The education industry – particularly large research universities — are likely stakeholders in this discussion – which NIST will expand outside the policy-making precincts of Washington DC. Standards Michigan collaborates with the American National Standards Institute on issues of this nature.
Comments are due July 30th. Ahead of this deadline a series of meetings will be hosted by NIST — both online and on-site — from May 17 through May 31. See the the first page of the Federal Register Notice [Docket Number: 180220199–819–01] for more information.
All NIST activity is on the standing agenda of our weekly Open Door teleconferences; every Wednesday, 11 AM Eastern time which are open to everyone. Click here to log in.
Issue: [18-122]
Category: US Department of Commerce, Public Policy
“View of Malakoff Hauts de Seine” | Henri Rousseau, 1903
For over 50 years the IEEE Color Books have set the standard of care for electrical power system design, construction, operation and maintenance. Reference to the Color Books usually show up in contracts that assert: “Conform to all applicable IEEE standards“.
While the Color Books are not written in the transitive language required of a “code” that can be incorporated by reference into public safety legislation[1] ; the Color Book committees have traditionally provided the most authoritative technical foundation for documents for the NFPA family of electrical safety documents. The Color Books continue to be referenced into the National Electrical Code, for example; though that has been changing [2]; and the rate of that change will gather pace. Competition from other trade associations that want to claim ownership of the regulatory landscape for the emergent #SmartCampus will make it so.
The IEEE committees are populated largely by electrical professionals; the NFPA committees are populated by a balance of subject matter experts largely informed by the fire safety culture. The leadership of electrical safety in the United States a fire safety organization is unique in the world. In other nations that adopt derivatives of Technical Committee 64 of the International Electrical Code Commission the subject matter experts are largely electrical industry professionals. The regulatory product of TC 64 is the IEC 60364 series of interdependent electrical safety documents are developed in relatively small, swiftly-moving modules and are referenced in Article 90 of the National Electrical Code. This is important because IEEE — the largest professional association in the world — has been migrating toward the more global IEC standards development model which features a constellation of interdependent modules.
Now comes another in a series of formal announcements by the IEEE Standards Association that another legacy Color Book will be allowed to lapse so that it can be superceded by its replacement in the 3000-suite[3].
IEEE Standards association formally announced it in this week’s ANSI Standards Action | PDF Page 13. Note that several other Color Books — notably the White Book ANSI/IEEE 602-2007, Recommended Practice for Electric Systems in Health Care Facilities — will also be allowed to lapse.
This means that design, construction, operations and maintenance documents that reference them as the standard of care will require an update.
Category: Electrical, Telecommunications, Facility Asset Management, #SmartCampus, Public Safety
Colleagues: Mike Anthony, Robert G. Arno, Neal Dowling, Gary Fox, Karen Evangelista, Jim Harvey, Andrew Hernandez, Christel Hunter, Daleep Mohla, Sergio Panetta, Dev Paul, Robert Schuerger, Joe Weber
[1] The requirement to be a “code” carries specific requirements for public access which places a financial responsibility upon the consensus document developers. ANSI accredited standards developers are accredited with consideration for conformity to ANSI due processes. The accreditation applies to their entire family of documents; however not all documents qualify as an ANSI accredited document that can be referenced into public safety law.
[4] This document is heavily referenced in telecommunication, information and computer technology standards
[5] This document is referenced in Article 700 of the National Electrical Code, establishing formal reliability concepts for emergency power systems.
[6] European electrical safety concepts evolved around shock hazard because, a) user exposure to a higher outlet utilization voltage of 220-240V and b) recognition of the diverse configuration European utilization outlets owing to the diversity of national electrical equipment markets.
Our tenure in consensus standards development for education facilities (see ABOUT) may enlighten local, state and federal authorities about the present status of leading practice discovery as reflected in the action of ANSI accredited and open source standards. Since local first-responders are aligned with the building and fire codes we follow the development of the documents that establish the standard of care for their responsibilities. Some of the most recent action within the more familiar standards suites is linked below:
This is a timely, subtle and complicated issue for the education industry to resolve. The overwhelming question — upon which good minds will disagree — is this: How much of this can be resolved by the federal government versus resolution at the state, local and institutional level?
