evaluating requirements for standards in legislation pamela androff washington internship for...
TRANSCRIPT
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Evaluating Requirements for Standards in Legislation
Pamela Androff
Washington Internship for Students in Engineering
Sponsored by ASHRAE
August 6th, 2008
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Outline
• Background Information• Explanation of Issue• Key Conflicts and Concerns• Discussion• Recommendations• Conclusion
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What are standards?
Standards are a baseline for a particular science or technology
• Used as the minimum requirement
• Easily communicate specifications
• Common understanding
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Why do we have standards?
Commodification Compatibility Interoperability
Safety Repeatability Quality
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Standards are not required!
• Standard = voluntary
• Code = requirement• A standard can become code if it is mentioned
in legislation
• Accreditation = an acceptable practice• An accredited body can employ a certain
technique
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The Problem
Policy makers want a specific target or goal out of industry
Requirements for new goal are written directly into legislation
Becomes a requirement for the industry
Policy makers want a specific target or goal out of industry
Policy maker knows that industry generally uses a standard for its work
In the legislation, SDOs are given targets to meet
SDO is responsible for developing new standard
Common Practice New Issue
Energy Information Administration, 2003
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Commercial Energy Usage
Lighting23%
Water Heating15%
Other7%
Office Equipment6%
Refridgeration3%
Cooking4%
Cooling7%
Ventilation3%
Space Heating32%
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H.R. 3221, Section 9031
“The Secretary shall support updating the national model building energy codes and standards at least every three years to achieve overall energy savings, compared to the 2006 IECC for residential buildings and ASHRAE Standard 90.1 2004 for commercial buildings, of at least—
(A) 30 percent by 2010;
(B) 50 percent by 2020; and
(C) targets to be set by the Secretary in intermediate and subsequent years, at the maximum level of energy efficiency that is technologically feasible and life-cycle cost effective.
…If the Secretary makes a determination…that a code or standard does not meet the targets…then the Secretary shall within 12 months propose a modified code or standard that meets such targets.”
The Renewable Energy and Energy Conservation Tax Act of 2007
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Key Conflicts and Concerns
• Interference in current process• Pressure on SDOs• Details of a government standard
replacing current standard• Current government documentation
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Standard Developing Process
• Standards developed since the late 1800s
• American National Standards• Balance• Openness• Consensus
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Standard Developing Organizations
• Difficulty in meeting the given timeline• Voting members must come to a consensus• Resources (staffing, funding for meetings, etc.) unavailable to
expedite the process
• Difficulty in meeting the target percentages• New technology available to meet the requirements?• Voting members must come to a consensus
• In an extreme situation, current due process may be forgone to meet requirements
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Government Standard
• No details are given in legislation
• Who will maintain or ‘own’ the standard?
Toth, StandardView Vol. 4, No. 4, December/1996
US Standards93,000
Federal Government44,000
Private Sector49,000
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Current Government Documents
• National Technology Transfer and Advancement Act (1996)
“ …all Federal agencies and departments shall use technical standards that are
developed or adopted by voluntary consensus standards bodies, using such
technical standards as a means to carry out policy objectives or activities
determined by the agencies and departments."
• OMB A-119
“All federal agencies must use voluntary consensus standards in lieu of
government-unique standards in their procurement and regulatory activities, except
where inconsistent with law or otherwise impractical.”
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Discussion
Form of organization Characteristic
Autocracy The boss decides
Bureaucracy Guided by formal rules and procedures
Diplomacy Personal processes to determine content and approval
Democracy All interested parties are welcome in drafting and approval.
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Discussion
• European Union• New Approach (Council Resolution, May 1985)
• 3 SDOs• The EC provides “essential requirements”
• China• Standardization Administration of China (Est. 2001)
• Manage all standard activities• 260 technical committees, 300 subcommittees
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Discussion
• America is unique!• Over 700 SDOs• Dynamic standard developing process
• Important to preserve our current process
• Standards are widely accepted due to the current process
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Recommendations
1. Eliminate requirements in legislation• Responsible party: policy makers• Action needed: lobbyists, constituents
2. Redefine standardization and re-educate stakeholders• Responsible party: SDOs• Action needed: SDOs, standard developers
3. Increase funding in Research and Development• Responsible party: policy makers• Action needed: lobbyists, constituents
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Conclusion
• Standards in legislation is an important issue to the standards-writing community
• A open, balanced process is used to develop standards that should be preserved
• Goals and targets should be left as that; not set as requirements
• Action needs to be taken to resolve the issue
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Questions and Comments?
Pamela Androff
Acknowledgements• Doug Read and Ryan Colker, ASHRAE• Dr. Jeff King, Faculty Member in Residence• Melissa Carl, ASME and Erica Wissolik, IEEE• John Budyos, Library of Congress• Fellow interns