Martin Kellermann :
On the occasion of celebrating International Accreditation Day, it is useful to reflect on accreditation’s place in the bigger picture. This rapidly leads us to reflect on the necessity of an internationally recognized national quality infrastructure, of which accreditation is generally considered to be one of the three fundamentals, the other two being metrology and standards. In this short article, we will look at international trade, why the quality infrastructure is important and where Bangladesh is at the moment in its quest to reach international recognition for its national quality infrastructure. Out of this, the necessity of a National Quality Policy will become clearer.
It is generally recognized that enhanced trade leads to economic growth, the impact of which ultimately is poverty reduction. One important factor essential for trade is a supply side that gains market access through competitive and safe products. There are many other factors that also play a role such as infrastructure, finances, good governance, macro-economic and social policies, education, health, gender and many more – see Figure 1. The Government of Bangladesh has recognized these trends, is committed to poverty reduction and therefore has embarked on policy interventions that would support industrial development, enhancement of exports and the like.
Much of the merchandise traded internationally is based on standards and technical regulations.
Of the ten main commodity categories traded, at least nine are fully subject to public standards, and at least eight of them would be subject to technical regulations in some form or another2. Hence standards and technical regulations influence our way of life in ways we often times may not even notice, but their influence on trade is profound. Therefore if the Bangladeshi industry, traders and exporters wish to profit from world trade, they must have access to the services of a national quality infrastructure that enjoys international recognition. Such services are necessary to demonstrate that Bangladeshi products meet international standards and technical regulations and can hold their own in the intense competition out there.
Bangladesh is in the fortunate position that it has already established the three fundamental institutions of the National Quality Infrastructure (NQI). These are the Bangladesh Standards and Testing Institution (BSTI), the Bangladesh Accreditation Board (BAB) and the Bangladesh National Metrology Institute (BNMI) within BSTI.
If these already exist, what then is the problem? Establishing these organizations is only the very beginning of the story. At the next level of the NQI are all the inspection agencies, test laboratories, calibration laboratories and certification bodies. Their acceptance in foreign markets, and even in the local market, is dependent on how well they are able to utilise the services of the national standards, metrology and accreditation bodies.
And it is not only the recognition of the NQI services that is at stake, it is also the way in which Bangladesh develops and implements technical regulations also known as mandatory standards. Standards are considered “voluntary” in the WTO Agreement on Technical Barriers to Trade (TBT). That means that the supplier has a choice to comply with a given standard or not. Non-compliance may result in the supplier losing market share or finding it difficult to penetrate the market, but the supplier does not break the law. On the other hand, compliance with a technical regulation, which looks very much like a standard, is a legal obligation. If your product does not meet the requirements of the technical regulation imposed by the government, you are breaking the law.
Therefore technical regulations are more frequently barriers to trade than standards. If you cannot provide evidence that your product complies with the technical regulation in a way that is acceptable to the regulatory authorities, you cannot market your product. And because trade should be a two way traffic – I export products to you and you export products to me – it follows that if the technical regulations of trading partners are different, it makes things more difficult for the exporters both sides. We also find that due to historical reasons, various Ministries and their Agencies that develop and administer technical regulation frequently follow their own way of doing so. Added to this, coordination of their activities at national level does not exist or is ineffective. Such a fragmented and ad hoc approach adds massively to transactional costs, rendering the products and therefore the count uncompetitive.
Sadly, this is also broadly the picture in Bangladesh, even though institutions are starting to pursue International recognition. At the time of writing, BAB was on the way to recognition by the International Laboratory Accreditation ‘ Cooperation (ILAC) through the Asia Pacific Laboratory Accreditation Cooperation (APLAC). NML-BSTI was getting ready for an assessment visit by NorskAkkreditieren, the Norwegian accreditation body. That sounds good, but is not enough. Very few laboratories have been assessed and accredited against ISO/IEC 17025, the international standard. Compare this situation to the one in Vietnam for example where more than 500 laboratories have been accredited by their national accreditation body that enjoys international recognition. This certainly gives Vietnamese industry a competitive advantage in foreign markets.
In the case of technical regulations, there are many ministries and their agencies in Bangladesh that develop and implement these in the various sectors they are responsible for. This is not the issue – in the majority of the world’s economies this is the case. However, no coordination mechanism exists to ensure that there are no gross overlaps or gaps in their activities, nor is an oversight in place to ensure that all of these meet the obligations that Bangladesh has as a member of the WTO TBT Agreement. For example, bottled water in Bangladesh may be controlled by three or four regulatory authorities depending on how you see the situation.