Market incumbents (whom we identify in our ABOUT) want to develop regulations at the national level because they have the financial resources to operate in Washington, D.C where so many education industry trade associations are domiciled and have their influence. In other words, they will seek a politically visible “top-down” solution that they write and administer.
On the other hand, school districts, colleges and universities may prefer local adaptations of regulatory products developed by ANSI accredited standards developers with which their front line subject matter experts in building, fire, electrical and public safety codes are already trained. Standards developed at this level — and, ideally incorporated by reference by federal agencies, offer the greatest degree of transparency and stakeholder involvement. Unfortunately, much of the leadership of the education industry is not involved in the US standards community. (See videoclip below)
Since our business model does not depend upon revenue from membership, publication royalties, conference attendance, continuing education credits for conformity assessment credentials we are relatively free to operate as a watchdog on the standards action of all the incumbents (and newcomers) in this space.
Education facility security standards are a standing item on our weekly Open Door teleconference — every Wednesday 11 AM Eastern time. Click here to log in.
Issue: [Various]
Category: Public Safety, Public Policy
Colleagues: Mike Anthony, Richard Robben
S. Joe Bhatia | CEO American National Standards Institute | University of Michigan Ross School of Business | October 2015
It is difficult finding subject matter experts within the education industry — both on the academic and business side — to help develop and advocate user-interest position in global electrotechnology standards. Academics respond to funding opportunities; either from the government or from incumbent, competitor stakeholders in the global standards system. The business side of the education industry is unable to bear the complexity and expense of supporting an expert over a long enough period of time where that voice is effective in advocating safer, simpler, lower-cost and longer-lasting campuses. As we explain in our ABOUT, effectiveness requires the sensitivity of education industry leadership to long and deep cycle undertakings — and a willingness to accept that results are subtle and oftentimes politically invisible in prospect. In retrospect, however; the stream of subtle changes accumulate into techtonic movement in technology and economics which benefits both sides of the education industry.
Nevertheless, we continue to try; and pass on to our rapidly growing cadre of website visitors, calls for new committee members.
The US National Committee to the International Electrotechnical Commission (USNA/IEC) has recently sent out a Call for Members in this week’s ANSI Standards Action Page 42. Subject matter experts are needed for the following committees:
If education industry subject matter experts are interested in participating in any of these groups, please contact Kendall Szulewski-Francis, USNC Program Administrator, at ksfrancis@ansi.org. We note that all IEC standards on the standing of our own weekly Open Door teleconference every Wednesday, 11 AM Eastern time. (Click here to log in)
Also, insofar as electrotechnology in the education facilities is concerned, the IEEE Education & Healthcare Facilities Committee (IEEE E&H) — as a group with American and European members — also follows IEC standards according to the requirements of the various national committees administered by CEN/CENELEC. The IEEE E&H Committee meets online twice this coming Tuesday, May 22nd.
Issue: [Various]
Category: Electrical, Telecommunications, Information Communications & Technology, #SmartCampus, International
Colleagues: Mike Anthony, Jim Harvey, Giuseppe Parise
We follow, but do not advocate in, a suite of consensus standards developed by theFinancial Accounting Standards Board (FASB) — among them, documents that discover and recommend best financial management practice for not-for-profit organizations common in almost all of the US education industry.
Today, we simply pass on an announcement posted on the FASB website about a June 15th webcast during which there will be some content that would interest financial professionals in the education industry:
Stakeholders in the US education industry are encouraged to communicate directly with the FASB on any issue (Click here).
The FASB suite is a standing item on our weekly Open Door teleconferences (every Wednesday, 11 AM Eastern Time) which are open to the public. Login information can be found in the link below:
We have seen an acceleration in the growth in website visitors over the past few months. We would like to reach out specifically to the vast constellation of education industry trade associations who visit Standards Michigan as a resource for streaming content relevant to their advocacy goals.
“Pythagoras and the beautiful Theano” (1913) | Artist unknown
We track broad policy trends, but do not advocate our agenda, in the legislative precincts of the US federal government. There is plenty of work to do in technical, management, safety and sustainability standards for the emergent #SmartCampus. Education policy is a space crowded with “market incumbents”, so to say, as some of the related links below should reveal. Sorting through the Orwellian fog, we see the broad contours of emergent legislation that will likely have some affect on the flow of money to the physical characteristics of our cities-within-cities.
