FAQ on Certifications
Q. Why doesn’t Buoy have certifications? You say you do good things, but then why don’t you prove it? You should have certifications saying you do what you say you do.
A. Buoy is not a B-Corp and we don’t have other certifications, like a certification that we use recycled materials. So why is that? Well first, we are a small company, and these certs are much more costly than people imagine, in the tens of thousands to hundreds of thousands of dollars a year. Every certification we got, if we did choose to get them, would increase the price to our customers and lessen our impact because fewer people could then afford to buy our products, so we'd make less impact.
Q. Aren’t certifications a good thing?
A. One of the characteristics of late-stage capitalism is the overproduction of symbolic capitalists. That link explains fulsomely, but to summarize my own understanding: When you give too many people higher educations but you don’t have enough productive employment for them, which we don’t as we’ve sent most productive jobs overseas, the excess educated ranks start to have a problem as to what to do. The traditional symbolic capitalist jobs in academia, journalism and government are hard to get and soak up only so many of the educated, so the surplus join NGOs and consultancies that also don’t produce anything but have to insert themselves, semi-parasitically, into the companies and organizations that remain (Not just for-profit companies but also government, education and healthcare), raising the costs of everything. (Libertarians would file the overall effect of this under, “Why we can’t have nice things.”)
All of this activity falls under the umbrella of Audit Culture (closely related to consultant culture), a handle I’ve taken from a book with that name by Chris Shore and Susan Wright, which I cannot recommend enough.
Q. Audits are necessary. If we didn't have audits, people would get away with murder.
A. The premise of audit culture sounds wonderful (as do all premises for everything): “These for-profit companies are greedy bastards who are only in it for the money. Whatever they are telling you is either fully or partly a lie. If you give us access, we’ll go in and check on them and make sure they aren’t lying or poisoning you. So when you see our mark on a product, you’ll know it’s organic or fair trade or fraud-free or whatever.” Sounds great, but here’s how that works out in practice.
If you are a company that certifies things, what you make money on is certifications. Say there are 500 companies that make ceramic cups and you dream up a certification that goes on the bottom of the cup saying that there are no harmful heavy metals in the clay and glaze. You set a standard where say 50% of the companies can reach it. That’s a decent business, but capitalism, even symbolic capitalism, is growth obsessed, so to grow your revenue, you either lower your standard so you can charge more companies, or, if you really want money, you set up a parallel operation that provides a consultancy service that helps the companies comply with these standards. The second step marks the end of any pretense to impartial auditing because now, just like the audited company wants to pass the supposedly rigorous standard, the auditing company also wants the subject of its scrutiny to pass the supposedly rigorous standard.
Up to this point, I want to emphasize that there are no cartoon villains. The auditors start with decent goals about transparency and accountability and the slide into complicity is so organic that they likely don’t notice and continue to believe that what they are doing is good even as the evidence mounts to the contrary.
But at some level this notion of innocence has to be abandoned: In its most mature expression, the auditor/consultant turns into a co-conspirator, architecting plausible pathways for fraud and cheating with the same avarice and duplicity as the worst cartoon capitalist ever imagined. When the fraud is revealed, the fraudsters themselves almost never face consequences, so you can understand that the symbolic capitalists involved generally get off without even a warning.
Q. So no certifications, but why aren't you at least a B-Corp to signal that you are doing good things?
A. As regards being a B-Corp, I can recount the exact moment that I decided against this for Buoy: I was on a call with my mid-sized accounting firm about becoming a B-Corp. (By midsize, I mean not KPMG or Price Waterhouse Cooper or Deloitte, but the next tier down.) The business accountant assigned to the project said that it should be easy to make us a B-Corp and added cheerily, “We are a B-Corp.” A mid-sized accounting firm that does taxes and manages money for companies and people is a B-Corp. Stop for a second and ask yourself, “Could it possibly mean anything to be a B-Corp aside from the fact that you have the funds and a summer intern who had the time to fill out the forms?” The answer, if you are struggling, is No. It cannot mean anything. It became obvious to me in that moment that what inevitably happens to all certifications had happened to the B-Corp. They had to grow, because growth is the religion of capitalism, so when the forms came up for a mid-sized accountancy firm, they said, “Sure, we’ll cash that check.” And that’s how that works. (One day, might we become a B-Corp? Sure, if it’s good for the mission. But our primary purpose is circularity. To be effective, we have to make enough money to move things through that circle.)
Q. Where did you get these opinions?
A, The personal experience I bring to all this comes from years in pharmaceutical manufacturing. We were always audited by the FDA. Those were good audits. An FDA investigator is most often a lab rat who got a government job. They’re smart and have integrity. They will definitely catch monkey business in the labs and they’ve gotten good in manufacturing through experience. But at some point, lawyers for big retailers like Walmart and CVS decided that the once every two year FDA surprise audit wasn’t enough for their clients to avoid liability. They advised them that to be litigation proof for their drug products, they should demand regular third party audits of all their supplying facilities. Except the retailers don’t want to pay for this. They make the supplier pay. And I think you see where this is going. Now there are say 3 to 5 companies that provide these audits. I own a supplying company and I get to pick who does the audit, even if Walmart only gives me limited choices. So I pick the audit company that is most likely to pass me. The auditing company understands that they are likely off the job in the future if they fail me, so that’s just not likely to happen. I think you’d have to hit someone in the face to fail.
While FDA audits could be legitimately stressful, there was never anything remotely stressful about what I came to call “checkbox audits.” These folks had sheet after sheet of systems that they needed to check and they had to check all of them. Some would hold up the thick audit package like its heft was a threat. Just the opposite, the thicker the packet the safer I knew I was. If they had three days to check 120 things, that’s 12 minutes per item. Do you know the kind of in-depth investigation you can do into anything in 12 minutes? Right. Not deep.
In contrast, an FDA auditor can start in any direction and if they find something that smells fishy, they have no obligation to check anything else in the plant. They can get a spade and just start digging in that one spot. They can stay a week or a month. Even when I was in pharma getting audited by the FDA, I would step back from the stress of the situation and think, “Next time I take a drug, I’m going to think about this very competent and professionally suspicious person who is sitting there assuming I’m lying to him/her and be thankful that s/he or one of her or his colleagues walked into that plant and grilled that management team.”
Q. OK, OK, I get it. You don’t believe in these canned audits, but how do I know you are not lying to me?
A. At Buoy, in lieu of audits, what we’ve decided to do is practice a form of radical transparency. We are going to publish our invoices, our purchase orders and our production runs so that at any time, you will be able to look at our suppliers as much as you like and mass balance our inputs and outputs to your heart’s content. I’ve just published an up-to-date transparency document, here.