Raymond G. Kammer
National Institute of Standards and Technology
Department of Commerce
House Committee on Science
Subcommittee on Technology
September 13, 2000
"The Role of Standards in Today's Society and in the Future"
Madam Chairwoman and members of the Subcommittee, I am pleased to testify before you today on a subject of great importance to the United States. For the first time, government, industry, standards developers, and other interested parties have come together under the banner of the American National Standards Institute (ANSI) to develop a National Standards Strategy. Thank you for focusing national attention on this important advance for the United States.
Although most people do not realize it, standards and the methods used to assess conformity to standards are absolutely critical. They are essential components of our nation's technology infrastructure—vital to industry and commerce, crucial to the health and safety of Americans, and basic to the nation's economic performance.
A few figures illustrate the international significance and relevance of standards:
- About 80 percent of global merchandise trade is affected by standards and by regulations that embody standards.
- In terms of the U.S.-European economic relationship, standards influence an estimated $200 billion in transatlantic trade.
For these and other important economic and social reasons, Commerce Secretary Mineta and I are delighted that the United States now has a new and very constructive National Standards Strategy. The Strategy builds on the strengths of the U.S.-based sectoral approach to standards development. It lays out the principles necessary for the development of national or international standards to meet societal and market needs and outlines a strategic vision for implementing these principles nationally and internationally. It also lays out a set of strategic initiatives with broad applicability, with roles for ANSI, standards developers, industry and government, to be applied according to their relevance and importance to particular sectors. I will touch on some of these initiatives in the context of what government agencies can contribute in more detail later.
The Department of Commerce and, in particular, the National Institute of Standards and Technology (NIST) are eager to assist the private sector in putting the National Standards Strategy into action. Effective implementation of the strategy will help to ensure U.S. industry's success in the international marketplace in the years ahead. Because of the strong partnership that NIST has built with ANSI over the years, we believe we are well positioned to be a strong partner in this effort.
I should also point out, Chairwoman Morella, that you and your subcommittee have made important contributions that are embedded into the new strategy. Legislation that you championed—the National Technology Transfer and Advancement Act—is central to achieving key objectives of the strategy. The act also enabled NIST to help facilitate the strategy's development—a role that I will mention later.
Standards: Details of "Mega" Importance
The topic of standards and the challenge of effective standards development can bewilder, immersing the uninitiated in a blizzard of details. To some degree, this is unavoidable. After all, standards are details. They specify characteristics or performance levels of products, processes, services, or systems. Examples range from specifications for film speed or the arrangement of all the characters of the world's languages for computer processing to process standards for boilers and pressure vessels to the relatively well-known ISO 9000 standards for quality management systems.
Sometimes numbering hundreds or thousands of pages, these specifications can be details of great importance, of market-making significance. On the bright side, consider, for example, the Internet and e-commerce applications, where U.S. technologies are setting the standards for the rest of the world. On the dark side, consider the much more rapid diffusion of digital wireless phone and mobile-commerce—or m-commerce—applications in Europe and Japan. The market for m-commerce technology is in its very early stages. But a recent study estimates that Europe's mobile phone systems are 18 to 22 months ahead of ours. It attributes Europe's fast start, at least in part, to the adoption of common standards.
The process by which thousands upon thousands of standards are produced is invisible to most consumers. In the United States, standards are developed through a complex but effective system administered by the private sector, with participation by industry, academia, consumers, and government. The system has evolved over the last 100 years to meet the needs of U.S. industry and society in general. Rooted in the private sector, it has successfully met domestic marketplace needs on a sector-by-sector basis. The system benefits from strong industry support and participation at all levels in the process. Government, through its technical experts, also participates—as an equal, not as an overseer.
The result is a diverse, flexible, and inclusive system that has successfully met market needs and government regulatory and procurement needs. The global infrastructure needs this type of stakeholder support and involvement.
