Comments to the Joint NGO/TC207 Discussion Paper

by Aleg Cherp, ECOLOGIA
In my opinion, the Discussion Paper paper should more closely correspond to its Terms of Reference, as outlined in the TC 207 Resolution. In other words, it should focus on the following four items:
  • The value of NGO input into the ISO/TC 207 standards setting process;
  • Motivations for NGO participation in the ISO/TC 207 standards setting process, including those associated with public interest concerns;
  • Procedures for improving NGO capacity to interact with ISO/TC 207; and
  • Examples where ISO/TC 207 standards are used in non-business applications.

It would be useful if these terms of reference are reiterated in the Introduction, which, for such a short paper, can be merged with the current 'Background'. On the other hand, the history of ISO currently placed in the Introduction may be shortened or omitted since it does not have direct relevance to the terms of reference.
    The rest of the paper could be structured according to the terms of reference, and probably somewhat re-ordered. I would start with Motivations for NGO participation in the standard setting process. This section, which follows the 'Background' in the current version, could remain where it is. The section entitled "Linkages between ISO 14000 and Public Policy," as well as other NGO concerns identified elsewhere in the paper, may also be added here as motivations for NGO involvement. The material illustrating the current extent of NGO participation (including the diagram) does not logically fit in this section and should be moved elsewhere, possibly to the introductory part explaining the history and the current state of the NGO involvement. The examples of deficiencies of ISO 14000 standards from a public policy perspective may be placed in Boxes or Inserts in order not to interrupt the flow of the text.
     The second section may be entitled The value of NGO input in the standard setting process and contain essentially the same information as the current section 'The benefits of NGO input'. All material regarding the way NGOs can improve the standard setting process should be logically grouped under this heading. Finally, the last section can remain Procedures for improving NGO capacity. This last section may be further expanded to reflect the current thinking on involving the public in international discussions, for example through electronic means. Ecologia will soon be presenting this proposal.
    The two final points are that (a) the fourth point in the terms of reference (examples of ISO 14000 non-business applications) may also be addressed in the paper and that (b) the paper might benefit from either an executive summary or from a short concluding section, or both.