Since 2013 we have been following developments in an International Organization for Standardization committee: ISO 288 – Educational organizations management systems – Requirements with guidance for use; a committee spun off from the committee that develops the more widely known ISO 9000-family of quality management standards prepared for industries and global regulatory agencies. The global Secretariat is South Korea; with 40 participating member nations and 11 observing nations. The status of this project can be tracked at the link below (You will need login credentials)
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:
Information and communications technology (ICT) is a fast-moving economic space in which a mix of consensus and open-source standards form the broad contours of leading practice. ICT standards tend to follow international developments — more so than, say, fire safety standards which are more familiar to education facility leadership. All school districts, colleges, universities and university-affiliated health care systems have significant product, system, firmware and labor resources allocated toward ICT. Risk management departments are attentive to cybersecurity issues. All school districts, colleges, universities and university-affiliated health care systems have significant product, system, firmware and labor resources allocated toward ICT.
The Building Industry Consulting Service International (BICSI) is a professional association supporting the advancement of the ICT community. This community is roughly divided between experts who deal with “outside-plant” systems and “building premise” systems on either side of the ICT demarcation point. BICSI standards cover the wired and wireless spectrum of voice, data, electronic safety & security, project management and audio & video technologies. Its work is divided among several committees:
BICSI has released for public review a new consensus document that supports education industry ICT enterprises: BICSI N1 – Installation Practices for Telecommunications and ICT Cabling and Related Cabling Infrastructure. You may obtain a free electronic copy from: standards@bicsi.org; Jeff Silveira, (813) 903-4712, jsilveira@bicsi.org.
Comments are due November 19th.
You may send comments directly to Jeff (with copy to psa@ansi.org). This commenting opportunity will be referred to IEEE SCC-18 and the IEEE Education & Healthcare Facilities Committee which meets 4 times monthly in American and European time zones and will meet today. CLICK HERE for login information.
The American Society of Heating and Refrigeration Engineers(ASHRAE) has released another addendum to its Standard 188-2015, Legionellosis: Risk Management for Building Water Systems (click here). Many ASHRAE consensus documents — especially in fast-moving technological spaces that involve public safety — evolve on a continuous basis with public review periods running in 30 to 45 day intervals. The legionella hazard requires speed in leading practice discovery and establishment of a standard of care.
Now comes Addendum a which proposes a revision to the definition of “non-potable” and “potable water system”. The revision defines “non-potable” with the opposite language used to define “potable water system,” and the revisions makes the definition consistent with the same definitions proposed in ASHRAE Guideline 12. The addendum in its entirety is available at the link below:
Comments are due October 21st. You may comment directly on the ASHRAE Online Standards Actions & Public Review Drafts web page with copy to psa@ansi.org. We will coordinate our comments with user interests in the education industry any day at 11 AM EDT. We also host monthly teleconference focused only on mechanical engineering issues. The next online meeting — accessible with the login credentials at the upper right of our homepage — is scheduled for October 15th, 11 AM EDT.
Issue: 12-42
Category: Mechanical Engineering, Occupational Health & Safety, Water
The American Society of Heating and Refrigeration Engineers(ASHRAE) has released another addendum to its Standard 188-2015, Legionellosis: Risk Management for Building Water Systems (click here). Many ASHRAE consensus documents — especially in fast-moving technological spaces that involve public safety — evolve on a continuous basis with public review periods running in 30 to 45 day intervals. The legionella hazard requires speed in leading practice discovery and establishment of a standard of care.
