NIST Standards 

Coordination Office

NIST Summary of the Responses to the 

National Science and Technology 

Council’s Sub-Committee on Standards

Request-for-Information, issued 

December 8, 2010: 

Effectiveness of Federal Agency Participation in 

Standardization in Select Technology Sectors 
2

This document was compiled at NIST and is intended for informational purposes only. It does not 

represent official government policy and does not convey endorsement of any specific 

recommendations listed.
3

Contents

Introduction ......................................................................................................................................5

About the Request-for-Information (RFI) .................................................................................................5

Broad Themes...........................................................................................................................................5

Profile of the RFI Respondents .................................................................................................................6

Commenters Viewed by Technology Sector and Other Areas of Expertise..........................................7

Section 1: Standards-Setting Processes, Reasons for Participation and the Benefits of Standardization .8

Who participates in standards setting activities?.....................................................................................8

A broad array of stakeholders from the private and public sectors participate in standards setting 

activities. ...............................................................................................................................................8

Reasons for Participation..........................................................................................................................9

Benefits of developing standards ...........................................................................................................10

How do standards impact organizations and their competitiveness? ...................................................10

How has standardization spurred innovation in the technology sector(s)?...........................................10

What is the current phase of the standards development process for this technology? ......................11

How has the process worked so far? ......................................................................................................11

How are standards setting processes managed and coordinated?........................................................11

Is there a strategic plan that identifies standards needs and defines the standards development life 

cycle?.......................................................................................................................................................12

Are there barriers to the development of high level strategies for standards setting?.........................12

Section 2: Perspectives on Government’s Approach to Standards Activities......................................13

What methods of engagement are used by Federal agencies to participate in private-sector led 

standards development? ........................................................................................................................13

How transparent is each method?..........................................................................................................14

How effective is each method of engagement? .....................................................................................15

How could the methods be improved? ..................................................................................................15

What other methods should the Federal agencies explore?..................................................................16

What impact have Federal agencies had on standards activities?.........................................................17

How well do Federal agencies coordinate their roles in standards activities in the sector of interest? 19
4

When Federal agencies have been involved in standards setting efforts in a technology sector, how 

has the progress of standards setting efforts in this technology sector changed after Federal agencies 

became involved? ...................................................................................................................................19

Are Federal agencies generally receptive to input from other participants in standards-setting 

activities? Does receptiveness tend to depend on whether the Federal agency is a regulator or a 

customer? ...............................................................................................................................................20

In those sectors where Federal agencies play a significant role in standards activities, how valuable 

and timely is the work product associated with this effort? ..................................................................21

Section 3: Issues Considered During the Standards Setting Process....................................................22

Part 1: Technology, competition, the impact of innovation, etc............................................................22

Part 2: Copyright and intellectual property rights..................................................................................24

Patents in standards ...........................................................................................................................24

Some major themes............................................................................................................................25

Suggestions from respondents relating to IPR in standards...................................................................26

Copyright and sale of standards .........................................................................................................27

Ownership of copyright ......................................................................................................................28

Section 4: Adequacy of Resources....................................................................................................30

Participation in standards setting ...........................................................................................................30

Federal funding support for standards development.............................................................................30

Management of standards development...............................................................................................31

Section 5: Process Review and Improvement Metrics........................................................................32

Lessons learned.......................................................................................................................................32

Performance metrics ..............................................................................................................................32

Appendix 1: Commenters to the NIST Request-for-Information released December 8, 2010..............34
5

Introduction

About the Request-for-Information (RFI)

NIST issued a Request for Information on December 8, 2010 requesting information from interested 

stakeholders on how the federal government can more effectively engage in the private sector led 

standards system. 

The RFI requested feedback on a set of core questions, with a particular focus on experiences with 

standards development for multi-disciplinary emerging technologies that address identified national 

priorities: Cyber Security, Smart Grid technologies, Health Information Technology, Nuclear/Radiation 

Detectors, and Emergency Communication Interoperability.

