Deciphering the latest changes to the Harmonized Structure

Changes are coming to Management System Standards. Three experts help understand the content.

By Suzanne Van Hove (ISO/IEC/JTC 1/SC 40), Sam Somerville (ISO/TC 176/ SC2), Denise Robitaille (ISO/TC 176/ SC1)

On 16 June 2023 the ballot closed on the proposed revisions to the Harmonized Structure (Annex SL, Appendix 2 of the ISO/IEC Directives). As with previous versions of Annex SL, the ballot was held on Draft ISO Guide 83 Harmonized structure for MSS with guidance for use, as an administrative voting tool with ISO.

The changes being proposed were predicated by the 2021 London Declaration, approved by all ISO Member Bodies, which affirms the ISO community’s commitment to addressing climate change. The pertinent text of the declaration is:

“Following the signing of the London Declaration at the ISO General Assembly 2021, ISO will:

  • Foster the active consideration of climate science and associated transitions in the development of all new and revised International Standards and publications;
  • Facilitate the involvement of civil society and those most vulnerable to climate change in the development of International Standards and publications;
  • Develop and publish an Action Plan and Measurement Framework detailing concrete actions and initiatives and a reporting mechanism to track progress.”

This ballot focused on the proposed text to reflect two main additions to the harmonized structure (HS), specifically:

4.1 Understanding the organization and its context:
The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended result(s) of its XXX management system.
Adding: “The organization shall determine whether climate change is a relevant issue.”

4.2 Understanding the needs and expectations of interested parties
 The organization shall determine:
      •   the interested parties that are relevant to the XXX management system;
      •   the relevant requirements of these interested parties;|
      •   which of these requirements will be addressed through the XXX management system.
Adding: “NOTE: Relevant interested parties can have requirements related to climate change.”

The ballot passed with the following results: 14 approve, 4 reject, 9 abstain (total 27 votes). 110 national bodies were eligible to vote. This was not a mandatory ballot and one assumption for the low participation is that only national bodies with an interest in multiple management system standards (MSSs) voted. It was noted, however, that in general the members who did vote represented more than 70% of the accredited certifications to the top 10 MSSs (i.e., ISO 9001, ISO 14001, ISO 45001, ISO/IEC 27001, ISO 22000, ISO 13485, ISO 50001, ISO/IEC 20000-1, ISO 37001, ISO 22301).

In addition to voting, the national bodies were able to comment on the proposed additions. The Joint Technical Coordination Group (JTCG) reviewed and agreed on the disposition of the comments. In that process, it was noted there were some key misunderstandings around the two additions to the HS, and the purpose of this paper is to address those misunderstandings for the benefit of all concerned.

TMB Mandate

Before addressing some shared misunderstandings, it is important to remember that the London Declaration (approved in September 2021 by 100% of all member bodies; Secretary-General Action plan, January 2022), has triggered numerous actions across ISO, one of which was the Technical Management Board (TMB) creating a detailed action plan (TMB Climate Action Plan). In that plan, the TMB specified two tasks for the JTCG:

  1. Identify and propose revision of standards that could have a major positive impact with “light revision” (sic) e.g., MSS;
  2. Request the JTCG to submit a proposal to include climate considerations in the MSS template.

As a result of the TMB request, the JTCG met several times between Jan 2022 – March 2023 specifically to discuss ideas, recommendations, and eventually agree to the two additions to the HS (additions to clauses 4.1 and 4.2 of the HS). All MSS committees were informed and invited to participate in these discussions via their JTCG representatives, but not all participated.

Review of the comments received

A total of 39 comments were received from the national member bodies. It should be noted that no technical changes are allowed on a DGuide, as per ISO’s stage rules, but all comments were certainly noted for future potential revisions of the HS. The main comment themes were:

  • Include other global issues such as inclusivity/diversity, biodiversity, social responsibility, child labor and legal requirements… While all these issues may be important, it has to be remembered that the JTCG was tasked specifically with addressing climate change. The other areas have been noted as possible inputs to potential future revisions of the HS, at which time there will be ample discussion and debate about each one.
  • Include other UN Sustainable Development Goals (SDGs). While the importance of other SDGs cannot be refuted, it was determined that each unique technical committee should define what SDGs are relevant to their document(s). The specific remit of the JTCG for the current revision of the HS was only to address climate change. We must also remember that a more extensive revision to Annex SL Appendix 2 was undertaken in the 2018 – 2021 timeframe and published in the ISO Directives in May 2021.
  • Include additions to other clauses in the HS. It was suggested to augment several other clauses to include specific references to climate change, but the outcome of extensive discussions within the JTCG was the decision to keep any addition simple and let the additions to clauses 4.1 and 4.2 permeate through to the other clauses.

Lastly, there was also a concern raised that the additional requirement in Clause 4.1, while seeming to be minor, could have significant ramifications for users, auditors and the overall credibility of an MSS if it is incorrectly applied.

What the additions mean

The JTCG decision to develop the single new requirement to clause 4.1 of the HS was based on extensive discussions. The requirement is actually quite simple – the organization must determine if climate change is a relevant issue within their scope, with the potential to affect their ability to achieve the intended results of their MSS. This new requirement is simply a reminder to the organization to consider the climate as well as other internal and external issues. They should be doing that anyway, but by the inclusion of this new phrase, we are putting the spotlight firmly on the question of climate change, in accordance with the spirit of the London Declaration. We recognize that the organization may already consider the climate as part of its context, but that may not be the case across all organizations. The auditable point of this requirement is the evidence that climate change was considered as a potential issue (directly impacting or being impacted by climate change) that can affect the organization’s ability to achieve the intended results of its management system. By no means is the requirement ‘forcing’ the organization to reduce their carbon footprint or GHG emissions or any other environmental action (unless that is a goal for that organization!). The JTCG and the IAF have a planned engagement to discuss the deployment of the changes and its impact to auditors and adopters of MSS.

The second addition is a note that states that relevant interested parties can have requirements that relate to climate change. There is no auditable evidence required but rather it is a reminder that interested parties may have interests in climate change and may require the organization to address them.

In conclusion

With the approval[1] of the two changes to the HS, what’s next? Within the TMB resolution, there are several action items but the one that will impact current Type A MSSs states: “ISO/CS ensures that all existing MSS (Type A) are automatically amended without delay and in an effective manner, only to address the changes in the Harmonized Structure (HS) related to climate change.” The JTCG will be working with ISO/CS to define the most appropriate way to do that. Additional action items focus on appropriate communication to members and the technical community as well as a joint communication between ISO and the IAF to address these changes. For those Type A MSSs which are under development, these two additions to the HS should be included. Additionally, the MSS committee could proactively prepare their user community via some form of communication (e.g., white paper, video, social media). In any case, the London Declaration is in place and the global climate issues are everyone’s concern.

Technical committees may afford themselves of more guidance on the application of the London Declaration by accessing the ISO Climate Action document at:

[1] TMB Resolution 75/2023 (19 September 2023) approves the two changes.