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Implementing ISO/IEC 17025:2017

Second Edition

Wisconsin

Bob Mehta

American Society for Quality, Quality Press, Milwaukee 53203 © 2019 by ASQ. Printed in 2019.

All rights reserved.

Printed in the United States of Amer ica.

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Portions of information contained in this publication/book are printed with permission of Minitab Inc. All such material remains the exclusive property and copyright of Minitab Inc. All rights reserved.

Library of Congress Cataloging-in-Publication Data

Names: Mehta, Bob, 1961– author.

Title: Implementing ISO/IEC 17025:2017 / Bob Mehta.

Other titles: ISO/IEC 17025:2017

Description: 2nd edition. | Milwaukee, Wisconsin : ASQ Quality Press, [2019] | Includes bibliographical references and index.

Identifiers: LCCN 2018051137 | ISBN 9780873899802 (hardcover : alk. paper)

Subjects: LCSH: Laboratories—Accreditation— Standards. | Laboratories— Standards.

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Chapter 8

Chapter 8 .7

Chapter 8 . 8

Chapter 8 .9

Appendix: Changes between the 2005 and 2017 Versions of the

List of Figures and Tables

Acknowledgments

First, to my late parents, who both passed away when I was in India. Thank you to my mother for sacrificing her life to give birth to me. Since my mother passed away during childbirth, I depended on my dad until he passed away when I was in college. He taught me to believe in myself, work hard, and stay determined in everything that I do. I kept these values with me when I came to the United States in 1986. Since then, I never looked back. You both are the inspiration for my lifelong passion for learning and for sharing my knowledge with others. Your nurtured love and support make me what I am today.

To my wife for her love and support for over two decades. Your support while I wrote this book after working long hours as a consultant was invaluable to me.

To my son, Jay, for his love and support, including proofreading the manuscript for this book and sharing ideas as a quality professional. My thanks to Ahmedabad Science College (Ahmedabad, India), where I earned a Bachelor of Science degree in chemistry; to Pepperdine University for helping me develop an understanding of business practices and use my learnings from my MBA degree toward professional goals; and to California State University–Dominguez Hills for helping me increase my competence in the field of quality and use my Master of Science degree in quality assurance to achieve my career aspirations. I would also like to acknowledge the adjunct faculty there, where I teach Master of Science in Quality Assurance classes, for their support and guidance.

And to the American Society for Quality sections around the world, members of the Orange Empire Section, to which I belong, and to all measurement and analysis professionals supporting and/or managing calibration functions.

Introduction

The focus of this book will be to demystify the requirements delineated within ISO/IEC 17025:2017, while providing a road map for organ izations wishing to receive accreditation for their laboratories. For those of you who have read my first book, which focused on complying with ISO/IEC 17025:2005, this is essentially a second edition. AS9100, ISO 9001:2015, and ISO 13485:2016 are standards that have been created to support the development and implementation of effective approaches to quality management and are recognized blueprints for the establishment of a quality management system (QMS) for many diverse industries. Similar to these recognized QMS standards, ISO/IEC 17025:2017 for laboratory accreditation serves a unique purpose. It is not unusual for laboratories to retain dual certification in ISO 9001:2015 and ISO/IEC 17025:2017. However, ISO/ IEC 17025:2017 does contain requirements specific to the laboratory environment that are not addressed by ISO 9001:2015. This book will highlight the differences between ISO 9001:2015 and ISO/IEC 17025:2017, while providing practical insight and tools needed for laboratories wishing to achieve or sustain accreditation to ISO/IEC 17025:2017.

1 Scope

The scope of ISO/IEC 17025:2017 is essentially the creating of a sound functional platform for laboratories to operate in an environment that supports laboratory competency, impartiality, and consistency. Irrespective of a laboratory’s size and the number of supporting personnel, the standard discussed in this book is deemed to be relevant. Not only can ISO/IEC 17025:2017 be employed to create the foundation for a laboratory, it can be used to assist customers, regulators, and other interested parties in their per for mance of assessment activities.

2

Normative References

There are two documents that are identified within ISO/IEC 17025:2017 that have content considered to be germane to any discussion associated with the understanding of this standard. According to ISO/IEC 17012:2017, these two documents are identified as: (a) ISO/IEC 17000 (Conformity assessment—Vocabulary and general principles) and (b) ISO/IEC Guide 99 (International vocabulary of metrology— Basic and general concepts and associated terms).