Respondents were given very broad guidance. Based on their experience and knowledge commenters 

were invited to describe: 

○ The mechanisms and models by which federal agencies engage in standards-setting within their 

community

○ The issues that are considered during standards setting that could impact U.S. innovation and 

the ability of U.S. companies to compete, such as intellectual property issues, the impact of 

government regulation, etc.

○ Adequacy of resources to support successful standards development activities

○ Process review and improvement metrics that are incorporated into the current standards 

development system

The RFI is part of a larger process aimed at improving the effectiveness of U.S. federal government

participation in standardization activities directed by the NSTC’s Subcommittee on Standards chaired by 

Dr. Patrick Gallagher, Under Secretary for Standards and Technology and Director of NIST. 

Broad Themes

The initial review identifies the following general themes related to government participation in 

standards setting:

Guidance on government participation needs to be clarified as it is inconsistent across 

government agencies

More resources need to be applied to increase participation in standards setting activities –

funding of travel, membership dues.

Federal agency positions must be coordinated during standards development 

NIST’s convener role is appreciated and valued; many respondents expressed the view that the 

convener-role is government’s most appropriate role in standards setting.
6

Profile of the RFI Respondents

A total of 92 responses were received to the NIST Request for Information issued December 8, 2010. 

Overall, this pool of commenters represents a wide spectrum of the standards stakeholders in the 

United States. Respondents were well-informed on the processes, political climate and complexities of 

standards development, nationally and internationally. Appendix 1 lists the commenters to the RFI.

The largest group of commenters – 34 in all – was Standards Setting Organizations (SSO), 

including ANSI-accredited standards developers and consortia developing standards and 

specifications for particular topical sectors.

Twenty one respondents represented industry with global business interests; within that group, 

almost all of these respondents represented companies from the information technology sector 

– software developers, hardware providers – engaged in standards development in one or more 

of the sectors called out in the RFI;

Sixteen individual experts with expertise and experience in standards development responded;

Fifteen nonprofit-type organizations (trade associations, professional societies and educational 

institutions) responded to the RFI; nonprofits that were standards developers were classed as a 

Standards Setting Organization;

Six commenters represented the government sector, 4 from within the U.S. (national and statelevel) and 2 respondents tied to governments outside of the U.S. 

34

21

16

15

6

92 Responses to the RFI

SDO/SSO -34

Industry -21

Individual experts - 16

Nonprofit organizations - 15

Government - 6
7

Commenters Viewed by Technology Sector and Other Areas of Expertise

The respondents had varying degrees of expertise and experience in the technology sectors called out in 

the RFI:

Twenty respondents had some knowledge of the Smart Grid (SSOs, industry, and government);

Sixteen commenters had direct experience as developers or users of Health IT systems and 

standards (SSOs, industry, government, and nonprofit organizations);

Eleven commenters had expertise in or comments pertaining to Cyber Security standardization

Three respondents addressed in some way Emergency Communications Interoperability 

standardization;

One commenter provided commentary on Radioactivity Detectors and Radiation Monitors 

standardization.

Various commenters had professional expertise in areas directly tied to standards setting:

Five responding organizations or individuals came from the legal community;

Two respondents represented conformity assessment programs/accreditation programs;

Four respondents submitted commentary that had been submitted to the Department of 

Education RFI on educational accessibility interests; although their comments did not address 

the NIST RFI directly, they provided some useful insights into standardization practices and 

needs in the educational sector.

A numerical summary of the commenters’ responses to the broad questions raised in the RFI is given in 

Table 1. Twenty-six responses provided general commentary that did not specifically address the 

questions outlined in the RFI. 