Over the years, the diverse U.S. standards community has developed rules for consensus, transparency, openness, balance, and due process—important parameters that have been presented to the World Trade Organization as bedrock principles for developing good and fair standards. Yet, this open, competitive system for developing standards creates major issues for us in the global market. Today, there are about 400 formal U.S. standards developers, and some 150 consortia, developing standards. ANSI is responsible for coordinating the formal U.S. system and serves as a point of contact for both the private and public sectors. Developing strategic policy positions and bridging sometimes competing positions can be difficult. Financing adequate U.S. representation in international activities can be another major difficulty and is often a point of contention.
Problems and challenges stemming from this situation can become vulnerabilities in global markets. Standards are becoming increasingly important due to several intensifying trends:
- the pace of technological innovation is quickening;
- trade volumes are growing faster than national economies; and
- business operations are globally distributed.
There is extreme pressure for the standards community to reckon fully with the realities of the brutally competitive, extremely fast-paced global economy. This is because standards are necessary complements of modern products, processes, and services. Standards can:
- promote industrial and market efficiency;
- foster international trade;
- lower barriers to market entry;
- diffuse new technologies; and
- protect human health and the environment.
But these benefits are not always achieved. In fact, the consequences of standards can
be negative. For example, companies—and nations—can use standards to disadvantage competitors. Embodied in national regulations, standards can be crafted to impede export access, sometimes necessitating excessive testing and even redesigns of products. A 1999 survey by the National Association of Manufacturers reported that about half of U.S. small manufacturers find international standards or product certification requirements to be barriers to trade. And according to the Transatlantic Business Dialogue, differing requirements add more than 10% to the cost of car design and development.
With new markets opening up around the world—and with U.S. companies facing stiff competition even in our domestic market—standards that are barriers to trade take on monumental importance. Unfortunately, we hear more and more about instances in which American firms are finding the gates to trade closed as compliance with standards developed elsewhere becomes the price of admission.
Evolution of the Strategy
The United States has long needed a compelling, national standards strategy if we are to realize the intended benefits of standardization and compete effectively in global markets. While there has been much talk by the U.S. standards community about the need for such a strategy, it is only within the last two years that the community has come together to address this challenge. I am pleased to be here with ANSI to unveil the National Standards Strategy.
Over the past two years, NIST and ANSI have undertaken a number of steps to foster development of this new strategy. At a March 1998 ANSI Board of Directors meeting, I challenged the ANSI community to come together to develop a national strategic approach to standards. This suggestion was followed by a series of meetings with industry, with standards developing organizations, and with government agencies – all designed to gather input and elicit ideas for strategic approaches.
NIST and ANSI then co-hosted a Standards Summit in September 1998. More than 300 participants—from all sectors and stakeholder groups—weighed the merits of pursuing a national standards strategy. There was a strong sentiment that overall, users and developers of standards need to advance U.S. interests more consistently and more effectively at both the national and the international levels.
NIST produced several white papers on issues that had arisen at the Summit and shared these widely. Even more importantly, under the ANSI umbrella, NIST and ASTM International co-sponsored two facilitated workshops to define the needs to be addressed by the national standards strategy. Throughout, the process has been inclusive. Government agencies, industry, standards developers, and consumers, have been full participants.
Our trading partners are addressing similar issues. Europe has had a standards strategy in place for some time and it is running at full throttle. It is fair to say that European governments and industries believe that they can meet domestic needs and also create a competitive advantage in world markets by strongly influencing the content of international standards. There is already a direct relationship between the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) and their counterpart European regional standards organizations – CEN and CENELEC – under which European regional standards can be processed in parallel as ISO or IEC standards. Similarly, our neighbors to the North, Canada, unveiled their strategy earlier this year. A major goal of the Canadian strategy is to influence the formation and evolution of global standards that are important to Canada. Interestingly, the Canadian standards strategy recognizes both the major formal international venues for international standards development—ISO and IEC—and also notes the importance of monitoring and influencing international standards development centered here in the United States.
Now the United States has joined our key trading partners in launching a standards strategy to guide collective responses to domestic and international standards issues. The strategy will help the decentralized U.S. standards community to face more squarely the issue of developing and adopting international standards. While many standards developed by U.S. organizations are used internationally, worldwide pressure is increasing to move toward standards developed and promulgated globally. Industries in all countries, including the United States, want standards that enable companies to build products that are accepted worldwide.