This is obviously not a business friendly environment, and it can even be argued that it complicates consumer protection. In addition it is contrary to the changes happening at the international level:(i) the drive to liberalise and globalise international trade, (ii) the determination that trade should be subject to rules which are transparent, non-discriminatory, and administered by a body which can impose penalties for non-compliance, (iii) the emphasis on maximising private and civil society involvement in setting standards and norms as against the earlier reliance on the state, (iv) the growth of international best practices in all fields, and (v) the need to be receptive to national and international public opinion.
All of these factors indicate that Bangladesh must establish the appropriate internationally recognized quality infrastructure that can provide the appropriate standardization and conformity assessment services to its developing manufacturing and processing industry; otherwise the industry will remain at a serious disadvantage. Fortunately, international best practices have evolved in the past two decades that can be usefully appropriated by a government to evaluate, review and establish or re-establish its own quality infrastructure.
Most of the measures to reduce technical barriers can be related to the implementation of good regulatory practices. The technical regulation regime should be simplified, rendered more transparent and predictable thereby enhancing certainty. Market forces should be allowed to operate wherever possible without compromising the safety and health of people and the environment. In most cases this also means that the government should change its strategy from testing and approving products before they are marketed to a post-marketing surveillance approach, placing the responsibility for the integrity of products squarely on the shoulders of the suppliers.
The OECD countries have recognized this reality more than a decade ago and have developed a whole body of guidelines to effect better regulatory practices3. A number of developing or transition low and middle income countries are also in the process of reviewing their technical regulation practices, e.g. Brazil, South Africa, Bangladesh, Chile, Pakistan, etc. Transition countries which are now current or aspiring members of the EU have had to radically transform their technical regulation systems in order to comply with the EU’s acquiscommunautaire. The question is not whether Bangladesh has to follow these trends, but how would it be able to do so as quickly and effectively as possible. This is a process that has to be driven by government. It has to create the policy environment within which such developments can be hastened, and it has to re-engineer the public NQI organizations to meet international criteria. The most useful start to this process would be a proper National Quality Policy.
The primary objective of the National Quality Policy is to ensure that goods and services emanating from or traded in Bangladesh are designed, manufactured and supplied in a manner that match the needs, expectations and requirements of the purchasers and consumers as well as those of the regulatory authorities in the local and in the export markets.
In support of the primary objective, implementation of the Quality Policy should raise the quality consciousness amongst both the suppliers and the consumers, and it is an undertaking by government to introduce and maintain a quality culture in public life and throughout society.
The immediate outcome of the implementation of the Quality Policy will be the re-engineering of the current situation to establish a world-class metrology, standardization, accreditation, inspection, testing and certification infrastructure, i.e. the NQI, and to support the application of its techniques, practices and service provision to demonstrably comply with international standards throughout.
In parallel to the establishment of the NQI, the technical regulation regime of Bangladesh will be reviewed and adjusted, including its related legislation, to meet regional and international requirements such as the WTO TBT and SPS Agreements as well as international best practices. This includes the establishment of effective cooperation amongst the NQI institutions and the national regulatory authorities, and with their regional and international counterparts. The service delivery of the NQI is totally dependent on a trained and skilled workforce, hence developing the human resources necessary to support the various standardization, quality and technical regulation programmes is a central theme throughout the Quality Policy.
The development process of the National Quality Policy should be an all-inclusive process. It is good to consider international good practices in developing the text of such a policy. It is even better to ensure that the views of all the stakeholders in Bangladesh in the National Quality Infrastructure and the Technical Regulation framework are sought. This ensures buy-in and helps the implementation process which will span almost all the ministries and their agencies at both the national and provincial level. Implementation needs to be meticulously planned and funded as it will span across a number of ministries and their agencies as well as the private sector. It will also take time.
The whole process can be likened to a marksman that wishes to shoot. In shooting we say: “Ready — Aim — Fire!” In policy development and implementation it is the same. “Ready” is all about the right time to develop the policy. In the case of Bangladesh that is now. “Aim” is all about the actual policy. Bangladesh is in the throes of developing one. And “Fire” is all about the implementation of the policy. In many countries we see that the “Aim” part comes after the “Fire” part – we first do and then consider whether what we have done is right. This is not the way. On the other hand, we frequently are very good at the “Aim” part, and we end up in an everlasting cycle of meetings, workshops, summits, etc. but we never pull the trigger: We do not get to the “Fire” part, we do not implement. Let all ensure that the whole process in Bangladesh will end well with a world-class Quality Infrastructure and a meaningful technical regulation regime, fully implemented.
(Courtesy: Bangladesh Accreditation Board)