Addendum h is linked can be found at the link below. Note that the changes are scattered throughout latest version of the complete document so it may be wise to purchase the entire document. A single copy may be ordered by emailing standards.section@ashrae.org
Comments are due March 19th. You may comment directly on the ASHRAE Online Standards Actions & Public Review Drafts web page with copy to psa@ansi.org. We will coordinate our comments with user interests in the education industry during our standing Open Door teleconferences every Wednesday, 11 AM Eastern Time. Anyone is welcomed to join these teleconferences with the credential in this link: (Weekly Open Door Teleconference Login)
Issue: 12-42
Category: Mechanical Engineering, Occupational Health & Safety, Water
We are observers in the development of a new ANSI accredited electronic equipment recycling standard jointly developed by NSF International and the Green Electronics Council (GEC). The electronic recycling space is growing quickly — reaching far upstream the value chain into how electronic equipment is designed in the first place. An overview of the project is available in the link below:
This standard has moved swiftly to market under NSF International’s continuous maintenance process. We bring it to the attention of the education facilities industry as a recommendation for lowering #TotalCostofOwnership. Participation as a User interest in American national standards development reduces “wheel reinvention” in which many recycling workgroups unnecessarily start from scratch, eliminates the need to attend costly workshops hosted by trade associations and significantly minimizes destructive competition.
For the past four years we have tracked interest in this standard from subject matter experts directly employed by one of the 5000-odd* colleges and universities in the United States:
Rochester Institute of Technology,
Georgia Institute of Technology
University of Michigan Ann Arbor (up until July 2016)
As one can imagine, manufacturers of electronic products dominate the roster of participants. As we explain in our ABOUT, the dominance of the Producer interest is not the fault of the standards developer, it is the failure of the User interest to participate. We encourage electronic equipment recycling experts in the education facilities industry to participate; ideally contributing operational data which so many technical committees need.
The NSF/GEC 426 committee met on June 19th, July 17th, September 18th and October 16th — i.e. monthly. There are two upcoming meetings scheduled for November 20th. To join the committee please communicate directly with Jessica Slomka at NSF International (jslomka@nsf.org). Of course, we are happy to walk you through other specifics any day at 11 AM. Use the login credentials at the upper right of our home page.
Issue: [14-74], [15-147], [15-148]
Category: Social & Environmental Responsibility, Electrical, Telecommunications, Facility Asset Management
From our archive: NSF International Balloting Process
Posted July 1, 2018
We are observers in the development of a new ANSI accredited electronic equipment recycling standard jointly developed by NSF International and the Green Electronics Council (GEC). An overview of the project is available in the link below:
This standard has moved swiftly to market under NSF International’s continuous maintenance process. We bring it to the attention of the education facilities industry as a recommendation for lowering #TotalCostofOwnership. Participation as a user/final fiduciary in American national standards development reduces “wheel reinvention” in which many recycling workgroups unnecessarily start from scratch, eliminates the need to attend costly workshops hosted by trade associations and significantly minimizes destructive competition. Destructive competition occurs when accrediting agencies drive markets for their services with branding mechanisms.
The electronic recycling space is growing quickly — reaching far upstream the value chain into how electronic equipment is designed in the first place. While some of the committee action material is confidential; enough is available to offer a glimpse into how the subject matter experts are collaborating. It is delicate work — reconciling concepts in two standards suites. A sample of the prevailing issues are as follows:
Qualified Electronics Recycling Standards: The recycling standards that Initial Service Providers must be conformant with in order for a manufacturer to use their services to meet this criterion
How do standards get qualified as meeting criterion?
Approval/qualification process for Initial Service Providers to demonstrate conformance to the qualified electronics recycling standard
Minimum technical requirements that a recycling standard must meet to become a Qualified Electronics Recycling Standard?
Equipment covered under this criterion
When a manufacturer must select an Initial Service Provider that meets a Qualified Electronics Recycling Standard
Definition of Initial Service Provider
Anyone in recycling enterprises in the education industry is encouraged to communicate directly with Jessica Slomka (jslomka@nsf.org) about participating in the development of this standard. This document will also be on the agenda of our standing weekly Open Door teleconferences to which anyone is welcomed. Login information is available in the link below:
ASCE/EWRI 56: Guidelines for the Physical Security of Water Utilities. These water utility guidelines recommend physical and electronic security measures for physical protection systems to protect against identified adversaries, referred to as the design basis threats (DBTs), with specified motivation, tools, equipment, and weapons.