On May 7th, Senate bill S 2791 – A bill to amend the Higher Education Act of 1965 to provide grants for institutions of higher education to prevent substance abuse, and for other purposes — was logged into the US Senate’s legislative calendar.
A summary is now in progress and will be posted at this link: Congress.GOV
Related information:
Promoting Real Opportunity, Success, and Prosperity through Education Reform: Prosper Act
We see how other industries apply technical and business standards to meet their organizational goals so it is natural for us to ask about the degree to which adoption of privately developed consensus standards accredited by the American National Standards Institute would be an effective tool for driving down the cost of higher education in the United States. Education — about 4 percent of gross domestic product — is an industry which, arguably, is built upon a foundation standards and related accreditation enterprise. A baccalaureate degree is, after all, a standard.
Even as the legislative activity on revising/reauthorizing the Higher Education Act of 1965 is already in motion* we see three related developments that might enlighten understanding about how standards support regulation, and how regulation determines cost:
In 1985 the ISO 9000 suite of standards began rolling out in many industries that had revenue streams originating in other nations.
The National Technology Transfer & Advancement Act — the parent legislation for many industries to develop their own standards (rather than standards written by the federal government) — was passed in 1996.
The number of organizations accredited by the American National Standards Institute as accredited standards developers for documents suitable for incorporation by reference by federal, state and local agencies has grown steadily.
December 1, 2017 Update from the House Committee on Education and the Workforce: (Click here)
The parent legislation for the US higher education industry is the Higher Education Act of 1965; available in its entirety at this link:
AN ACT: To strengthen the educational resources of our colleges and universities and to provide financial assistance for students in postsecondary and higher education.
AN ACT: To extend the authorization of programs under the Higher Education Act of 1965, and for other purposes.
The sections of interest to us are highlighted below:
‘‘SEC. 143. ADMINISTRATIVE SIMPLIFICATION OF STUDENT AID DELIVERY.
‘‘(a) IN GENERAL.—In order to improve the efficiency and effectiveness of the student aid delivery system, the Secretary and the Chief Operating Officer shall encourage and participate in the establishment of voluntary consensus standards and requirements for the electronic transmission of information necessary for the administration of programs under title IV.
‘‘(b) PARTICIPATION IN STANDARD SETTING ORGANIZATIONS.— ‘‘(1) The Chief Operating Officer shall participate in the activities of standard setting organizations in carrying out the provisions of this section. ‘‘(2) The Chief Operating Officer shall encourage higher education groups seeking to develop common forms, standards, and procedures in support of the delivery of Federal student financial assistance to conduct these activities within a standard setting organization. ‘‘(3) The Chief Operating Officer may pay necessary dues and fees associated with participating in standard setting organizations pursuant to this subsection.
‘‘(c) ADOPTION OF VOLUNTARY CONSENSUS STANDARDS.—Except with respect to the common financial reporting form under section 483(a), the Secretary shall consider adopting voluntary consensus standards agreed to by the organization described in subsection (b) for transactions required under title IV, and common data elements for such transactions, to enable information to be exchanged electronically between systems administered by the Department and among participants in the Federal student aid delivery system.
‘‘(d) USE OF CLEARINGHOUSES.—Nothing in this section shall restrict the ability of participating institutions and lenders from using a clearinghouse or servicer to comply with the standards for the exchange of information established under this section.
‘‘(e) DATA SECURITY.—Any entity that maintains or transmits information under a transaction covered by this section shall maintain reasonable and appropriate administrative, technical, and physical safeguards— ‘‘(1) to ensure the integrity and confidentiality of the information; and ‘‘(2) to protect against any reasonably anticipated security threats, or unauthorized uses or disclosures of the information.
‘‘(f ) DEFINITIONS.—
‘‘(1) CLEARINGHOUSE.—The term ‘clearinghouse’ means a public or private entity that processes or facilitates the processing of nonstandard data elements into data elements conforming to standards adopted under this section.
