Voluntary Standards Program
CRE's Voluntary Standards Program, (VSP) provides services to
industry which support the development and recognition of standards developed by
the private sector.
CRE offers three key services under the VSP:
Organization of a Standard Setting Body;
Accreditation of A Standard Setting Body; and
Regulatory Support Services.
Specialized services may be developed on request.
Organization of a Standard Setting Body
Market-Driven Consortia offer industry the unprecedented
opportunity to quickly develop voluntary technical standards without going
through a time-consuming and expensive ANSI-style development process. In
addition to their utility to industry, MDC standards are eligible for regulatory
use by government agencies. Furthermore, an MDC standard may obtain consensus after
development to enhance its status (see Standards Accreditation Assistance).
CRE offers two types of Standards Development Assistance
- Analysis and specific recommendations as to whether your standard
development needs are better met through a consensus or MDC process.
- Assistance with creation and management of an MDC targeted to meet your
specific standard-development needs. Assistance includes: stakeholder
identification; organization development; development of operating
procedures; legal (antitrust, intellectual property protection;
confidentiality); and liaison with Standards Development Organizations
supporting MDC activities.
Accreditation of A Standard Setting Body
Standards developed through an MDC process may be put through a
canvassing process to obtain ANSI accreditation after they have been developed.
ANSI accreditation is a major factor in increasing the stature of a standard.
Such accreditation is most important if the standard is intended for regulatory
or international acceptance. CRE offers two different types of Accreditation
- CRE, a member of ANSI's Company Member Council, will develop and conduct
an action plan for obtaining ANSI accreditation of an MDC-developed
standard. Accreditation Assistance planning may be undertaken simultaneously
with Development Assistance to enhance the ability of the standard to
- As an alternative to ANSI accreditation, CRE offers the CRE Consensus
Documentation Audit (CDA). The CDA is an independent examination of a
standard development process to determine if it complies with the definition
of consensus contained in OMB Circular A-119 which sets federal policy
regarding the regulatory use of voluntary consensus standards. The CRE CDA
is unaffiliated with ANSI.
Regulatory Support Services
The National Technology Transfer and Advancement Act provides a
strong legal presumption in favor of the regulatory use of voluntary consensus
standards over the use of government-unique standards. OMB Circular A-119
provides specific implementing regulations for agencies to follow when using
or rejecting voluntary consensus standards. The OMB Circular also provides a
potential role in regulation for private non-consensus standards.
Despite the requirements contained in the Act and the OMB
Circular, agencies, and industry, are often not fully aware of government
responsibilities to utilizes domestic and international standards. CRE offers
the following Regulatory Support Services:
Discussions with regulatory agencies during the development of proposed
regulations to support inclusion of relevant private standards;
Analysis of proposed regulations to ascertain compliance with all
requirements of the Act and OMB Circular; and
Cooperative work with various stakeholders, including members of the
standards development community, to provide broad-based support for agency use
of voluntary consensus standards in lieu of government-unique standards in
regulation and procurement.
If necessary, CRE may provide advice and support in exploring
litigation options for compelling agency compliance with their statutory duties.
CRE would be compensated on a monthly retainer basis for services
provided under the Voluntary Standards Program.
Use of voluntary standards may provide industry with:
-- Significant operating flexibility and cost savings compared to use of
government-unique standards; and
-- Additional business opportunities compared with operating in a
The CRE Voluntary Standards Program can assist industry in achieving
new business opportunities and minimizing expensive constraints.
CRE Expertise in Voluntary Standards
CRE's Standards Program has strong experience regarding the
regulatory application of voluntary consensus standards. CRE's standards work
and related experience includes:
Publishing a landmark white paper, Market-Driven Consortia:
Implications for the FCC's Cable Access Proceedings, weighing the use of
consensus standards versus privately developed non-consensus standards in
regulatory applications. Based on this paper, ANSI took the initiative in:
– Distributing the CRE paper to all member of their Company Member
-- Inviting CRE to be one of two presentors to discuss our work on
standards before the CMC Executive Committee; and
– Inviting CRE to make a special presentation to senior ANSI officials in
CRE has formed the Cable Access Standards Exploratory Committee to
further develop issues concerning the regulatory application of private
standards which were outlined in the white paper. Committee membership
includes representatives of major regional and long distance
telecommunications companies and Internet Service Providers.
CRE has in-depth expertise in the application of National Technology
Transfer and Advancement Act, which provides statutory preference in favor of
the regulatory use of voluntary standards, and OMB Circular A-119 which
implements the Tech Transfer Act. The CRE Advisory Board consists of former
career chiefs of OMB’s Office of Information and Regulatory Affairs, the
federal agency responsible for publishing and revising Circular A-119.
CRE routinely comments on standards issues in agency rulemakings.
CRE hold discussions with senior agency staff of the applicability of
standards to regulatory proceedings.
CRE provides advice to ANSI and to standard development organizations
on how and why to incorporate federal "good government" laws into
their operating procedures when developing standards intended for regulatory
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