Shared goals and principles embodied in the National Standards Strategy provide motivation and direction. They establish a basis for collective action so that members of the U.S. standards community will work cooperatively to develop sound policies in support of global trade. Our mutual goals oblige us to work proactively with our trading partners to further shared technical interests. And they commit us to participating regularly in the critical activities of technical committees.
We anticipate that, through vigilance and sustained commitment, U.S. industry can greatly increase the likelihood that U.S. technical input is reflected in global standards. This will translate into fewer technical barriers to market entry for U.S. exports, which should benefit the entire national economy.
The strategy recognizes that standards needs are diverse and that these needs cannot be addressed by a monolithic, top-down system of standardization. We have agreed to pursue sectoral approaches where one size does not fit all. The strategy fully recognizes the importance of serving industry needs, while ensuring continued strong commitment to health, safety and protection of the environment.
Standards in the IT Sector – Is a National Strategy Relevant?
A sectoral approach recognizes that there is no simple recipe that can be handed down to fit all needs. The National Standards Strategy provides guidance, coherence and inspiration to those inside and outside the system without constraining creativity or effectiveness. Thus it is flexible enough to remain relevant to diverse sectors – from construction equipment to wireless Internet and other e-commerce technologies.
New technologies for wireless Internet will have major economic ramifications, in the United States and globally. Important standards development work is taking place in a variety of venues – both traditional and nontraditional. Consortia, such as the World Wide Web Consortium, and forums (e.g. Wireless Access Protocol Forum and others) are important venues that are outside the formal standards development system. The National Standards Strategy specifically recognizes that successful standards processes are flexible, allowing the use of different methodologies to meet the needs of different technology and product sectors. As consortia and forums develop their specifications, their work becomes the basis for action by the formal process when that adds value.
There is at least one area where the more formal standards development process, with its principles of openness, transparency, balance and consensus, can make a contribution to the spread of e-commerce technologies. The success of these new technologies is closely linked to the development of interoperability standards, which specify how devices communicate with each other. Successful standardization efforts in this area are global and driven by technical superiority.
Standardization of wireless Internet technologies on the cellular telephone model (third generation wireless, for example) has taken place under the auspices of the International Telecommunications Union (ITU), the traditional body for the publication of international telecommunications standards. The ITU is a United Nations agency with national governments as member organizations and strong private sector participation in developing standards. The United States has a significant presence in ITU standards development activities. A great deal of standardization activity related to wireless technologies based on computer network technology has been centered in the Institute of Electrical and Electronics Engineers (IEEE), a nonprofit technical professional society of 350,000 members with close ties to ISO and IEC's Joint Technical Committee 1 on Information Technology.
Standardization of infrastructure is important, even for wireless Internet and e-commerce technologies. NIST is making a major contribution to the successful development and deployment of these technologies by accelerating the process of voluntary industry standardization and keeping it solidly focused on technical issues. The principles embodied in the National Standards Strategy provide important guidance for ensuring that these standardization efforts are recognized globally.
Implementing the National Standards Strategy – Government Role
Crafting a National Standards Strategy acceptable to all stakeholders is a significant achievement. Now we must carry this momentum forward and successfully implement the strategy. Government agencies, including NIST, have key roles to play. Indeed, the strategy underscores the importance of an effective public-private partnership. For government, there is much to be gained.
For the next few moments, I will highlight several critical areas where, I believe, government action can have a significant impact and move the strategy forward.
For many years, government agencies have been directed by Executive Branch policy to participate in the development of voluntary consensus standards and to use these standards in regulatory, procurement and other policy activities. More recently, the National Technology Transfer and Advancement Act of 1995, which originated in this Subcommittee, assigned NIST responsibility to coordinate federal, state, and local standards and conformity-assessment activities with those of the private sector.