Table 1: Numerical Summary of Responses to the RFI Questions 

Topics Addressed

Number of Responders

Addressing this Question

Standards Setting Processes 42

Reasons for Participating 11

Benefits of Standardization 14

Perspectives On Government’s Approach to Standards 30

Issues Considered During the Standards Setting Process 51

Adequacy of Resources 37

Process Review and Improvement Metrics 24

Smart Grid 20

Cyber Security 11

Health IT 16

Radiation Detectors 1

Emergency Communications 3

Other Technology Sectors 6

Response to the U.S. Department of Education RFI 4
8

Mentions NIST Specifically 36

Provides one or more Case Studies 20

Addresses IPR issues 43

Provides Recommendations 32

Section1: Standards-Setting Processes, Reasons for Participation and the 

Benefits of Standardization

Who participates in standards setting activities? 

A broad array of stakeholders from the private and public sectors participate in standards setting 

activities. 

Taking a high-level view, the participants can be categorized as representing:

Industry

Government

Standards Setting Organizations

Academic community (including teaching faculty and researchers)

Professional communities (including law, architecture, engineering, medical)

Nonprofit trade associations and interest groups

Individual experts who advise and monitor standards development activities

Sixty-five U.S. government bureaus were specifically referenced in the responses to the RFI. These 

agencies represent twenty-five executive, independent and legislative branch departments and agencies 

listed in the following table.

US Government Departments and Agencies Referenced in Responses to the RFI

Access Board FCC FTC

Agriculture

Forest Service

Soil Conservation Service

Interior

National Park Service

USGS

Bureau of Reclamation

National Transportation Safety 

Board

Architect of the Capitol Justice

FBI

Nuclear Regulatory Commission

CPSC GSA State

Commerce

ITA

NIST

NTIA

Census Bureau

NOAA

Health and Human Services

CDC

-NIOSH

FDA

SSA

-CMS

ONC

NIH

-NCI

-NLM

Transportation

Federal Highway Admin

Federal Aviation Admin

NHTSA

Defense Homeland Security Treasury
9

Army Corps of Engineers

Defense Logistics Agency

Defense Supply Center

National Geospatial 

Intelligence Agency

National Security Agency

Navy

 -Marine Corps

FEMA

NCS

CBP

TSA

IRS

Education

NIDDR-National Institute 

on Disability and 

Rehabilitation Research

Labor Veterans Affairs

Energy

Lawrence Berkeley NL

National Renewable Energy 

Laboratory

Pacific Northwest National 

Laboratory

Oak Ridge NL

Library of Congress

EPA NASA

Reasons for Participation1

The rationales for participating may be broken into three major categories including (1) general business 

and organizational motivators, (2) process or product improvement factors and (3) professional reasons. 

Business and organizational motivators: ensure business process representation, gain 

competitive advantage; obtain discounts; influence outcome; minimize the cost of establishing 

interoperability; support organizational mission; represent, advance, and protect corporate 

interests; ensure standards meet the broader needs of the industry; ensure fed agency 

requirements are met by the standards; reduce technology risk and systems costs; collaborate 

with other government agencies; encourage a more competitive market.

Process or product improvement motivators include: achieve interchangeability, compatibility 

and related functionality; develop new test methods; influence reliability, quality, efficiency, 

support market acceptance; reduce costs; advance technology and the state-of-the-art; market 

acceptance; setting appropriate reliability and durability assessment method; fix historical 

problems; maximize the life span and value of legacy systems.

 

1 Of the commenters who responded to this prompt (11), there were 8 SSOs, two industry respondents 

and one individual.
10

Benefits of developing standards2

Respondents described myriad reasons for participation. The rationales may be broadly grouped into 

the following categories: cost savings, commercial and market interests, government/social interests 

and other. Below are examples of specific benefits by category which were called out by the 

respondents.

Cost savings: greater efficiencies through eCommerce, paperwork reduction, simplification of 

contract specifications, overall efficiency, interoperability, avoids duplicative R&D and compliance 

with multiple format, production efficiencies, less costly exchange of data, interchangeability of 

replacement equipment and subsystems resulting in reduced life cycle costs, reduced vendor lockin, free up resources to spend on innovation, protect investments in new technology.

