European Office of Crafts, Trades and Small and Medium-sized Enterprises for Standardisation

Bureau Européen de l'Artisanat et des Petites et Moyennes Entreprises pour la Normalisation

Europäisches Büro des Handwerks und der Klein- und Mittelbetriebe für die Normung
With the financial support of the
European Commission

 
 
 
To: National ISO member bodies – mirror committees of ISO TMB/WG SR

Brussels, February 1st 2010

Prot. 026/10/SB

Re: Upcoming vote on ISO 26000 (DIS)

Dear Sirs,

By means of introduction, NORMAPME is the European association of SMEs for Standardisation. It is

supported financially by the European Commission to represent the interests of 12 Million SMEs in the
area of standardisation, and it is worth noting that SMEs represent 99% of enterprises in Europe and are
the largest group of potential users of standards.
NORMAPME is actively involved in this ISO project as a D-Liaison organisation which does not hold
the right to voice its position.

NORMAPME promotes the use of all kinds of standards by SMEs, however NORMAPME underlines
that such standards must be SME friendly and of foreseeable benefit and relevance to SMEs.

Despite the good intentions and progress evident in the ISO 26000 draft standard, NORMAPME remains
critical of this ISO project and does not support the approval of the text in its current form on the grounds
that greater recognition is required of the specific reality of SMEs as final users of the standard. Obstacles
to the implementation of ISO 26000 by SMEs arise especially in issues such as the volume of the text, its
language and tone, guidance on handling issues regarding “sphere of influence”, and the lack of relevance
to small enterprises of all core subjects.

The main issues of concern to SMEs arise firstly with the misleading assumption that large enterprises
and SMEs can be treated as a single stakeholder having the same needs and concerns. Small
enterprises do not have the extent of resources at their disposal as large businesses nor do they operate
under the same articulated management structure. Social responsibility requires a different approach for
SMEs which engage directly and on a personal level with their stakeholders toward the resolution of SME
specific issues which arise, as opposed to that of larger multinational enterprises whose stakeholder
interaction is largely anonymous due to the global dimension of its operations.

Secondly, it is worth pointing out that NORMAPME is the only SME representative body which has been
involved in the ISO standard drafting process. We are sure that the interests of SMEs on other continents
are not really different to those in Europe, but as they are not involved, the participation of SMEs is
doubted to be sufficiently balanced so as to be a reflection of reality.
Thirdly, it is evident that stakeholder representation via the national delegations to the ISO SR Working
Group is significantly unbalanced; the process is thus rendered undemocratic.
In short, only 28 of 81 countries have a representative of the six stakeholder groups allocated to their six
person delegation to the ISO working group. This means that 65% of delegations are incomplete and thus
not a true representation of their country.

4, Rue Jacques de Lalaing –B-1040 Brussels

Tel: +32 2 282 05 30 - Fax: +32 2 282 05 35 - Email:info@normapme.com - internet: http://www.normapme.com

 
 
 European Office of Crafts, Trades and Small and Medium-sized Enterprises for Standardisation
Bureau Européen de l'Artisanat et des Petites et Moyennes Entreprises pour la Normalisation
Europäisches Büro des Handwerks und der Klein- und Mittelbetriebe für die Normung
With the financial support of the
European Commission

 
 
 
Fourth, the process allows for the participation of consultants even though they have an explicit conflict
of interest with the standardisation. Although experts with conflicting interests are formally excluded by
the WG rules, the absence of control has allowed participation of these actors, particularly in the
stakeholder groups of SSRO (i.e. service, support, research and other) and Industry.
Many consultants are CSR professionals who make a business out of selling advice on standards
compliance to companies, especially SMEs. While being involved in the standardisation process these
consultants may exercise their influence to be able to capitalise on the complexity of the document and
assist users in its interpretation.

An explicit conflict of interest arises in cases where consultants identify themselves as SMEs and hence
distort the process promoting their views as though they were a prospective standard user.
Such actors have considerable influence in the process, and as has been seen during the drafting of ISO
26000, prominent positions in the Working Group management structure have been occupied in this
manner.

To conclude, SMEs will be affected negatively by this standard if approved. Due to the document’s
length, complexity and lack of relevant content SMEs will simply not be in a position to adapt the
recommendations proposed in the standard.

On the grounds of the argument outlined above NORMAPME strongly encourages that your
organisation takes the mentioned arguments into account when voting on this version of the draft
international standard. We are convinced that working on a second DIS will provide an opportunity for
work to be continued on the document toward the attainment of a text which is more utility driven and
considerate of SME needs. We are convinced that this is in the best interest of the future acceptance of the
guidance standard by SMEs.

Yours sincerely,

Loucas Gourtsoyannis,
Director of NORMAPME
 

4, Rue Jacques de Lalaing –B-1040 Brussels

Tel: +32 2 282 05 30 - Fax: +32 2 282 05 35 - Email:info@normapme.com - internet: http://www.normapme.com