June 19, 2020
Mr. Joe Bhatia
President and CEO
American National Standards Institute
1899 L Street, NW, 11 th Fl.
Washington, DC 20036
Dear Mr. Bhatia,
Our concerns echo those expressed in statements to ISO from the International Labor Organization
(ILO) Secretary -General Guy Ryder (Annex 1), the International Labor Office (Annex 2), and the joint
statement from the International Organization of E mployers (IOE) and the International Trade Union
Confederation (ITUC) (Annex 3). Further development of the AFNOR proposal would break hard -won
consensus and jeopardize the impact of ISO 26000; require unnecessary output of resources among
stakeholders tha t would be better used for implementation and innovation in the field of social
responsibility; and create divergence with authoritative international standards.
ISO 26000 has provided companies of all sizes valuable guidance on the underlying principles o f social
responsibility. The scope of subject -matter within ISO 26000, and that it is not intended or appropriate
for certification purposes or for regulatory or contractual use, were carefully and painstakingly
negotiated features of the guidance. Re -starting a years -long and bureaucratic process to revise ISO
26000 would damage its impact by reversing the consensus reached in its initial drafting. In particular,
establishing a TC would enable a proliferation of standards with provisions that may not be appropriate
for businesses, nor useful for advancing human rights.
Moreover, the proposal would require stakeholders to use considerable resources that would be better
utilized for implementation and innovation in the field of social responsibility. Not only would organizations be required to use significant resources throughout the revision process, turning ISO 26000 into a certifiable standard would also greatly increase compliance and audit costs for businesses.
This risks turning compliance into a bo x checking exercise, rather than an iterative process of addressing
constantly evolving, salient human rights risks in complex supply chains. The nature of respecting
human rights through due diligence exercises requires a degree of flexibility to innovat e impactful
solutions that only ISO 26000 in its current form would allow.
Finally and most importantly, the proposed TC would divert focus from and undermine universally
accepted standards on human rights and labor issues. International standards an d guidelines – including
the UN Guiding Principles on Business and Human Rights, ILO Conventions, the ILO Tripartite
Declaration of Principles concerning Multinational Enterprises and Social Policy, and the OECD
Guidelines for Multinational Enterprises – have been carefully developed over the years through multi -
stakeholder processes, and standards continue to be developed in areas where there are gaps. Moreover,
guidance and tools from the ILO, UN and OECD are publicly available at no cost, enabling all
stakeholders, regardless of resources or lack -thereof, to participate in this vitally important work stream.
The ANFOR proposal is superfluous, unnecessary, and unwelcome. While ISO is well placed to deliver
technical standards, actual expertise on human r ights and labor lies with the UN and the ILO.
We strongly recommend against revisions to ISO 26000, development of one or more implementation
guidelines or standards, and the creation of a new TC on Social Responsibility. We would be pleased to
further discuss our comments with you. If you have any questions, or would like to discuss the above
points further, please contact me at firstname.lastname@example.org. I look forward to hearing from you.
American Apparel & Footwear Association
Informati on Technology Industry Council
National Retail Federation
Responsible Business Alliance
Retail Industry Leaders Association
United States Chamber of Commerce
United States Council for International Business
• Mr. Joseph Tretler, Jr, Vice President for International Policy, ANSI
• Mr. Steven Cornish, Senior Director for International Policy, ANSI