At the federal level, the Interagency Committee on Standards Policy (ICSP), chaired by NIST, leads this shift to greater reliance on voluntary standards. As NIST reported earlier this year, federal agencies are already increasing their use of voluntary standards; they are withdrawing competing federal standards; and they are refraining from developing agency-unique standards. The National Standards Strategy provides important guidance for the ICSP. We anticipate that it will shape future agency activities in this area, both domestically and in government-to-government activities at the bilateral, multinational, and global levels.
At the same time, NIST and the rest of the ICSP must act to reverse the decline in federal participation in voluntary standards activities. Agencies that use voluntary standards for regulatory or procurement purposes should contribute expertise and resources to the development and implementation of these standards.
The ICSP, which is charged with implementing both the law and executive branch policy, has welcomed the issuance of the National Standards Strategy. The ICSP recognizes the strategy as a positive step forward, addressing many issues of concern to government and other stakeholders of the standards community. The ICSP has encouraged its members to examine the strategy and to implement it as appropriate for each agency. With this start, appropriate elements of the strategy should filter through individual agencies and help to guide standards-related activities. For example, federal agencies can do a better job of leveraging their relationships with state and local governments to encourage greater use of voluntary consensus standards. This, in turn, would help to reduce regulatory redundancy and duplicative testing requirements.
Some of the tools for this type of streamlining already are in place. For example, NIST recently issued guidance on conformity assessment to federal agencies. This document advocates intergovernmental efforts at all levels to remove unnecessary testing and certification requirements, which would improve the efficiency and transparency of domestic and export markets. Also, in July of this year NIST signed a Memorandum of Understanding (MOU) with the National Cooperation for Laboratory Accreditation (NACLA). The MOU commits NIST to encourage agencies at all levels to accept the use of laboratory accreditation bodies recognized by NACLA, and to encourage U.S. accreditors to seek NACLA recognition. For its part, NACLA commits to follow accepted international guides and standards and to accommodate relevant government requirements in the implementation of its recognition program.
Principles outlined in the National Standards Strategy closely match regulatory and procurement initiatives already under way in many agencies. But the strategy can help agencies identify additional opportunities for improvement. For example, the strategy underscores the importance of consumer participation in standards activities—consistent with the core principles of consensus, openness, balance, and transparency. In response and where appropriate, agencies may wish to initiate standards information and participation programs for consumer-focused activities.
In addition to working with other government agencies to encourage implementation of relevant portions of the National Standards Strategy, there is a great deal that NIST itself can do to support ANSI's efforts to implement the strategy. We have a very good working relationship with ANSI already. This is reflected both in our Memorandum of Understanding (MOU) and in the broad range of joint activities we have already undertaken. The MOU formalized our mutual agreement on the need for a unified national approach to develop the best possible national and international standards. It also affirmed our organizations' shared commitment to enhance and strengthen the U.S. national voluntary consensus standards system. We will revise and extend the MOU to reflect the goals of the National Standards Strategy.
NIST also will incorporate National Standards Strategy principles into our own standards strategy. One of my five major organizational goals is for NIST to provide technical leadership for the nation's measurement and standards infrastructure. This includes fostering and technically assisting the development of high-quality standards needed by government and industry. This goal also includes cooperating with ANSI to improve the effectiveness and responsiveness of the national system for developing voluntary standards. Another element is increasing our work with international bodies to ensure that U.S. standards are understood and accepted by our trading partners.
NIST can make a very significant contribution by endorsing the ANSI process for accrediting standards development organizations, which often are referred to as SDOs. NIST endorsement would establish that American National Standards (ANS) meet federal criteria for voluntary consensus standards. Through its process, ANSI ensures that its guiding principles—consensus, due process and openness—are followed by the more than 266 SDOs it has accredited. ANSI-accredited standards developers are committed to supporting development of national and, in many cases, international standards. And they are responsive to critical technology, market, and regulatory trends, which also concern federal regulators. NIST endorsement of the ANSI accreditation process would go well beyond our current MOU, but we intend to evaluate this option for encouraging greater federal use of voluntary standards.