3

Terms and Definitions

According to ISO/IEC 17025:2017, the terms and definitions associated with ISO/IEC 17000 and ISO/IEC Guide 99 are applicable for this standard. However, ISO and IEC do maintain terminological databases that can be used in support of standardization. These two databases can be located at:

• ISO’s Online Browsing Platform, https://www iso org /obp

• IEC’s Electropedia: The World’s Online Electrotechnical Vocabulary, http://www.electropedia.org/

Key terms and definitions referenced within the standard include:

Complaint: An expression of dissatisfaction by any person or organ ization to a laboratory, relating to the activities or results of that laboratory, where a response is expected.

Decision Rule: A rule that describes how measurement uncertainty is accounted for when starting conformity with a specified requirement.

Impartiality: The presence of objectivity.

Interlaboratory Comparison: The organization, performance, and evaluation of measurements or tests, on the same or similar items, by two or more laboratories in accordance with predetermined conditions.

Intralaboratory Comparison: The organization, perfor mance, and evaluation of measurements or tests, on the same or similar items within the same laboratory in accordance with predetermined conditions.

Laboratory: A body that performs one or more of the following activities: (a) testing, (b) calibration, and (c) sampling associated with subsequent testing or calibration.

Proficiency Testing: The evaluation of participant per formance against preestablished criteria by means of interlaboratory comparisons.

Reference Standard: A reference standard is a highly characterized, standardized, and validated reference material. It enables the measurement of the sensitivity, specificity, and accuracy of your assay or workflow.

Validation: The verification where the specified requirements are adequate for its intended use.

Verification: The provision of objective evidence that a given item fulfills specified requirements.

4 General Requirements

INTRODUCTION

It is imperative that laboratories complying with ISO/IEC 17025:2017 adhere to two fundamental concepts: (a) impartiality and (b) confidentiality. Not unlike a person’s relationship with their family doctor or that inopportune time when a person ends up in traffic court, the expectation is that regardless of outcome, impartiality and confidentiality are appropriately maintained. Laboratories are required to adhere with those same principles. Because of the brevity of clause 4.1 (Impartiality) and clause 4.2 (Confidentiality) of ISO/IEC 17025:2017, both clauses will be reviewed in this initial chapter.

SUMMARY OF ISO/IEC 17025:2017 REQUIREMENT—4.1 (IMPARTIALITY)

• Laboratory activities must be carried out in a manner to ensure impartiality is maintained.

• Management shall be fully committed to the concept of impartiality.

• Commercial, fiscal, or other operational pressures should not influence impartiality.

• Laboratories are expected to review and identify potential risks to sustaining impartiality.

• When risks to impartiality have been identified, the laboratory is required to mitigate those risks.

SUMMARY OF ISO/IEC 17025:2017 REQUIREMENT—4.2 (CONFIDENTIALITY)

• Laboratories are to be responsible for carefully managing information with which they have been entrusted. If the information is not deemed to be public knowledge, then appropriate permission shall be in place to protect the confidentiality of information.

• When a laboratory is required by law to release confidential information, then this agreement must be defined within a contract.

• Confidential information shared between a laboratory and its clients, regardless of source, is still to be treated as confidential.

• Individuals acting on behalf of a laboratory (e.g., consultant) shall maintain the integrity of confidential agreements.

EFFECTIVE TOOLS FOR IMPLEMENTATION AND COMPLIANCE

Clause 4.1 and clause 4.2 are essentially cornerstones for laboratories wishing to achieve compliance with ISO/IEC 17025:2017 requirements. Impartiality is rooted in a laboratory’s ability to prioritize a customer’s needs above those of the laboratory. It starts with the management making difficult decisions that may not be in the best interest of the laboratory but supports a customer’s need for impartiality in the obtaining of accurate calibration or test results, regardless of the outcome. This becomes an extremely impor tant task when supporting highly regulated industries such as aerospace and defense or medtech. Regardless, impartiality is a top­down driven concept that is routed in laboratory integrity.

Tools for complying with clause 4.2 are less abstract as contracts and nondisclosure agreements (NDAs) can be scripted to ensure information is appropriately protected. Additionally, for med­tech clients, there is always the possibility for patient information to potentially be involved in failure investigations. As a result, there may be a need to address Health Insurance Portability and Accountability Act (HIPAA) requirements in support of protecting patient­related information. Regardless, a well­written contract and a signed NDA are a laboratory’s best friend when addressing confidentiality concerns.

