Standards Boards and Bodies
Definition: In many instances, MITRE's systems engineering and subject matter expertise is brought to bear in helping committees produce industry standards. Industry standards typically require the consensus of the committee's members, which may include representatives from government or industry or both. MITRE's contributions include direct technical contributions, managing committees and their documents, and helping to moderate negotiations between committee members to bring about consensus.
Keywords: AIEE, ASE, consensus documents, IEEE, negotiations, RTCA, standards
MITRE SE Roles & Expectations: MITRE systems engineers (SEs) need to understand the objectives of the standards body that is producing the standard, typically articulated in Terms of Reference for the committee. They should ensure that the goals of the standards committee, the MITRE work program, and sponsor are in alignment. SEs are expected to bring expert technical analyses and discipline to the standards process by providing objective data relevant to the topic of standardization.
MITRE's interest in standards board participation is in establishing the best standards to further technology and industry implementation to improve interoperability across government capabilities. Participation in standards bodies provides opportunities to bring the world to bear on our customers' problems, and collaborate with other FFRDCs, industry, and academia.
Standards committees have historically provided standards that allow for compatibility of equipment produced by different vendors, or that provide for minimum safety of equipment or devices. For example, the Radio Technical Commission for Aeronautics (RTCA) develops standards for aircraft equipment that allow multiple vendors' equipment to be cross compatible within the aircraft, from aircraft to ground systems, and between neighboring aircraft. Another example is minimum requirements for electrical equipment.
Standards bodies are typically attended voluntarily by participating government and industry organizations that send experts on standardization. Government employees may work directly with industry in developing the standards. Usually standards bodies' meetings are open to participation and to the public.
Most standards are agreed upon by consensus; that is, all participating organizations agree to the requirements represented in the standard. Arriving at a consensus can be challenging and time consuming, which is a principal reason why standards sometimes take substantial time to produce. MITRE's expertise and objectivity can be key to brokering consensus.
Government Interest and Use
Many U.S. federal, state, and local government agencies depend on voluntary consensus standards. In many cases, the U.S. government relies on standards bodies to provide input to potential government rules and regulations. RTCA, for example, functions as an advisory committee to the Federal Aviation Administration (FAA) under the U.S. Federal Advisory Committee Act of 1972 . RTCA standards, when accepted by the FAA, may become the basis for FAA Technical Standard Orders, which govern the requirements for equipment manufacture, or FAA advisory circulars, which provide advice on equipment installation, usage, etc.
An agency may adopt a voluntary standard without change by incorporating the standard in an agency's regulations or rules. Depending on the relationship of the standard body to the government, the government may adopt the standard with certain exceptions. In other generally exceptional cases, the government may ignore the standard outright. Under the U.S. Federal Advisory Committee Act, for example, a voluntary consensus standard is submitted to the government as advice, and the government is under no obligation to accept that advice. MITRE systems engineers can play an important role in brokering agreements between government and industry to ensure that the standards are accepted and utilized by government agencies .
In some cases, standards become the basis for rulemaking by the government. In this situation, the government will first propose the rule in the Federal Register as a notice to the public, known as a Notice of Public Rulemaking. At this stage, the public is invited to comment on the proposed rule. All comments must be considered by the government in advance of issuing a final rule. The government's response to the comments becomes a matter of public record. The relevant standards may form a substantial basis for the final rule; in some cases, a standard may be one accepted means of compliance, may be the basis for guidelines for compliance, or voluntary compliance with a given standard may be accepted in lieu of formal rulemaking .
The U.S. federal government updates The Code of Federal Regulations (CFR) once per year. The CFR contains all the rules published by the U.S. federal government. The CFR is divided into various areas of regulation .
Standards Best Practices and Lessons Learned
- Objectivity is paramount. MITRE must act, and be viewed, as an objective participant, since our goal is to be able to moderate negotiations. Committee participants should make sure that all perspectives are considered fairly, even though some perspectives may conflict with our sponsor's point of view. MITRE's role is to bring objective analysis to the table for all parties to consider. It is highly desirable to bring analytical results to the conversation to inform the discussions. In lieu of analytical data, objective expert opinion should be clearly articulated.
- Bring the best expertise to the table. Committees are usually public forums in which MITRE's reputation and credibility are at stake. Most organizations tend to staff committees with their most senior and knowledgeable staff; MITRE should do no less. Specific subject matter expertise should be brought into conversations whenever appropriate; key staff should be on call to serve in these roles.
- Involvement in committee leadership is an asset. One way to demonstrate MITRE's influence and objectivity more effectively is for MITRE participants to be involved in the committee leadership. MITRE roles have varied from high-level leadership positions in the overall organization (e.g., leading the RTCA Program Management Committee), leading special committees, leading working groups under the larger committees, and taking on the role of committee or working group secretary. All of these types of leadership roles reflect well on the company and put MITRE in a position of regard and influence.
- Hold the pen. It might seem like a tedious job, but volunteering to manage the standards document puts MITRE in an effective position to help assume a key responsibility for the development of the standard. The book manager may be personally responsible for significant textual input to the standard. In addition, the book manager is responsible for coordinating inputs from various authors, managing configuration control, incorporating updates to the document, and ensuring that all comment resolutions are implemented as agreed.
- Standards development should be a disciplined process. There should be clear, agreed procedures for running meetings with a leader who can moderate the conversation such that all voices are heard while progress and decisions are made. Documents should be developed with a clear configuration management plan. After a rough draft, documents should be reviewed and a record of comments and their dispositions, usually in the form of a comment matrix, should be maintained. A written record of proceedings is essential so that issues that have been discussed and dispositioned are not reopened.
- Work difficult issues or specific sub-tasks in smaller subgroups. A key manner in which to accelerate the standards development process is to assign small groups to work out and agree on key technical points. In some instances, a small, ad hoc group may be formed to make recommendations on a specific issue. In other cases, more formal, long-term subgroups may be formed to draft whole sections of a standard. In any case, a "divide and conquer" approach is usually more effective in bringing acceptable proposals back to a larger group, rather than having a large group debate a given topic.
References & Resources
- The Federal Advisory Committee Act, October 6, 1972, and the Federal Advisory Committee Act Amendments of 1997, December 17, 1997.
- ANSI, "U.S. Government Use of Voluntary Consensus Standards," http://www.standardsportal.org/, accessed February 22, 2010.
- Office of Management and Budget, February 10, 1998, "OMB Circular No. A-119: Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities."
- GPO Access, "U.S. Code of Federal Regulations," accessed February 22, 2010.
Additional References & Resources
The MITRE Corporation, "Tradeoff & Engineering Analysis," MITRE Project Leadership Handbook, accessed February 22, 2010.
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