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Bottom-up: how standards should be made

Standards development works best when the expert community is open to diverse and dissenting views. The door is already open to the government to listen, participate and propose. If it isn’t broken don’t try to fix it.
About the author: As CEO of the PDF Association and as an ISO Project Leader, Duff coordinates industry activities, represents industry stakeholders in a variety of settings and promotes the advancement and adoption of … Read more
Duff Johnson

Duff Johnson
April 14, 2021


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A recent article on IEEE Spectrum discussed various models for standards development currently under consideration by the US-China Economic and Security Review Commission created by Congress in 2010. In particular the article focussed on the Commission’s proposal that Congress adopt a “top-down” approach to government involvement in standards development. The authors, Professors Coopersmith and Yates, offer a caution against this approach, and advocate for the more organic process that has typified successful standards development in the USA and around the world for over 100 years.

My view is based on my active involvement with technical standards development for PDF technology since 2004. In this domain, at least, the article’s authors are right: standards work best for everyone when they are developed openly, without thumbs on the scales. Maintaining an open door to all stakeholders from across the globe, encouraging insights from all corners, accommodating all use-cases and basing decisions on consensus understandings are vital features of effective technical standardization.

The right venue for government agencies that take an interest in technical standards is to participate in and support the organic industry associations that help develop and coordinate existing stakeholder efforts to maintain and advance their standards. Engagement with industry associations at the subject matter expert level is a potent way to represent government interests and foster information exchange. The government gains expertise, skills and context; industry members benefit from understanding government perspectives and concerns. The PDF Association is an excellent example; the organization regularly communicates with interested experts in a variety of member government agencies such as the Library of Congress, the National Archives and Records Administration (NARA) and the US Accessibility Board, answering their questions and seeking their input on future development of technical specifications.

Industry associations do more than simply advance industry perspectives; they offer a unique venue for the development and evolution of technical analysis and understanding. Engagement with associations, consortia and other assemblies of stakeholders allows government agencies to study technical programs without necessarily attempting to direct or shape them. Industry associations can help governments (or anyone else, frankly) see into the future of any given technology far more that a government agency is ever likely to be able to do for itself (unless it is the industry’s principal customer).

Government agencies should also be aware that in many or even most cases, ISO ballots and similar publication-stage standards activities already occur at the national level. In many cases a technical standard’s requirements are fashioned, debated and (within the industry) determined within industry association working groups, even though these groups have no ballot at the ISO table. Drafts of all technical standards are then balloted to become international ISO standards, with each national body having a single vote.

A new agency or commission won't improve standards development. Instead, Congress should encourage agencies to seek out and engage with the various associations, working groups, consortia, alliances and others self-forming groupings of experts, and leverage the manifest energy and expertise that already drive these stakeholder groups forward. These forums already exist to give all stakeholders a voice.

Congress should also understand that the Commission’s notion regarding promotion of national interests in standards development is already conventional. In the ISO standards approval process, for example, each ISO national member body takes a unified position representing the aggregated interests of their country’s members. For example the American National Standards Institute’s Technical Advisory Group for ISO TC 171 SC 2 - my own standards development community - represents US interests concerning development of the technologies within our subcommittee’s remit (in our case, standards for digital document formats). US government agencies with interests in this area are already participating alongside industry experts to advance US national interests.

Standards development works best when the community of experts is open to diverse and dissenting views, and where national interests get a seat at the table alongside commercial and end-user interests. The door is already open to the government to listen, participate and propose. Congress should not try to fix what’s not broken.

NOTE: Government agencies interested in PDF and associated technologies are welcome to join the PDF Association as Liaison Members. US federal and state agencies can participate in ISO meetings at no cost as part of the US delegation via the PDF Association-managed ISO TC 171 SC 2. Contact Betsy Fanning, PDF Association Standards Director, for more information.

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