ASCE/EWRI 57: Guidelines for the Physical Security of Wastewater/Stormwater Utilities. These wastewater/stormwater utilities guidelines recommend physical and electronic security measures for physical protection systems to protect against identified adversaries, referred to as the design basis threats (DBTs), with specified motivation, tools, equipment, and weapons. Additional requirements and security equipment may be necessary to defend against threats with greater capabilities.
Comment Deadline: October 29, 2018
We encourage direct engagement by education industry leaders, their engineering consultants, or municipal water management experts to participate in the development of these standards through the ASCE standards portal:
You will need to set up an access account. You may also communicate directly with the American Society of Civil Engineers, 1801 Alexander Bell Dr., Reston, VA 20191. Contact: James Neckel (jneckel@asce.org)
Our monthly breakout teleconference for campus water management standards is scheduled for October 19th, 11 AM Eastern time. Use the login credentials at the upper right of our home page.
Scope: These water utility guidelines recommend physical and electronic security measures for physical protection systems to protect against identified adversaries, referred to as the design basis threats (DBTs), with specified motivation, tools, equipment, and weapons.
Project Need: Guidelines for physical security for facilities used in potable water source, treatment, and distribution systems.
Stakeholders: Utility staff.
This document (and supplement) is 134 pages long. Access to draft changes are restricted to stakeholders with approved login credentials.
Comments are due July 2, 2018. Because many research universities have healthcare delivery campuses, district energy and fire protection systems that are dependent upon water supply and wastewater security — with complex interdependencies upon the municipal and/or utility systems — we regard this guideline as a priority and an opportunity to contribute to setting the standard of care for the safety and sustainability of those systems owned and operated by education facility industry operations and maintenance units.
You are encouraged to visit the ASCE Standards Public Comment Page and/or communicate directly with the American Society of Civil Engineers, 1801 Alexander Bell Dr., Reston, VA 20191. Contact: James Neckel (jneckel@asce.org)
Click on image
All ASCE consensus documents are on the standing agenda of our weekly Open Door teleconferences — every Wednesday, 11:00 AM Eastern time — to which everyone is welcomed. CLICK HERE to log in. We hope to collaborate with workpoint experts such as tradespersons, shop foremen, design engineers and front-line campus security experts in district energy and healthcare delivery systems for specific technical recommendations.
Issue: [18-52]
Category: Civil Engineering, Water, #SmartCampus
Colleagues: Jack Janveja, Richard Robben, James R. Harvey
The University of Texas Medical Branch (UTMB) is the United States Technical Advisory Group Administratorfor thefirst global standard for health care administration; developed by International Organization for Standardization Technical Committee 304 (Click here: ISO/TC 304). The creation of this standard was initiated by UTMB and, if this document is incorporated by reference into public law, or adopted by the private sector as a performance benchmark, it will have significant effect upon health care enterprises in every industry in the US — not the least among them the healthcare delivery enterprises in the US education industry.
The core committee met July 13th at NSF International Headquarters in Ann Arbor, Michigan. A summary of the activity at that meeting will be posted here soon. This standard will be on the agenda or our monthly international standards teleconference, October 18th, 11 AM. See Live Link information at the top of our homepage.
For information about participating contact Lee Webster (lswebste@utmb.edu).
ISO TC 304 Participation Map | Click on image for more details
March 28, 2018
We have received an update from S. Lee Webster, the global Secretariat for this emergent document:
The next meeting of the various working groups will be held in Vilnius, Lithuania, May 21-25, 2018. Contact Lee Webster for information about how to attend (lswebste@utmb.edu). Ahead of the May meetings, we will be scheduling a live Q&A with Lee during one of our weekly Open Door teleconferences.