‘‘(2) STANDARD SETTING ORGANIZATION.—The term ‘standard setting organization’ means an organization that— ‘‘(A) is accredited by the American National Standards Institute; ‘‘(B) develops standards for information transactions, data elements, or any other standard that is necessary to, or will facilitate, the implementation of this section; and ‘‘(C) is open to the participation of the various entities engaged in the delivery of Federal student financial assistance.
‘‘(3) VOLUNTARY CONSENSUS STANDARD.—The term ‘voluntary consensus standard’ means a standard developed or used by a standard setting organization described in paragraph (2).’’. (b) REPEAL OF OLD GENERAL PROVISIONS.—Title XII (20 U.S.C. 1141 et seq.) is repealed. PUBLIC LAW 105–244—OCT. 7, 1998 112 STAT. 1617 (c) REPEAL OF TITLE IV DEFINITION.—Section 481 (20 U.S.C. 1088) is amended— (1) by striking subsections (a), (b), and (c); and (2) by redesignating subsections (d) through (f ) as subsections (a) through (c), respectively.
We provide a link to an overview of the American National Standards Institute in the link below.
The IAPMO Group has launched the 2021 revision cycle for the Uniform Mechanical Code; widely incorporated by referent into public safety law in many states.
BSR/IAPMO UMC 1-20xx, Uniform Mechanical Code (UMC). This code provides minimum standards to safeguard life or limb, health, property, and public welfare by regulating and controlling the design, construction, installation, quality of materials, location, operation and maintenance, or use of heating, ventilating, cooling, refrigeration systems, incinerators and other miscellaneous heat-producing appliances. The provisions of this code apply to the erection, installation, alteration, repair, relocation, replacement, addition to, use, or maintenance of mechanical systems.
This document is developed so that its technical concepts correlate with the Uniform Plumbing Code (UPC). The UPC provides standards and requirements to safeguard life or limb, health, property and public welfare by regulating and controlling the design, construction, installation, quality of materials, location, operation and maintenance or use of plumbing systems. The provisions of this code apply to the erection, installation, alteration, repair, relocation, addition to, use, or maintenance of plumbing systems.
Project Need: Designation of the UMC as an American National Standard has provided the built industry with uniform mechanical standards resulting in a reduction in training costs and product development costs, and in price reduction for consumers. This American National Standard provides consumers with safe mechanical systems while allowing latitude for innovation and new technologies. This project is intended to keep the code current.
Stakeholders: Manufacturers, users, installers and maintainers, labor research/standards/testing laboratories, enforcing authorities, consumers, and special experts. *
The Complete Monograph of proposed revisions for the 2021 Uniform Mechanical Code has been released and available for public review.
Comments are due Jauary 3, 2019. We encourage subject matter experts at the workpoint in the education facilities industry — i.e. tradespersons, foremen, supervisors that have a user-interest point of view (the stakeholder who is the final fiduciary)– to participate in the development of the next revision of the Uniform Mechanical Code. As we explain in our ABOUT we find that standards developers routinely attempt to cultivate the user-interest.
More detailed information about how all stakeholders may participate is available this link: Public Comment Page. You may communicate directly with IAPMO’s standards staff here:IAPMO (International Association of Plumbing & Mechanical Officials) 4755 E. Philadelphia Street Ontario, CA 91761 Office: (909) 472-4241 Gabriella Davis gaby.davis@iapmo.org
University of Richmond
Since 2012 we have been tracking several IAPMO documents which govern the safety and sustainability concepts in education facilities; among them:
It is noteworthy that the US education industry is not a participant in this global standard which will likely have implications for standards setting for all aspects of educational organizations including the management of Massive Open Online Courses which we have covered in previous posts.
The ISO/TC 288 has reached a milestone with its May 1st of the First Edition (Click on image):
All ISO consensus documents are on the standing agenda of our weekly Open Door teleconferences every Wednesday, 11 AM Eastern time. Anyone is welcomed to Click Here to login and help prepare user-interest comments on documents open to public review:
The Roy G. Cullen Building at the University of Houston is believed to be the first university facility to install an air-conditioning system. (Click image for more information)
The American Society of Heating and Refrigeration Engineers (ASHRAE International) has released an addendum to its Standard 170 Ventilation of Health Care Facilities. The purpose of this standard is to define ventilation system design requirements that provide environmental control for comfort, asepsis, and odor in health care facilities. Click here for the ASHRAE Standing Standard Project Committee 170 landing page.
