Considerations on letter Prot.

026/10/SB issued by NORMAPME

We would like to present the following considerations on the correspondence sent by

NORMAPME to the NSBs and other organizations that were copied in the document
'Upcoming vote in ISO 26000 (DIS)'.

1) The WG SR was carefully created by ISO in order to enhance broad stakeholder

participation. Each national mirror committees in the participating country is
open to and consists of many different types of large and small organizations,
from the different stakeholders’ categories. In fact, more than in any other ISO
technical committee, the stakeholder process adds a lot of legitimacy and is
unquestionably a milestone in standardization.
2) In many countries and regions, SMEs are organized into important associations
that represent them. In Brazil, for example, SEBRAE is an active member of the
ISO 26000 mirror committee and has been very supportive and active in the
Brazilian contribution to ISO 26000. The same occurs in many other
participating countries.
3) All the Liaison D organizations that are represented in ISO 26000 are heard
within the scope of the WG, with a right to name 2 experts and submit
comments during each of the many commenting rounds over the past years.
Several Liaison D organizations are even members of the standard drafting
committee (IDTF), have a seat on the CAG, and enormously contributed to
build the consensus (examples: IOE, ICFTU, Global Compact, UNEP etc).
Therefore, to state that a Liaison D organization "does not hold the right to
voice its position" does not reflect the reality at all.
4) Furthermore, Liaison D organizations, even in voting, are considered, as is
determined by the master document of the WG SR, the NWIP:
"Although approval is determined by ISO member body votes, it is also
expected that the provision in the Directives to seek full and formal backing
of liaison organizations on DIS, be explicitly implemented in this particular
case."
5) Moreover, WG SR internal procedures determine that: "The national
consensus positions and liaison D comments will be the basis for experts’
deliberations."
6) The autonomy of NSBs to comply with the rules of the TMB for ISO 26000
regarding stakeholder balancing in correlated countries has to be respected
and trusted. The capacity of developing countries to send all of the experts (6 in
all) to international meetings should not be confused with the absence of
balancing. The statement that: "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" fails to recognize the national efforts
required for sending experts when funds are scarce.
7) The presence of consultants is legitimate as they are part of the SSRO (Service,
support, research and others) stakeholder category. It is noted that the
ISO/TMB/WG SR N 73 document establishes criteria for naming experts and
observers at the meetings, for example: "all experts and observers must be
categorized under one of the 6 stakeholder categories. This categorization
should be undertaken in consultation with the mirror committee and/or
relevant stakeholders involved in national discussions, and should be
 consistent with the guidance provided in N048 rev1: Guidance on Stakeholder
Categories in WG/SR"
8) In document N48 rev. 1 it is stated that the following are included in the SSRO
category: organizations and individuals, not from other stakeholder
categories, that provide services related to the implementation and support
on SR activities.
9) In other words, consultants may be legitimately represented and, furthermore,
the view that consultants are always going to "exercise their influence to be
able to capitalize on the complexity of the document and assist users in its
implementation" is prejudiced and we have no such indications from the many
WG SR members we have talked to.
10) Finally, we believe the coming dissemination for the ISO 26000 is greatly
enhanced by this process.

We hope to have provided enough clarification to the points we found more sensitive
in the above mentioned letter, but we would like to once more emphasize that the
correct forum for debates about improving ISO 26000 has been and always will be the
plenary sessions of the WG and its subgroups.

We, the leaders of WG SR, believe that the power and capacity of more than 430
experts from more than 90 countries and more than 40 D-liaison organizations who for
5 years have been developing ISO 26000 in line with the rules set up by ISO cannot be
underestimated.

We believe in the plurality of views and we shall always be careful to ensure that all
relevant voices are heard and understood, provided they are committed to the truth
and voice their opinion within the scope of the technical discussions.

All the best

ISO WG SR Leadership:

Jorge Cajazeira chair

Staffan Soderberg vice-chair
Kristina Sandberg secretary
Eduardo São Thiago co-secretary