Vilnius University Hospital Santaros Klinikos (Click on image)
“With more than $360 billion spent annually on health care administration in the U.S., reducing costs and streamlining administrative processes in health care is a critical national priority,” said S. Joe Bhatia, president and chief executive officer of ANSI, the U.S. member body to ISO. “The newly formed ISO TC 304 shows great promise in tackling inefficiencies in health care administration worldwide, and ANSI proudly supports UTMB’s leadership role as acting secretariat on behalf of the United States.”
It is rare for a US educational institution to assume leadership at this scale. As an Accredited Standards Developer the UTMB will oversee the creation of standards and technical reports that define effective, interoperable, and comparable healthcare administration practices and metrics among healthcare entities. These practices and metrics will be limited to staff and operational management of healthcare facilities. Excerpts from the standardization project identify the rationale:
Rationale 1: Establishing healthcare administrative standards will reduce the cost of providing healthcare through the widespread adoption of interoperable metrics and practices.
Rationale 2: Reducing the cost of healthcare will make these services more affordable and thereby provide an opportunity for greater access to society.
Rationale 3: Improving the administrative and managerial performance of healthcare entities results in better healthcare outcomes for patients.
Rationale 4: Although numerous standards exist for the laboratory protocols, clinical services and patient care functions of healthcare organizations, there are scant standards that address administrative functions or these standards are specific to a particular healthcare entity.
Rationale 5: Standardizing Healthcare administrative metrics will create apple-to-apple comparisons of organizations performance that will better educate consumers and drive process improvement activities
Rationale 6: Rural and underserved communities will have access to effective practices that offer a roadmap to improve their own quality of healthcare services they receive.
Rationale 7: Positive support have been received from other ASD and members of the healthcare technical community
Rationale 8: Standards will complement standards developing efforts of existing ANSI and ISO standards developing committees.
Rationale 9: The healthcare community and its stakeholders are highly receptive to standardization and certification and will adopt approaches from these sources readily.
Those practices and metrics that directly affect patient care and medical research are outside the scope of this standards effort. Clinical performance and patient safety and satisfaction standards will not be pursued by this ASD body. ISO 304 will also not address 1) the management or administration of organizations that practice dentistry, 2) the production and use of medical devices or instruments, and 3) the capture and analysis of clinical medical information or procedures. More detailed information is available in the documents linked below:
Facility managers in university-affiliated medical research and healthcare delivery enterprises who would like to participate in developing the US position are encouraged to contact Lee Webster Lee Webster (lswebste@utmb.edu).
[Issue 14-99]
Contact: Lee Webster (lswebste@utmb.edu), Mike Anthony (mike@standardsmichigan.com), Richard Robben (rrobben1952@gmail.com), James Harvey (jharvey@umich.edu), Christine Fischer (chrisfis@umich.edu)
Category: Medical Research & Health Care, Management, Finance & Administration, International
The IAPMO Group has launched the 2021 revision cycle for the Uniform Mechanical Code; widely incorporated by reference 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 January 3, 2019. We encourage subject matter experts at the workpoint in the education facilities industry — i.e. tradespersons, foremen, supervisors with a user-interest in lowering #TotalCostofOwnership — 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 but workpoint subject matter experts do not receive the sustained financial support from their management and leadership anywhere close to the way incumbent interests — conformity, compliance, enforcement, insurance, labor, manufacturers — receive support.
We will walk through the IAPMO suites, and other mechanical engineering standards, today — October 15th at 11 AM Eastern time. Use the login credentials at the top right of our home page.
