We’re now reviewing the comments received and will present them to the ISEAL Board of Directors in June. The final decision on the revision will be taken by the upcoming ISEAL Stakeholder Council in late 2009.

The new requirement to carry out stakeholder mapping was seen as useful, particularly as an internal tool to see whether and where the consultation has been effective.  Mapping could differentiate between core stakeholders that should be involved in the technical working groups or in decision-making and those that should be given the opportunity to input.  One question to ask is whether there are any key stakeholders without whose participation the process would not be credible?

Pilot testing is a useful tool to engage local stakeholders who would not otherwise participate.  Consultation with producers really needs to happen in producer countries if their participation is to be effective.  It is important to ensure that equal weight is given in the consultation process to informal contributions such as through pilot testing and in-person meetings.

Section 6 in the Code addresses local applications of the standard and harmonisation between standards.  This has always been a weak component of the Standard-Setting Code since it is hard to enforce, particularly on harmonisation.  An interesting discussion focused on the potential use of proxies to evaluate the need for another standard – so rather than requiring standards to harmonise, can the participation of key stakeholders be used as a proxy for the value of the process?

On local application of standards, the challenge in applying the requirements is to balance the need for local applicability with the need for consistent application and interpretation at an international scale.  It was suggested that if a local interpretation is needed then a robust local standards development process is required, whereas an emphasis on extensive guidance can help to make an international standard applicable so long as it doesn’t water down the standard.

Finally, on consultation periods, there is often a desire to shorten the consultation and to try to have one consultation period instead of two.  Where the revised Code suggests that a policy is required for when the consultation period can be shortened, the group agreed that a set of criteria for evaluating the need for a second consultation process may be more effective.  This would include criteria such as no outstanding contentious issues; adequate stakeholder participation; balanced participation, etc.

If you are interested to sign-up for the second teleconference on 15 April, please send an email to consultation@isealalliance.org

Patrick Mallet

Of the respondents, 66% have provided input to a standard-setting process and 59% consider themselves to be technical experts.  52% have been involved in the drafting process and 41% have been involved in decision-making.

The most revealing question asked what are the most important requirements in the Standard-Setting Code.  Respondents were asked to select up to 5 requirements.  The full list is reproduced here:

74% Clear objectives

65% Meaningful stakeholder participation

47% Harmonisation of standards

40% Locally applicable standards

40% Public consultation

37% Written procedures

37% Regular review of the standard

33% Transparent records

21% Complaints mechanism

21% Consensus decision-making

19% Freely available standards

16% Needs assessment

16% Enabling disadvantaged stakeholders

9% Stakeholder mapping

The last section of the survey asked participants to provide suggestions for areas to be strengthened, which criteria are unrealistic to apply, which ones require more discussion and whether there are any requirements missing.  Some common themes have emerged from the comments.  Improved transparency is a key issue, at minimum requiring that standards bodies make public all the comments received as well as improve their record-keeping.

It was recognised that the language in section 6 on local application and on harmonisation of standards contains ambiguous language that hasn’t been translated into meaningful action.  While there were calls to strengthen harmonisation, the tools for doing so are not yet clear.   A refrain that has been heard over the last few years is the need to shorten the comment periods.  Guidance will suggest a number of criteria that can be used to assess whether a second comment period is necessary.  Finally, there were also suggestions for tightening the language and making it less ambiguous, such as around terms like effective and meaningful.

Patrick Mallet

Technical Director

Representation is pretty straightforward.  Building from the mapping exercise, it is possible to identify major interest sectors and put in place a process to seek representatives from each sector.  However, this also requires that stakeholders know how people are chosen and how they can be involved if they are interested.  I will come back to this in a future post.

ISEAL is proposing a slight but significant change to clause 5.6 which talks about the decision-making process.  The original text stated that the “procedures shall ensure that no group of interested parties can dominate nor be dominated in the decision-making process.”  The proposed new text clarifies that we are talking about interest sectors rather than any individual interested party: “shall ensure that no significant interest group can dominate nor be dominated in the decision-making process.”

The question then becomes how to identify significant interest groups?  This again goes back to the mapping exercise which will ideally define which are the groups of stakeholders who would have a direct or indirect interest in the application of your standard.  There will likely be anywhere from 10 to 20 major interest groups.  You will have to use some judgement to determine if some of these groups are not significant consitituencies.  Additionally, in decision-making you will have to look at geographic representation as well just the interest groups themselves.

Patrick Mallet

The original intent of the timelines was to recognise that an international standard has implications for a broad range of stakeholders and that, particularly on the production end it is difficult to reach stakeholders and to have them respond.  If they are not able to do so electronically, it takes even longer.  In practice, we are finding that regional or national meetings are required in producing countries in order to get a good sense of their priorities and interests.  Planning these in-person consultations to happen during the consultation period requires time.

The counter-argument rests mainly on the fact that most stakeholders will wait until the last minute anyway to submit comments so why do they need the full 60 days?  Also, with the two comment periods and the time to revise and approve the standard, the whole process will take at least 6 months, assuming the standard is not controversial.

The challenge is really about the quality of the stakeholder consultation process.  Much like the post on mapping stakeholders, the main intention of the comment periods is to build buy-in and engagement to the process.  If you think of the consultation as a first step in building long-term relationships with the organisations and individuals that will support your standards system, then there is a stronger case for giving them time to find out about the standard.

So the 60 day timeline is more often needed to raise awareness that the consultation is happening and to convince people of the importance of contributing than to give people adequate time to respond.  However, if there is a strong effort to build that awareness and engagement in advance of the consultation, then less time may be required.  This is an open question.  If you have comments, submit them by clicking on the comments button below.

Patrick Mallet

Mapping is not a difficult exercise but is one that is rarely done well.  The value of mapping is not only that you can see who’s missing from your consultation but where there are stakeholders that are difficult to reach.  It also makes it easier to monitor who is involved in the consultation at different stages, which stakeholder groups should be represented in your governance or decision making bodies, and where you need to put additional resources or tools to engage certain stakeholders.

Survey respondents suggested that meaningful stakeholder engagement is the second most important component of the standard-setting process.  If we are going to get to a point where stakeholder engagement is actually meaningful and not just a tick box exercise, we need to get serious about mapping – and use the results of that mapping to guide the consultation process.

Patrick Mallet

Section 6 of the Standards Code (Effectiveness, relevance,and international harmonisation) deals with harmonisation of standards.  We have made amendments to this section–does it meet your needs?  What is meant by the term, harmonisation, and does the ISEAL Standard Setting Code capture what you feel it should capture of this notion?

Paddy Doherty

If it is possible for a standard-setter to engage with interested parties even when they are setting their standard-setting procedures, that’s great.  But it is most often the case that interested parties are informed of the standard-setting procedures and, specifically, how they can input and how decisions are made, after the procedures have been written.

The proposed revision to clause 5.1 takes this reality into account and focuses on the importance of regular review of the standard-setting procedures, taking into account comments by interested parties.  “These procedures shall be made widely available to interested parties, who shall be provided opportunities to comment on the procedures at any time. Comments shall be considered by the standard-setting organisation through a regular review of the standard-setting procedures.”

Does this better reflect realistic good practice?  Submit your comments here.

Patrick Mallet