QUESTIONS TO CONSIDER DURING AN AUDIT

Questions placed at the end of this and subsequent chapters are relevant to the subject matter discussed in each chapter. However, the questions are intended to be an all­inclusive list. They can be used to populate an audit checklist or supplier questionnaire and used as part of the supplier assessment process:

1. Could the fiscal health of the laboratory impact the laboratory’s ability to remain impartial?

2. Has someone reviewed a recent Dun & Bradstreet report that provides a general financial picture of the laboratory?

3. Is there ongoing litigation or other regulatory action potentially influencing the impartiality of the laboratory?

4. Are contracts required to be in place with all laboratory clients?

5. Are NDAs required to be signed for all clients?

CHAPTER REVIEW

For this initial chapter, maintaining impartiality and protecting the confidentiality of information is not rocket science. It is easy to pursue commonsense approaches that result in laboratories being able to provide accurate and impartial calibration or test results, while protecting the confidentiality of the information handled. It starts with management’s commitment to these basic fundamentals—maintaining impartiality and confidentiality—at all costs. Customers demand it, ISO/IEC 17025:2017 requires it, and laboratories shall comply with it; all are requirements associated with maintaining impartiality and confidentiality.

5 Structural Requirements

INTRODUCTION

Similar to other ISO standards, identifying the salient requirements needed for establishing the foundation for an effective organ ization are delineated within clause 5 of ISO/IEC 17025:2017. If an organ ization is seeking accreditation to 17025, and an approved ISO 9001:2015 Quality Management System (QMS) has already been certified by a recognized registrar, then the chances are good an acceptable organizational infrastructure has already been established. It is imperative that the identification of the legal entity of the laboratory and its relationship to a parent organization or subsidiaries be clearly defined. Additionally, the laboratory’s management system, policies, procedures, orga nizational structure, responsibilities of personnel, the interrelationships of laboratory personnel, identification of key management personnel, the handling of deviations from the QMS, methods of communication, and the reporting of the laboratory perfor mance to management must be defined and developed in the context of complying with 17025. Further, the primary task of a laboratory is to perform testing and calibration activities in accordance with ISO/IEC 17025:2017. Fi nally, and arguably the most impor tant point for a laboratory, is the ability to meet and hopefully exceed the expectation of their customers, including meeting all applicable regulatory and statutory requirements. This initial chapter will examine the requirements and the steps necessary for a laboratory to comply with clause 5 of ISO/IEC 17025:2017— Structural Requirements.

SUMMARY OF ISO/IEC 17025:2017 REQUIREMENT—5 (STRUCTURAL REQUIREMENTS)

• An organization is classified as a stand-alone laboratory or the legal entity that is legally responsible for the laboratory.

• The management of the laboratory needs to be clearly identified and their overall responsibilities clearly defined.

• Laboratories need to define the range of activities and work performed within their facility in accordance with ISO/IEC 17025:2017 requirements. Compliance can only be claimed for the actual activities performed by the laboratory.

• Work performed within a laboratory shall be performed in a manner that complies with ISO/IEC 17025:2017 requirements. These requirements apply to other facilities, mobile facilities, or work being performed at client facilities.

• Laboratories, as defined by the standard, are required to:

– Define the organizational structure, including the relationships between functional groups;

– Clearly define the roles and responsibilities of all laboratory personnel; and

– Establish (define, document, and implement) procedures that will result in consistent laboratory results.

• Laboratories are required to:

– Retain adequate management and technical personnel with sufficient authority to support the implementation, maintenance, and improvement of the management system. When deviations from the established management system occur, these individuals will pursue corrective action to mitigate deviations, as appropriate;

– Ensure management and personnel are protected from undue influences (internal and external) that may impact the quality of their work;

– Establish policies and procedures to protect the confidentiality of customer data;

– Establish adequate policies and procedures in support of the overall operational integrity of the lab;

– Adequately define the organizational structure;

– Delineate the authority, responsibility, and interrelationships of laboratory personnel;

– Provide adequate supervision for all laboratory personnel;

– Retain technical management responsible for technical operations;

– Appoint a quality manager that has a direct reporting line to senior management;

– When deemed appropriate, identify and appoint deputies for key management personnel; and

– Ensure all personnel clearly understand the influence the execution of their day-to- day activities have on the management system.

