17.2 Paraphrased Class I Characteristics

We begin with a discussion of class I paraphrasing. The best way to define this issue is to give an example of a paraphrased quality policy statement. We have chosen the Standard's requirement, 8.2.2: Internal Audit.

The following is a typical direct paraphrasing of this requirement (essentially word by word of the Standard's text):

Excellent's managers who are responsible for the area being audited shall ensure that actions are taken without due delay to eliminate detected nonconformities and their causes. Follow-up activities shall include the verification of the actions taken and the reporting of verification results.

17.2.1 ISO 10013:1995

By contrast, the ISO 9000 Guideline on Quality Manuals, ISO 10013:1995, gives an example of how to respond to a descriptive quality policy statement with prescriptive statements with regard to internal audits. The 1994 requirements were very similar to the 2000 requirements. The difference in language and intent from paraphrasing is obvious. Each SHALL is broken out into prescriptive statements that discuss such items as function management, authority and responsibility for audit reports, and management review of the audit results. Because of the clarity and specificity of the ISO 10013 quality policy statements, people have argued with me that what was presented was actually a procedure—even though the guideline was absolutely clear that it was an example of a quality manual section. The confusion in this area is mind boggling.

17.2.2 Discussion of the Direct Method of Paraphrasing —Class I

In the direct method of paraphrasing, all or nearly all of the Standard's text is used as a quality policy statement. As a result, a manual written in this fashion

Looks, reads, and feels like the Standard itself;
Has little to differentiate the text from that of a competitor;
Fails to define the prescriptive rules of the house.

For example, a purchasing or quality-assurance manager who receives such a manual during a make-buy decision would have little information to go on. Any employee who read the manual would be hard put to understand the dynamics of the organization and its commitment to ISO 9001:2000.

Also, if we compare the direct method of paraphrasing with the ISO 10013 Guideline (i.e., Table 17.1), we see that the contrast is significant in terms of information transfer and clarity. The response in ISO 10013 offers a look into the actual operation of the company while the paraphrased text could be written about any number of competitive organizations. The competitive advantage is negated. Moreover, the paraphrased text maintains the future tense, so it is not clear if this is what is going on now or later. In addition, there is nebulous information in the paraphrased text so any decision maker would find it difficult to decide on the depth of quality in that company.

Table 17.1: Attribute Comparison of ISO 10013 Versus Direct Paraphrasing
Attribute	ISO 10013	Directly Paraphrased
SHALL response	Each SHALL responded to with a quality policy statement	Each SHALL restated without a prescriptive response
Clarity/tense	Simple declarative sentences in the present tense	Restatement in the future tense—questions arise as to whether or not the action has happened yet
Detail	Sufficient for decision makers to make judgments about the efficacy of the QMS and to prepare an audit plan	Nebulous information—restates the Standard
Responsibility	Clearly stated	Does imply some responsibility
Market differentiation	Contains the personality and pulse of the organization	Looks and sounds like everybody else
Reference to procedures	Directly stated as Document QA 123-4	In general, also directly stated
Configuration	Directly sequenced to Standard's elements	Directly sequenced to Standard's elements