a Quality Partner group, other than ISO believe and act as if it has some ownership control over the document is a falsehood and a detriment.
ReplyDeleteTime will tell.
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