• Laboratory management is required to:

– Ensure the effectiveness of the management system is clearly conveyed to all stakeholders (individuals having a vested interest in the laboratory’s success— e.g., a medical device manufacturer);

– Ensure the integrity of the management system remains intact when changes to the management system are planned and implemented.

EFFECTIVE TOOLS FOR IMPLEMENTATION AND COMPLIANCE

Clause 5 is essentially an overview of elements required from laboratory management to maintain an effective management system. For example, the laboratory is required to retain adequate and properly trained resources to ensure the management system always remains in compliance with ISO/IEC 17025:2017. When deviations from the management system have been identified, management is tasked with correcting the deviation in accordance with clause 5.6(b) of ISO/IEC 17025:2017, discussed in Chapter 5 of this book.

For starters, the creation of an orga nizational chart is a fundamental requirement for laboratories considering accreditation. A well­ constructed organ ization chart clearly delineates the functional structure of the laboratory. It is imperative that the roles of the laboratory’s quality manager and technical manager are clearly depicted on the chart (see Figure 5.1).

The fundamental requirement is to ensure the roles, responsibilities, and the authority established within the laboratory is adequate and in compliance with 17025. The importance of having a job description will be discussed in greater detail later in this book; however, it is strongly recommended that the job description contain the reporting structure for each job. For example, the calibration technicians report directly to the test and calibration supervisor. Additionally, it is also imperative that every laboratory employee is trained to understand the influence their functional duties have on the overall effectiveness of the laboratory’s management system. Most organizations accomplish this task through initial employee orientation and training.

Laboratory quality manager

Document control Quality engineer

Laboratory president

Human resources

Laboratory technical manager

Test and calibration supervisor

Test and calibration data reviewer

Field service technicians

Test and calibration technicians

Figure 5.1 Typical laboratory organizational chart.

Regardless of the approach pursued, make sure the training is documented in accordance with clause 5.6 of ISO/IEC 17025:2017 (Chapter 6.2 of this book).

Further, it is impor tant that the laboratory appoint a quality manager and a technical manager and delineate the specific roles and responsibilities for each of these positions. Once again, the job description will play a key role in definition of duties and responsibilities. For small organ izations (e.g., less than ten individuals and in some cases one or two employees), team members will be tasked with wearing many hats. However, orga nizational size does not result in diminished levels of compliance with the standard. Finally, laboratories must ensure the confidential nature of customer data. ISO/IEC requires that laboratories script a policy and procedure that defines the protection of confidentiality process. The procedure should be prescriptive when it comes to defining the security of confidential data.

QUESTIONS TO CONSIDER DURING AN AUDIT

1. Is the laboratory a stand­alone entity or part of a larger organ ization?

2. Is the laboratory currently accredited to ISO/IEC 17025:2017?

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England, but also tyranny and repression wherever they operate. The indictment of George III, which at times approaches sublimity, is in reality directed against the entire reactionary policy of contemporary European statesmen and rulers. The doctrines of the revolutionary Byron, already familiar to us in Don Juan, are to be found in the ironic stanzas upon the sumptuous funeral of the king, a passage admired by Goethe; respect for monarchy itself had died out in a nobleman who could say of George’s entombment:

“It seemed the mockery of hell to fold The rottenness of eighty years in gold.”

With all its broad humor, the satire is aflame with indignation. In this respect the poem performed an important public service. In place of stupid content with things as they were, it offered critical comment on existing conditions, comment somewhat biassed, it is true, but nevertheless in refreshing contrast to the conventional submission of the great majority of the British public.

Much of what has already been pointed out with regard to the sources and inspiration of Don Juan may be applied without alteration to TheVisionofJudgment, which is, as Byron told Moore, written “in the Pulci style, which the fools in England think was invented by Whistlecraft—it is as old as the hills in Italy.”

369 The Vision, being shorter and more unified, contains few digressions which do not bear directly upon the plot; but it has the same colloquial and conversational style, the same occasional rise into true imaginative poetry with the inevitable following drop into the commonplace, the same fondness for realism, and the same broad burlesque.370 Hampered as it is by the necessity of keeping the story well-knit, Byron’s personality has ample opportunity for expression.