The proposed addendum revises requirements for filters in the body of the standard, removes Table 6.4, and adds filter efficiencies on a space-by-space basis. The redline can be found on ASHRAE’s Online Standards Action & Public Review Draft page. (Click here)
Comments are due June 10th.
Standards Michigan limits its interest in environmental air systems in healthcare facilities to university-affiliated medical research and clinical delivery enterprises. We acknowledge the American Society for Healthcare Engineering as an identifiable user-interest in this space.* For the most part environmental air system design, construction, operation and maintenance of the ventilation systems of university affiliated healthcare facilities is identical to healthcare facilities elsewhere; though the risk aggregations may be different for university-affiliated healthcare systems since those enterprises tend to have more research square-footage and receive high-risk patients seeking cutting-edge treatment.
We encourage front-line and middle level subject matter experts in a supervisory role in a university-affiliated healthcare system to participate in ASHRAE’s leading practice discovery processes; possibly at ASHRAE’s Annual Conference in Houston, June 23-27th.
All ASHRAE consensus documents — many of them evolving in 30 to 90 day intervals under ANSI’s continuous maintenance process — are on the standing agenda of our regular Wednesday, 11 AM Eastern Time, Open Door teleconference. We have one today. Anyone is welcomed to join it with the login information below:
You can also dial in using your phone. United States : +1 (408) 650-3123 Access Code: 718-914-669
Issue: [13-56], [15-83] and [16-144]
Category: Healthcare Facilities, Mechanical
Colleagues: Larry Spielvogel, Richard Robben
* By listing its corporate sponsors ASHE acknowledges financial sponsorship of user-interest competitor stakeholders identified in ANSI Essential Requirements: Due process requirements for American National Standards (Section 2.3 Balance). The dominance of stakeholders such as manufacturers, insurers, labor, conformity and trade associations that can build their participation cost into the price of the product or service they sell to the user-interest is condition is seen nearly everywhere in the global standards system As we explain in our ABOUT this condition is a wicked problem — a problem not unlike the problem of participatory democracy generally. While lack of participation may never go away entirely — despite clear, due diligence by accredited standards developers — Standards Michigan seeks to at least manage the weakness of the voice of technical and management experts in the ~$300 billion education facilities industry. To some degree, and in some cases, user-interest price signals are conveyed through trade associations.
It is not too soon to begin preparing public input for the 2021 edition of NFPA 101: Life Safety Code. The Life Safety Code is the most widely used source for strategies to protect people based on building construction, protection, and occupancy features that minimize the effects of fire and related hazards. Unique in the field, it is the only document that covers life safety in both new and existing structures.
We have been advocating in this document since the 2003 edition in which we submitted candidate code changes such as the following:
• Student residence facility life safety crosswalk between NFPA 101 and IBC
• Refinements to Chapters 14 and 15 covering education facilities
• Identification of an ingress path for rescue and recovery personnel toward electric service equipment installations.
• Risk-informed requirement for installation of grab bars in bathing areas
• Modification of the 90 minute emergency lighting requirements rule for small buildings and for fixed interval testing
• Modification of emergency illumination fixed interval testing
• Table 7.3.1 Occupant Load revisions
• Harmonization of egress path width with European building codes
There are others. It is typically difficult to make changes to any consensus standard though some of the concepts were integrated by the committee into other parts of the NFPA 101 in unexpected, though productive, ways.
Public input is due June 27, 2018. We reach out to facility managers, subject matter experts and trade associations — collaborating where possible – but at least reporting on the progress made on behalf of the user/owner/final fiduciary in this industry. This document is a standing item on our weekly (Wednesday 11 AM Eastern) Open Door teleconference to which everyone is welcomed. Click here to log in.
Issue: [18-90]
Category: Fire Safety, Public Safety
Colleagues: Mike Anthony, Josh Elvove, Joe DeRosier
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