ISO 9001: 2000 Quality Management System Design

17.4 Conclusions

As demonstrated, we believe that the use of paraphrasing (restatement of the Standard) is a matter of one's decision to obscure rather than to clarify. The paraphrased approach does the following:

• Trivializes the Standard;

• Minimizes the opportunity to question the organization's processes and thereby improve them.

Such trivialization is anathema to the purpose of ISO 9000—that is to support continuous/continual improvement. In fact, in the case where one individual writes the manual and also paraphrase's the Standard, the loss of clarity is magnified even further. Yet, it is our experience that such events frequently occur.

Therefore, although we have found paraphrasing often used, we feel that paraphrasing is inherently an ineffectual and inappropriate method of communication. Unfortunately, paraphrasing is widely encouraged by consultants and tolerated by registrars.

We maintain the following about paraphrasing:

• In its restatement of already known phrases of the Standard, it offers the reader minimal organizational information and obscures the uniqueness of the quality management system—it is out of phase with the concept of information technology flow.

• It fails to clearly instruct the executive staff of the importance of continuous improvement and the manner in which the staff is to achieve this goal.

• It is clearly not in the spirit of ISO 10013:1995 (p. 11), which demonstrates that enough detail is necessary to paint an operational picture of the organization's response to a given requirement.

• It does not permit the reader to grasp the organization's technical and manufacturing personality.

• It negates the marketing and sales potential of the manual—it makes every organization sound like every other organization, and we are befuddled as to why any organization would want to be seen as undifferentiated from its competitors.

• It is a form of intellectual dishonesty because it trivializes the intent of the Standard, which is to provide a clearly stated and definitive top-down, executive view of the organization.

• It has been found to be a tool used primarily by a single author instead of a group of technical experts, thereby diluting the technical integrity of the manual.

• It makes the manual so useless in the eyes of internal auditors that they don't even bother to audit it.

• It makes the manual so useless in the eyes of the customer that they cannot use it as a reliable tool in purchasing decision making.

Third-Party Impact We demonstrated several approaches to paraphrasing and indicated the difficulties inherent in such an approach from a general viewpoint. We have also observed that usually in the case of an accredited third-party assessment:

• Direct paraphrasing is not acceptable because it cannot be clearly audited. It forces the auditor to make assumptions regarding the policies of the organization. They are not permitted to do so.

• The table of content technique is also not acceptable for the same reason, as the assessor is still forced to assume what the policies (house rules) are.

• Paraphrasing forces a compromise position that dilutes the audit value to the client—the assessor is forced to search the lower tier documents to find the quality policy statements. Result: less bang for your audit buck!

Alternatively, however, there are consultants, registrars, and assessors who do not agree with this conclusion (some vigorously), and if the reader feels the same, you should be able to find suitable partners for your certification effort.

Obviously, we consider paraphrasing unacceptable in any manual. The formation of informative quality policy statements will force you to better understand your QMS and will orient your intellectual efforts in the direction of continual, enterprise improvement.