It is probable that Byron’s description of Saint Peter and the angels owes much to his reading of Pulci.371 In at least one instance there is a palpable imitation. Saint Peter in the Vision, who was so terrified by the approach of Lucifer that,

“He patter’d with his keys at a great rate, And sweated through his apostolic skin,”372

suffered as did the same saint in the Morgante Maggiore who was weary with the duty of opening the celestial gate for slaughtered Christians:

“Credo che molto quel giorno s’affana: E converrà ch’egli abbi buono orecchio, Tanto gridavan quello anime Osanna Ch’eran portate dagli angeli in cielo; Sicchè la barba gli sudava e ’l pelo.”373

In employing the realistic method in depicting the angels, Byron seems to have caught something of Pulci’s grotesque spirit.

One line of the Vision,

“When this old, blind, mad, helpless, weak, poor worm,” seems to imitate the opening of Shelley’s powerful Sonnet; England in1819, already quoted,

“An old, mad, blind, despised, and dying king.”

Professor Courthope has suggested that Byron’s DonJuanowes something to the work of Peter Pindar.374 The evidence for the relationship seems, however, to be very scanty. Wolcot never employed the octave stanza, nor, indeed, did he ever show evidences of true poetic power. The two men were, of course, alike

in that they were both liberals, both avowedly enemies of George III, and both outspoken in their dislikes. But Byron seldom except in parts of the Vision used the method of broad caricature so characteristic of Pindar. In the Vision, too, occurs the only obvious reference on Byron’s part to Pindar’s satire. He describes the effect of Southey’s dactyls on George III, in the lines:

“The monarch, mute till then, exclaim’d, ‘What! What!

Pye come again? No more—No more of that.’”375

The couplet recalls Pindar’s delightful imitations of that king’s eccentric habit of repeating words and phrases. However, Byron’s style in both Don Juan and the Vision is drawn more from Italian than from English models.

The Vision of Judgment is, if we exclude Don Juan as being more than satire, the greatest verse-satire that Byron ever wrote. It is only natural then to compare the poem with other English satires which have high rank in our literature. A practically unanimous critical decision has established Dryden’s AbsalomandAchitophelas occupying the foremost position in English satire before the time of Byron. Unquestionably this work of Dryden’s is admirable; it is witty, pointed, and direct, embellished with masterly character sketches and almost faultless in style. It does, however, suffer somewhat from a lack of unity, due primarily to the fact that the narrative element in the poem is subordinate to the description. Byron’s Vision, on the other hand, has a single plot, which is carefully carried out to a climax and a conclusion. Action joins with invective and description in forming the satire. Thus the two poems, approximately the same length if we consider only Part I of Absalom and Achitophel, give a decidedly different impression. Dryden’s satire seems a panorama of figures, while Byron’s has the coherence and clash of a drama.

Absalom and Achitophel is witty but seldom humorous; while Byron joins caricature and burlesque to wit. The best lines in

Dryden’s poem, such as:

“Beggar’d by fools, whom still he found too late; He had his jest, and they had his estate,”

excite admiration for the author’s cleverness, but rarely arouse a smile; the Vision, the contrary, is full of buffoonery. Dryden’s sense of the dignity of the satirist’s office did not permit him to lower his style, and he never became familiar with his readers; the very essence of Byron’s satire is its colloquial character.

Dryden kept his personality always in the background, while the egotistical Byron could not refrain from letting his individuality lend fire and passion to whatever he wrote. Thus the Vision, despite the fact that it is the most cool of Byron’s satires, cannot be called calm and restrained. Self-control, the will to subdue and govern his impulses and prejudices, was beyond his reach. Fortunately in the Vision he did take time to exercise craftsmanship, but he never attained the polished artistry and firm reserve of his predecessor. Certainly in urbanity, in dignity, and in justice Dryden is the superior, just as he is undoubtedly less imaginative, less varied, and less spirited than Byron.

The two satires are, then, radically different in their methods. One is a masterpiece of the Latin classical satire in English, formal and regular, and using the standard English couplet; the other is our finest example of the Italian style in satire—the mocking, grotesque, colloquial, and humorous manner of Pulci and Casti. Both are effective; but one is inclined to surmise that the purple patches in Absalom and Achitophel will outlast the more perfect whole of The VisionofJudgment.