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:
The National Fire Protection Association is developing a new public safety standard: NFPA 2400 Standard for Small Unmanned Aircraft Systems (sUAS) used for Public Safety Operations. This standard covers the minimum requirements relating to the operation, deployment, and implementation of small unmanned aircraft systems for public safety operations. The standard is developed by two main committees — one committee for drone systems (UAS-AAA) and another committee for the professional qualifications to operate and maintain drone systems (PQU-AAC)
From the project prospectus:
This standard shall cover the minimum requirements relating to the operation, deployment, and implementation of small unmanned aircraft systems (sUAS) for public safety operations. This standard shall establish operational protocols for public safety entities who use and support sUAS. This standard shall include minimum job performance requirements (JPRs) for public safety personnel who operate and support sUAS. This standard shall include minimum requirements for the maintenance of sUAS when used by public safety entities. This standard shall provide additional minimum requirements specific to public safety entities.
This standard is deep into the its development cycle. The First Draft Report for the AAA committee is linked below:
We choose these reports to provide an overview of the technical and management concepts in play in the first draft. Second draft action appears to be largely administrative and is available for public viewing with a (free) NFPA public review account.
Application of this technology for public safety on college and university campuses is growing. We find that several educational organizations are supporting faculty and staff involvement: University of Illinois Fire Service Institute, Piedmont Virginia Community College, Embry-Riddle Aeronautical University, Oklahoma State University and the University Of Cincinnati are supporting the participation of Special Experts. The Los Angeles Unified School District is supporting a User Interest.
With the Second Draft Report posted, the NFPA permits additional public comment at its 2019 Annual Conference through its NITMAM process; simply an application to reserve a spot on the NFPA Standards Council agenda,
NITMAMs are due October 8th.
Anyone may obtain an electronic copy from: www.nfpa.org/2400next Send your comments to NFPA with your free NFPA account (with copy to psa@ansi.org). We are happy to walk through the specifics with anyone, any day at 11 AM. Use the login credentials at the upper right of our home page
We also host a monthly[ teleconference that covers the status of the expanding constellation of school security standards. The next online meeting is scheduled for today — October 16th, 11 AM. Feel free to join us.
Issue: [18-269], [16-199]
Category: Public Safety, Risk Management, #SmartCampus
The power restoration activity now underway in the areas of the US affected by Hurricanes Michael and Florence inspires a revisit of the standard to which public utilities build the overhead and underground power and telecommunication wiring for the communities they serve. We collaborate closely with the IEEE Education & Healthcare Facilities Committee (IEEE E&H) to raise the standard of care for power security on the emergent #SmartCampus. Another IEEE consensus document — IEEE 1366 Guide for Electrical Power Distribution Reliability Indices — is also used by state utility commissions for setting reliability benchmarks. The IEEE E&H Committee tracks campus power outages as a research project.
Several proposals recommending improvements to the 2017 National Electrical Safety Code (NESC) were submitted to the IEEE subcommittees drafting the 2022 revision of the NESC. They are fairly technical and subtle in their implications for the advancement of safety and sustainability in campus power distribution systems. Some of the proposals deal with coordination with the National Electrical Code — which is now deep in 2020 revision cycle
Keep in mind that that NESC is revised every 5 years at the moment. The next steps in the 2022 NESC development will span across most of the next 12 months as the various subcommittees meet a prepare written response to public input and release those responses no later than July 1, 2019. The complete schedule is linked below:
The subcommittee that coordinates standards action between the IEEE and NFPA suite of technical standards — IEEE Standards Coordinating Committee 18 — will also be hosting worksessions in the coming months. While those work sessions are generally closed to the public, some of the concepts will be open for discussion during any of the IEEE Education & Healthcare Facilities online committee meetings which meets 4 times monthly in Europe and the Americas.
Business unit leaders, facility managers and electrical engineers working in the education facilities industry may be interested in the campus power system reliability database. Forced outages in on large research campuses, for example, can have enterprise interruption cost of $100,000 to $1,000,000 per minute. The database discriminates between forced outages attributed to public utility interruptions and forced outages attributed to the university-owned power system. The E&H committee will convey some of the discipline applied by the IEEE 1366 technical committee into its study of campus power systems; many of which are larger than publicly owned or cooperative utilities.
