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Insight

Insight on Quality

The COTO Thing 

Wow, quite a heated debate, but too much about clauses and auditability, not enough about the principles and potential benefits of the COTO Thing.

Regardless of how it got there, where it sits, how it is documented, and even what it’s called, the attempt to move organizations towards a more reality-based QMS is a good thing. 

Too many businesses have been living for years with a bolt-on QMS that didn’t reflect the reality of their operations when it was written, and has become even less relevant with each passing year. One system I inherited as a consultant last year only blinked into the daylight for transition purposes, its first significant update since 1995. So much for continual improvement. I’ve seen others of 15 or 20 year vintage. All had stagnated rather than matured at the back of the filing cabinet. 

My point is that these systems were only designed to fit the context of whatever ISO standard was available at the time. The context of the organization was barely considered, especially for non-manufacturing operations. At least the conversation is now required. And it is the conversation that matters most. 

A conversation about relevance to real business issues should be the starting point for designing or transitioning any QMS. This is not new: it was equally true before the COTO Thing came along. But the commercial bandwagon took over and business context was flattened by dilution and standardisation dressed up as integration (Annex SL being a classic “Emperor’s new clothes” story). Thus we moved towards every system and, more recently, every standard starting to look the same. 

So, instead of stressing about the clumsy way it is presented in the standard, I prefer to see the COTO Thing as an opportunity for consultants and auditors to help clients bridge the gap between ISO 9001 and reality.  This is the problem it can help solve, if used in a positive, jargon-free way. 

I started writing this on my way to a meeting with a small business client. I thought I’d wait until after the meeting to share my thoughts, knowing that the COTO Thing was on the agenda. He offered the opinion that “context of the organization is just as opaque as product realisation in the old standard". Jargon in jargon out. After some discussion we landed on the understanding that COTO really boils down to relevance, i.e making sure the QMS remains relevant to the current reality of the business - arguably the most important criterion for the effectiveness of a QMS in the long run.  

One final thought on the benefits of COTO, especially for organizations who use consultants to implement ISO 9001. If the existence of COTO forces consultants to discover and understand their client's business realities before designing the QMS, it must be a step in the right direction. 

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