Overcoming Implementation Misconceptions

By Mark Stolorow, OSAC Registry Implementation Ambassador

The Organization of Scientific Area Committees for Forensic Science (OSAC) has posted over 150 standards in 22 disciplines on the Registry. More than 130 national and international government, private, and university forensic science service providers (FSSPs) have submitted declaration forms identifying which standards they have either partially or fully implemented. Those FSSPs have each been awarded an OSAC Registry Standards Implementer Certificate in recognition of embracing standards implementation. Of the OSAC Registry Implementers who have received recognition certificates, 64 have published news releases announcing their achievement. 

Despite the accelerating rate of certificates being awarded, there still exists a surprising level of hesitation on the part of some FSSPs to initiate standards implementation or to share communication with OSAC about their progress. 

In response to the OSAC 2021 and 2022 standards implementation surveys, we have received many comments related to the challenges FSSPs are facing in deciding whether to complete and submit an OSAC Registry - Standards Implementation Declaration Form. We have learned from the surveys and from numerous members of OSAC who help write and evaluate standards that some of their colleagues back home share some common misconceptions about standards implementation.

To help the FSSPs better understand and feel comfortable with the implementation process, we would like to address these common misconceptions.

Below are some of the more commonly heard misconceptions followed by actual experiences of OSAC Registry Implementers:

MISCONCEPTION #1: Some FSSPs fear that if they declare that they have any standards only partially implemented that their forensic science experts will be harshly cross-examined if that is revealed in discovery.

• Actual Experience: 70 of the 130 current OSAC Registry Standards implementers met virtually in an OSAC outreach meeting in June 2023. We learned that none of their forensic experts has experienced cross-examination about these issues in court. It was suggested that it would be valuable for FSSPs to provide training to their scientists about their overall quality system and how to present it effectively in court.

MISCONCEPTION #2: Some FSSPs fear that as soon as they submit a declaration form, it will be out of date. If they are asked to provide a copy in response to a discovery request or FOIA, they may be criticized for standards not yet or only partially implemented on an outdated document.

• Actual Experience:
  • The current OSAC Registry Standards implementers also concurred during the June 2023 meeting that none of them has received criticism for implementing standards (fully or partially). Quite to the contrary, they reported that the reactions internally from their staff members and externally from prosecutors and the media, has been highly complementary and supportive.
  • FSSPs quality systems are dynamic and undergo continuous improvement throughout the year. Most FSSPs have annual quality audits and find that updating their tracking records of standards implementation and their declaration forms coincides nicely with the annual audits. In similar form, as additional standards are constantly being added to the Registry, there is an expectation that declarations will not be fully synchronized with implementation efforts. This is to be expected and should not be an issue for any FSSP. The new Open Enrollment process sets a target date that should be useful in the respect that declarations can be updated and submitted at that time.

MISCONCEPTION #3: Some FSSPs feel that they have implemented plenty of standards on the OSAC Registry but they don’t want to submit a declaration form because it will become public information. If submitting a declaration cannot be maintained without disclosure by OSAC, they don’t want to participate.

• Actual Experience:
  • Being respectful of the preferences of our OSAC collaborators is critically important to maintain relationships. OSAC has only publicly posted online on the OSAC Implementer webpage the names of the FSSPs that have submitted declaration forms and issued public news releases or officially authorized OSAC to publicize their names. Some of the forensic science service providers (FSSPs) do not want their identities revealed because they have good relationships with other forensic science laboratories in their jurisdictions and don't want to appear to be upstaging other FSSPs in their jurisdictions who have not yet submitted declaration forms. 
  • One of the recommendations from the 70 participants in the June 2023 outreach meeting was to spread the word about how large the number of implementers has grown and their willingness to help other agencies. They recommended providing contact information to other non-implementer FSSPs for them to find mentors among the implementers willing to help their colleagues initiate the process of standards implementation. They also suggested listing on the OSAC website not only the FSSPs which have issued press releases but also the other FSSPs willing to authorize OSAC to add their names to the list of OSAC Implementers online so other agencies can reach out to them for help. 
  • In response to that suggestion, we asked the other FSSPs who have not already done so to authorize OSAC to add their agency names to the OSAC Registry Implementers webpage. To date, many of the remaining FSSPs have already sent us authorization to list them on the OSAC implementer web page. We hope that this campaign will serve to inform and encourage more standards implementation. Please check to find an FSSP mentor on the OSAC implementer web page and begin the process of standards implementation.

MISCONCEPTION #4: Some FSSPs have no objection to implementing standards but feel that they just don’t have sufficient funds or resources to even begin the process of tracking those standards.

• Actual Experience: 
  • FSSPs are constantly fighting the battle of competing needs for limited resources. But in many ways, the objection to implementing standards because of the lack of resources is historically reminiscent of the objection of some FSSPs to seeking accreditation. Eventually, over 88 percent of the more than 400 governmental forensic science laboratories in the US have become accredited – the overwhelming majority of those voluntarily. We have learned that the benefits of accreditation far outweigh the effort and the resources required.
  • Accredited FSSPs have already demonstrated implementation of at least one standard – ISO/IEC 17025. They are eligible to begin the process of tracking standards implementation and informing OSAC of their status. The first step is recognizing that standards implementation is a value proposition with benefits that outweigh the required effort and resources. Once the decision is made to prioritize the quality system and the FSSP is ready to begin the process of standards implementation, the organization can proceed at a pace it can most appropriately manage. 

The OSAC Program Office is working in collaboration with many professional forensic science organizations to help reduce anxiety about the implementation process by creating and providing resources to help educate and facilitate implementation for FSSPs.

There is help available to members from other FSSPs who have already been through the process and from a wide array of tools, mentors, and training available on the OSAC Registry Implementation webpage.

If you have any questions or comments or need help facilitating the implementation of standards on the OSAC Registry in your organization, please contact Mark Stolorow in the OSAC Program Office at mark.stolorow [at] nist.gov (mark[dot]stolorow[at]nist[dot]gov).