Issue: [16-67]
Contact: Mike Anthony, Robert G. Arno, Lorne Clark, Nehad El-Sharif, Jim Harvey, Kane Howard, Joe Weber, Guiseppe Parise, Jim Murphy
Category: Electrical, Energy Conservation & Management, Occupational Safety
We collaborate with the IEEE SCC-18 and the IEEE Education & Healthcare Facilities Committee in developing safety and sustainability concepts unique to educational facilities — particularly the campuses of large research universities where the power systems are on the order of 25 to 250 connected MVA. Power systems this large are unregulated by public service commissions because they are considered premises wiring by the NEC and considered to be on the customer side of the point of common coupling by investor-owned utilities who are. Coupled with the NEC, the NESC sets the standard of care for all exterior campus power system design, construction and maintenance.
Public input is due July 16, 2018. All IEEE consensus documents are on the standing agenda of our weekly Open Door teleconference — every Wednesday, 11:00 AM Eastern time. Click here to log in. The next teleconference of the E&H committee is scheduled for June 9th. Anyone is welcomed to join either of the two teleconferences hosted bi-weekly during the business day of Europe (15:00 – 15:30) and the Americas (3:00 – 3:30 PM EDT) with the login information on the IEEE E&H website: http://sites.ieee.org/icps-ehe/
Issue: [16-67]
Contact: Mike Anthony, Robert G. Arno, Lorne Clark, Nehad El-Sharif, Jim Harvey, Kane Howard, Joe Weber, Guiseppe Parise, Jim Murphy
Category: Electrical, Energy Conservation & Management, Occupational Safety
Walla Walla University
*The NFPA is an organization with fire safety as a primary consideration. The IEEE is an organization with the safety and sustainability of electrotechnology as a primary consideration. These are two different complementary but oftentimes competing cultures with respect to sustaining the business model of an accredited consensus standards developer.
The National Electrical Contractors Association develops a suite of consensus standards titled National Electrical Installation Standards that define the actions needed to meet standard of care criteria in the National Electrical Code (NEC); particularly where the NEC asserts that an installation be constructed in a “neat and workmanlike manner”. The scope of the original undertaking, begun in the early 1990’s with University of Michigan as an early adopter, has since expanded into operation and maintenance standards; and more recently into design, installation, operating and maintaining integrated systems such as microgrids*.
Public notification of this commenting opportunity filed with ANSI is available at the link below:
You may obtain an electronic copy from neis@necanet.org. Send comments to Aga Golriz, (301) 215-4549, Aga.golriz@necanet.org with a copy of your comments psa@ansi.org. Because the proposed change is relatively minor editorial/grammatical change, we will not comment on it but encourage other user-interests in the education facilities industry (electric shops, engineering managers, etc.) to at least become familiar with the NECA suite of standards and to incorporate them by reference into their standard practice guides for electrical trades.
Our door is open every day at 11 AM for consultation on this and other standards. Use the login credentials at the upper right of our home page. Additionally, we will refer this to the IEEE Education & Healthcare Committee, which is a subcommittee in the IEEE Industrial Applications Society which follows — and leads — the development of the emergent #SmartCampus
*Most seasoned electrical power professionals recognize that many large research universities with district energy systems that generate in parallel with a public utility have, for decades, operated with all the essential characteristics of a microgrid except the political “buzz”.
Posted June 15, 2018
The National Electrical Contractors Association (NECA) is proposing a new standard — NECA 417 Recommended Practice for Designing, Installing, Operating, and Maintaining Microgrids. The proposed standard applies to microgrids and provides recommended practices for their design, installation, commissioning, operation, and maintenance. Public notification of this commenting opportunity filed with ANSI is available at the link below:
Comments are due July 30th. You may obtain an electronic copy from neis@necanet.org. Send comments to Aga Golriz, (301) 215-4549, Aga.golriz@necanet.org. Send a copy of your comments psa@ansi.org.