The probable results of the publication of a work of such a sensational character had been foreseen by both Murray and Longman. When the first number of TheLiberalappeared containing not only TheVisionofJudgmentbut also three epigrams of Byron’s

on the death of Castlereagh, it was received by a torrent of hostile criticism from the Tory press. The Literary Gazette for October 19, 1822, called Byron’s work “heartless and beastly ribaldry,” and added on November 2, that Byron had contributed to the Liberal “impiety, vulgarity, inhumanity, and heartlessness.” The Courierfor October 26 termed him “an unsexed Circe, who gems the poisoned cup he offers us.” On the Whig side, in contrast, Hunt’s Examiner for September 29 spoke of it as “a Satire upon the Laureate, which contains also a true and fearless character of a grossly adulated monarch.”

Byron himself described it to Murray as “one of my best things.”376 Later critical opinion has also tended to rank it very high. Goethe called the verses on George III “the sublime of hatred.” Swinburne, himself a revolutionist but no partisan of Byron’s, exhausts superlatives in commenting on it: “This poem—stands alone, not in Byron’s work only, but in the work of the world. Satire in earlier times had changed her rags for robes; Juvenal had clothed with fire, and Dryden with majesty, that wandering and bastard muse. Byron gave her wings to fly with, above the reach even of these. Others have had as much of passion and as much of humor; Dryden had perhaps as much of both combined. But here, and not elsewhere, a third quality is apparent—the sense of a high and clear imagination.—Above all, the balance of thought and passion is admirable; human indignation and divine irony are alike understood and expressed; the pure and fiery anger of men at the sight of wrong-doing, the tacit inscrutable derision of heaven.” Nichol, in his life of Byron, says:—“Nowhere in so much space, save in some of the prose of Swift, is there in English so much scathing satire.”

Two figures in Byron’s poem have been made the basis of a shrewd comparison by Henley. He says: “Byron and Wordsworth are like the Lucifer and Michael of TheVisionofJudgment. Byron’s was the genius of revolt, as Wordsworth’s was the genius of dignified and useful submission; Byron preached the doctrine of private revolution, Wordsworth the dogma of private apotheosis—Byron was the

passionate and dauntless ‘soldier of a forlorn hope,’ Wordsworth a kind of inspired clergyman.” Byron’s sympathies in the Vision, as in Cain, were undoubtedly with Lucifer, the rebel and exile, and his poem will live as a satiric declaration of the duty of active resistance to despotism and oppression.

CHAPTER X

“THE AGE OF BRONZE” AND “THE BLUES”

BYRON’S Monody on the Death ofSheridan, written at Diodati on July 17, 1816, and recited in Drury Lane Theatre on September 7, was followed by a period of several years in which he ceased to employ the heroic couplet in poetry of any sort. The reasons for this temporary abandonment of what had been, hitherto, a favorite measure, are not altogether clear, although his action may be ascribed, in part, to his renunciation of things English and to the influence upon him of his study of the Italians. During his residence in Italy, Byron used many metrical forms: the Spenserian stanza, ottava rima, terza rima, blank verse, and other measures in some shorter lyrics and ephemeral verses. Not until The Age of Bronze, which he began in December, 1822, did he return to the heroic couplet of EnglishBards.

On January 10, 1823, Byron, then living in Genoa, wrote a letter to Leigh Hunt, in which, among other things, he said: “I have sent to Mrs. S[helley], for the benefit of being copied, a poem of about seven hundred and fifty lines length—TheAgeofBronze—or Carmen Seculare et Annus haud Mirabilis, with this Epigraph—‘Impar Congressus Achilli’.” By way of description, he added: “It is calculated for the reading part of the million, being all on politics, etc., etc., etc., and a review of the day in general,—in my early EnglishBardsstyle, but a little more stilted, and somewhat too full of ‘epithets of war’ and classical and historical allusions.”377 The work as revised and completed contains 18 sections and 778 lines. Originally destined for The Liberal, it was eventually published anonymously by John Hunt, on April 1, 1823.