U.S. Participation in International Standards Activities
A major focus of the National Standards Strategy is on increasing U.S. presence and leverage in international standards activities, and working to improve processes internationally to more closely reflect U.S. principles and vision. ANSI represents the United States in international standards-development activities in ISO and IEC, as well as in private sector regional bodies in the Americas and Asia-Pacific. The Administration supports full industry and government participation ANSI's international activities, to ensure that U.S. interests are fully represented in ISO and IEC.
Without this participation, the U.S. voice will not be heard and U.S. technical positions will not be promoted in ISO, IEC and other international standards development organizations. This can exclude U.S. exports from markets where these standards are adopted as product testing standards, government regulatory or procurement requirements, or as reference methods in testing protocols. Recent communications from the management of ISO, IEC and ITU to the World Trade Organization (WTO) propose that only those international organizations that operate according to certain principles, including limiting membership to appropriate national bodies, should be recognized by the WTO as International Standardizing Bodies. . While the U.S. government strongly opposes such special status, the Europeans would be happy to see this happen and would like to see the links between ISO and IEC and European regional standards organizations (CEN and CENELEC) become even closer so that European standards can move even more easily into ISO and IEC. Certainly, these close links ought to be re-evaluated to the extent that they disadvantage other regions of the world and exclude their technologies and philosophies.
ANSI will be presenting the U.S. National Standards Strategy at the upcoming ISO General Assembly and IEC general meeting in September 2000. As part of this process, I have recommended to ANSI that we seek direct ISO and IEC recognition of the U.S. sector-based approach to standards development. In some sectors, U.S. standards, developed with extensive international participation, represent a body of work that complements existing ISO and IEC work, without overlapping. Over the past year or so, ANSI and U.S. SDOs have been working with ISO on a series of pilot projects, testing various approaches to bridging U.S. standards into the ISO arena. We could build on these pilot projects to move U.S. standards more rapidly into the formal international arena. More generally, we in government also can advance strategic goals and facilitate improvements in how other nations develop and apply voluntary, consensus standards. Federal agencies interact with their foreign counterparts in many venues. Examples are treaty organizations, trade negotiations, joint commercial commissions, training, and business development committees. In these encounters, U.S. representatives can improve our trading partners' understanding of the U.S. approach to standards development and use, and build the strategic alliances desperately needed in the global marketplace of the future.
As the National Standards Strategy indicates, the challenge for the United States in the 21st century is to turn its capabilities and achievements toward greater leadership in developing the standards and operational structures needed by the global market. Meeting this challenge requires coordinated policy development among U.S. industry, U.S. government agencies, and U.S. voluntary standards bodies. It requires developing strategic alliances with our counterparts around the world to develop standards that reflect Asian, European, Latin American, African and North American interests. Thus, an effective global strategy would be one that works to ensure fairness at the international level. The playing field must be level so that one region does not dominate over others; so that developing nations have the opportunity to participate; and so that industry needs are met while protecting health, safety, and the environment.
The formal international process must provide a voice for all interested and affected parties, and allow acceptance of standards based on merit, not simply political decision-making. The standards infrastructure of the 21st century would be greatly strengthened if it contained the flexibility, diversity, and ability to meet user needs contained in the U.S. approach. The United States has an incredible opportunity to work with the international community to incorporate sound U.S. principles into the standards used worldwide. The National Standards Strategy allows us to move easily to these next steps, including working to level the international playing field, as well as secure the high-level industry backing that the standards community needs.
Clearly, if we are to succeed and prosper, U.S. industry, standards developers, and government must continue to cooperate with each other in standards and conformity assessment activities. ANSI, NIST, and the standards community must - and will - continue to work together to develop and implement unified U.S. positions on technical and standards policy issues at the domestic and international levels. If we continue to progress together, as we have over the last several years, the future will be bright. Achieving this bright future, however, means effective implementation of the National Standards Strategy. NIST is committed to continue to work aggressively with ANSI and its members, including other federal agencies, to build on the great beginning we have made in developing a sound and effective National Standards Strategy. A first step is to raise national awareness of the importance of the strategy for our economy. Again, I thank this Subcommittee for spotlighting this achievement.