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1800 East Oakton Street
Des Plaines, Illinois 60018-2187
FAX 847.296.3769

December 2, 2004

Mr. Steve Cornish
American National Standards Institute
25 West 43 rd Street
New York, NY 10036 U.S.A.


Dear Mr. Cornish:

This letter represents the insights of ASSE regarding the proposal for an ISO Guidance Standard on Social Responsibility.

Before beginning our comments it is important to point out that ASSE was founded in 1911 and for almost 100 years has been dedicated to the protection of people, property, and the environment. Our members are committed to such ideals and we recognize and appreciate the importance of social responsibility both on the national and international levels. More pointedly, the positions of ASSE are based upon and arrived at by good science, sound technology, and appropriate policy making.

Our basic concern with the proposal is that the concept of social responsibility may not be something that can be effectively or efficiently standardized. In addition, many ASSE members have commented that such an area may not meet the tests for standardization. Such an example can be found in Annex D, 4th bullet, which in our view is not consistent with basic ISO principles of harmonization.

From the perspective of SH&E management, ASSE believes that a standard on social responsibility would be difficult to develop, implement, advocate, and finally ensure compliance by ISO. We believe the current structure of a combination of SH&E policies, procedures and practices, an individual company's business culture, and enforcement by state and national governmental agencies probably create a more viable functioning of social responsibility.

As we read the background materials, it seems that the reason cited for the standard is that standardization is good, therefore we should standardize. Although there may be confusion existing about different cultural norms on social responsibility, we still do not understand a clear driving need for a standard on the topic at this time.

In addition, while we noted that safety, health, and environmental (SH&E) standards are recognized in Annex C they are not recognized or cited in the actual proposal. Our review indicates that only the environmental standards would be directly covered by such a standard should it be developed. 1

Yet, if this proposal is approved and a standard is to be developed, the U.S. views should be included. The only time that those views can be raised and effectively impact the document in a meaningful way is for ASSE and/or others to participate in creating the document. If the initiative is approved, ASSE would request that it be contacted to consider naming a representative to the TAG for the United States including participation with the “mirror” committees.

We thank you for your attention to this matter, and please feel free to contact the Society should you have any additional comments or questions.

Respectfully Submitted,

Gene Barfield, CSP
Society President 2004-2005

1 If project is initiated ASSE specifically suggests that Annex B Item a) 3rd Paragraph/ 2nd line and Item c) last line should include safety, health and environment.