The Age of Bronze is, then, entirely a political satire, intended chiefly as a counterblast to the recent stringent regulations of the reactionary Congress of Verona (1822). It comprises, however, other material: an introductory passage on the great departed leaders, Pitt, Fox, and Bonaparte; frequent digressions treating of the struggles for constitutional government then taking place in Europe; and some lines attacking the landed proprietors in England for their luke-warm opposition to foreign war. It is, in nearly every sense, a timely poem, although the note of “Vanitas Vanitatum” sounded in the early sections gives the satire a universal application.

For a comprehension of Byron’s motives in writing The Age of Bronze, it is necessary to understand something of the situation in Europe at the time. Following the numerous insurrections of 1820–22 in Spain, Portugal, Naples, Greece, and the South American States, the European powers, guided by the three members of the Holy Alliance, Russia, Prussia, and Austria, sent delegates to meet at Verona on October 20, 1822, for a consideration of recent developments in politics. The leading figure at the conference was Metternich, the Austrian statesman, although Francis of Austria, Alexander of Russia, and Frederick William of Prussia were among the monarchs present. Montmorenci, representing an ultra-royalist ministry under Villiele, was there to look after the interests of France; while England, deprived at the last moment of Castlereagh’s services by his suicide, sent Wellington. The gathering finally resolved itself into a conclave for the purpose of discussing the right of France to interfere in the affairs of Spain, by restoring Ferdinand VII, a member of the House of Bourbon, to the throne of which he had been deprived by the Constitutionalists. Wellington, after protesting against the agreement reached by the other envoys to permit the interference of France, left the Congress,378 by Canning’s instructions, in December. His withdrawal, however, did not affect the ultimate decision of the Congress to stamp out revolt whenever it assailed the precious principle of Legitimacy. War between France and Spain broke out in 1823; Ferdinand VII was replaced upon his tottering throne; and the despotic policy of Metternich triumphed,

for a time, over democracy. Canning’s only reply was to recognize the independence of the rebellious colonies of Spain, and to assert the belligerency of the Greeks, then fighting for their liberty against the Turks.

It is to the year which saw the work of the Congress of Verona that Byron’s secondary title, Annus haud Mirabilis, obviously refers. In a striking passage in the beginning of the poem, he pays a tribute to the mighty dead, contrasting, by implication, the leaders of the Congress with the departed heroes: Pitt and Fox, buried side by side in Westminster Abbey; and Napoleon,

“Who born no king, made monarchs draw his car.”

The summary which Byron presents of Napoleon’s career is full of admiration for the fallen emperor’s genius, and of resentment at the indignities which, according to contemporary gossip, he had been compelled to undergo on St. Helena. The man “whose game was empires and whose stakes were thrones” was forced, says the poet, to become the slave of “the paltry gaoler and the prying spy.” The passage is both an appreciation and a judgment, wavering, as it does, between sympathy and condemnation for the conqueror who burst the chains of Europe only to renew,

“The very fetters which his arm broke through.”

The reference to these giants of the past leads Byron naturally to a glorification of such liberators as Kosciusko, Washington, and Bolivar, and to a joyful heralding of revolutions in Chili, Spain, and Greece:

“One common cause makes myriads of one breast, Slaves of the east, or helots of the west; On Andes’ and on Athos’ peaks unfurl’d, The self-same standard streams o’er either world.”

Under the influence of this enthusiasm he prophecies a liberal outburst which will end in the regeneration of Europe.

Contrasted with the optimism of this aspiring idealism is Byron’s gloom over the deeds of the Congress of Verona. The measures advocated by this gathering, as we have seen, were reactionary and autocratic; and Byron’s description of it, tinged with liberal sentiment, is vigorously satirical. In the conference headed by Metternich, “Power’s foremost parasite,” he can see nothing but a body of tyrants, “With ponderous malice swaying to and fro, And crushing nations with a stupid blow.”

Many of the allusions in Byron’s sketches of the members recall the language used by Moore in his Fablesfor theHolyAlliance. Moore’s views of the situation in Europe agreed substantially with those of Byron. Byron’s reference to the “coxcomb czar,”

“The autocrat of waltzes and of war,” recalls Moore’s mention of that sovereign in FableI:

“So, on he capered, fearless quite, Thinking himself extremely clever, And waltzed away with all his might, As if the Frost would last forever.”

Byron accuses Louis XVIII, who was not present at the Congress, of being a gourmand and a hedonist,

“A mild Epicurean, form’d at best To be a kind host and as good a guest.”

The same idea is conveyed in Moore’s description of that king as,

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