EAC Decision on Request for Interpretation 2016-02

(Environmental Control Testing: Operating)

VVSG 1.1 Volume I, Section 4.1.2.13

VVSG 1.1 Volume II, Sections 5.7.1.1 and 5.7.1.2 

Date:

October 18, 2016 

Questions:

1. Does the temperature ranges outlined in 4.1.2.13 a. unreasonably eliminate COTS products (such as 

tablets and laptops) from being more widely incorporated into voting systems? 

2. Is it required that the relative humidity range of 5% - 85% described in VVSG Volume I Section 

4.1.2.13 be completed entirely in the Operating Humidity test described in VVSG Volume II Section 

5.7.1.2 or can the requirement be fulfilled by testing the range through the combination of tests 

described in VVSG Volume II Section 5.7.1 – Operating Temperature and Humidity Tests? 

3. How many cycles are required for the Operating Humidity? 

Section(s) of Guidelines:

4.1.2.13 Environmental Control - Operating Environment

a. Voting systems shall be capable of operation in temperatures ranging from 41 °F to 104 °F (5

°C to 40 °C) and relative humidity from 5% to 85%, non-condensing. 

b. If the system documentation states that the system can operate in humidity higher or lower than 

the required range, the system shall be tested to the level of humidity asserted in the

documentation. 

For testing information, see Volume II, section 5.7.1. 

5.7.1.1 Operating Temperature

All voting systems shall be tested according to the low temperature and high temperature testing 

specified by MIL-STD-810-D: Method 502.2, Procedure II – Operation and Method 501.2, Procedure II –

Operation, with test conditions that simulate system operation. 

5.7.1.2 Operating Humidity

All voting systems shall be tested according to the humidity testing specified by MIL-STD-810-D:

Method 507.2, Procedure I – Natural (Hot–Humid), with test conditions that simulate system

operation. 
Discussion:

For the past several years, EAC has received input from entities and individuals suggesting that the 

operational environment temperatures required by VVSG Section 4.1.2.13 are unreasonable for COTS 

devices. Since more and more COTS devices are being incorporated into voting systems, the EAC felt 

the need to further review this section to see if, in fact, the requirements are unreasonably limiting 

COTS products from inclusion into systems seeking EAC certification. 

After significant research into this matter, the EAC concludes that while some COTS tablets, laptops 

and printers are not designed to meet the requirements of Section 4.1.2.13, a large variety of 

products in the COTS market place are available and have operating environment specifications equal 

to or exceeding those required by the VVSG. Because there are products readily available that meet 

these requirements, the EAC finds little merit to the argument that the operating environment 

requirements are either excessive or limiting to voting system manufacturers. 

The EAC has also conducted extensive research into the MIL-STD-810 and determined that there is a 

disparity between the temperature and humidity ranges in VVSG 1.1 Volume I Section 4.1.2.13 and 

MIL-STD-810D, against which the standards shall be tested, pursuant to VVSG 1.1 Volume II Section 

5.7.1. For the Operating Temperature (high) and the Operating Humidity test, the variation is very 

minimal, whereas in the Operating Temperature (low) test the variation in temperature is fairly 

significant. 

The temperature range described in MIL-STD-810D Table 501.2-II, set forth in VVSG 1.1 Volume II 

Section 5.7.1.1, for the high-temperature test under basic hot conditions fulfills the high-temperature 

(104 °F) and low-humidity (RH 5%) levels described in the VVSG 1.1 Volume I Section 4.1.2.13. 

Further, the humidity range in MIL-STD-810D Table 507.2-I for Natural, Hot-Humid Conditions (Cycle 

1), set forth in VVSG 1.1 Volume II Section 5.7.1.2 fulfills the high- humidity levels (85%) described in 

the VVSG 1.1 Volume I Section 4.1.2.13. However, as previously stated, the ranges vary slightly 

between the VVSG 1.1 Volume I Section 4.1.2.13 a. and its respective MIL-STD-810D test procedure. 

Therefore, the EAC finds that the test labs should adjust the ranges listed in MIL-STD-810D for the 

Operating Temperature (high) and the Operating Humidity tests proportionately to fulfill the 

requirements prescribed by VVSG 1.1 Volume I Section 4.1.2.13. 

Although the range for Operating Temperature (low) varies significantly from the suggested ranges 

provided for in MIL-STD-810D Method 502.2, the procedures described in MIL-STD-810-D: Method 

502.2, Procedure II – Operation, as required by VVSG 1.1 Volume II Section 5.7.1.1, do not prescribe 

a specific range; rather the procedures states “With the test item in the test chamber, adjust the 

chamber air temperature to the low operating temperature of the test item as specified in the test 

plan.” Since the chamber is to be set to the low operating temperature as specified in the test plan, 

the test plan shall be 41 °F, pursuant to VVSG 1.1 Volume I Section 4.1.2.13 a. 

The MIL-STD-810-D: Method 507.2, Procedure I – Natural (Hot–Humid), Step 4 states “Repeat steps 2 

and 3 for the number of cycles indicated in table 507.2-II...” Table 507.2-II states that duration for 

non-hazardous items under natural conditions (Cycle 1) is 10 cycles. 

Conclusion:

The EAC does not believe that an interpretation or adaptation appears necessary to allow the 

industry to reasonably meet the temperature requirements of VVSG 1.1 Volume I Section 4.1.2.13. 
The EAC concludes that the range of relative humidity does not need to be fulfilled in the single 

Operating Humidity test as prescribed by VVSG 1.1 Volume II Section 5.7.1.2; rather the range will be 

met when conducting the three tests defined within the MIL-STD-810D – Operating Temperature 

(high), Operating Temperature (low), and Operating Humidity. However, in order to align the test 

procedures for those tests, the EAC has interpreted VVSG Volume II Section 5.7.1 to read as “All 

voting systems shall be tested similar to...” the respective tests specified in MIL-STD-810D. To further 

clarify the term “similar to”, it is the EAC’s intent that the test labs will proportionately adjust the 

tables contained within the MIL-STD-810D for the Operating Temperature (high) and the Operating 

Humidity tests, MIL-STD-810D Table 501.2-II and MIL-STD-810D Table 507.2-I for Natural, Hot-Humid 

Conditions (Cycle 1), respectively, so that they align with the requirements of VVSG 1.1 Volume I 

Section 4.1.2.13. The proportional methodology is not applicable to the Operating Temperature 

(low) test in that the procedure for it does not provide a range, yet states “...adjust the chamber air 

temperature to the low operating temperature of the test item as specified in the test plan.” The test 

plan shall specify the low operating temperature of 41 °F, pursuant to VVSG 1.1 Volume I Section 

4.1.2.13. 

The EAC does not believe that an interpretation appears necessary for the number of cycles 

necessary for the Operating Humidity test. However, Step 3 states that an operational checkout 

should be performed at any convenient time which test conditions are constant and at a maximum 

temperature and RH levels. As to not have ambiguity in testing the EAC has interpreted that as 

during the interval between time = 71 hours and time = 77 hours (maximum RH) and between time = 

181 hours and time = 185 hours (maximum temperature). 

Effective Date:

Effective immediately for all new test campaigns.