Competitive and market advantages: clarity between trading partners, ensuring standards meet 

business needs, understanding of issues facing industry, awareness of standards builds competitive 

advantage, improved quality, reliability, and market acceptance, commercialization of new 

technology, reduce potential for market failure, enable new business opportunities, enable new 

markets, foster innovation, facilitate technology diffusion, enhance competition, catalyze 

innovation.

Public Good (Government/Social): meeting government requirements, stimulate investment and 

economic growth, improved safety, health, welfare, security of networks, conservation of resources, 

consistent nomenclature, consistency in testing, global development, better management of 

congestion resulting in improved security and emergency response relieves the government of 

developing technical specifications.

Other: professional development, networking, developing of contacts to address issues, keeping up 

with state of the art.

How do standards impact organizations and their competitiveness?

Ten commenters, principally standards setters, responded to this question, generally agreeing that 

standards have a positive impact and contribute in a beneficial way to a competitive business 

environment. It was noted that as standards are used to address and resolve problems encountered by 

all those engaged in an industry sector resources can become available to support innovation that 

results in product differentiation that will fuel market growth.

How has standardization spurred innovation in the technology sector(s)?

Eleven respondents described how standardization activities intersect with innovation in their 

community. Two respondents offered the opinion that standardization has not been a driver of 

 

2 Of those respondents (14) who commented directly to this prompt, 8 were standards setting 

organizations, 3 represented industry and one each represented government, a trade association and an 

individual expert. Of note also is that 8 are engaged in the IT, ICT or Health IT sectors. 
11

innovation in their technology sector noting that, in their view, innovation has been spurred by cyclical 

peaks in industry activity. A third respondent commented that standards most often trail innovation in 

their particular industry sector. Other respondents reported that standardization activities have resulted 

in leaner, safer, sustainable designs and that the research undertaken to support standards efforts has 

resulted in improved and innovative products. One respondent, in the information technology sector, 

was unequivocal in stating that standardization was the driver that created innovative business 

opportunities that resulted in the formation of a new industry sector.

What is the current phase of the standards development process for this 

technology?

The respondents, in most cases, did not address this question directly. From the information presented 

we can conclude that the standards activities engaged in by the respondents ranged from relatively new 

standards work introduced within the last ten years to activities ongoing since the 1930s (or earlier). 

These represent mature standards supported through continuous maintenance to standards in the early 

development phases. 

How has the process worked so far?

Commenters provided their perspectives on how well the process is working. Some described the 

overall standards development process model, while others described specific stakeholder engagement. 

Overall the majority expressed the opinion that their system of engagement was working fairly well. 

However, there were a number of commenters that mentioned areas for improvement under this 

question. 

Areas of standards process improvement mentioned by commenters include:

Purchase and implement electronic tools to support the standards development process

Improve the length of time for standards development

Lower cost of participation or increase resources allocated

Increase stakeholder participation

In addition to commentary on areas of how the process has worked so far, several commenters made 

specific mention of areas that were working well that relate to federal engagement. These include:

Participation in standards development has been an effective use of agency resources

The role of convener (NIST) is an important role in the development of new standards for 

construction sealants.

How are standards setting processes managed and coordinated?3

Most respondents described an ANSI accredited process as the primary vehicle for management and 

coordination.

 

3 Of the respondents who answered this question directly (11), most (9) were standards developing 

organizations that to some degree or another described their organizations’ internal standards 

development process. 
12

Is there a strategic plan that identifies standards needs and defines the 

standards development life cycle?

Of the nine standards setting organizations that responded to this question directly, five indicated that 

they used some method of strategic planning. These appear to be strategic efforts at the organizational 

level such as a Board or oversight organization rather than at the technical standards development level.

Are there barriers to the development of high level strategies for standards 

setting?4

Respondents cited a number of barriers, reflecting both internal and external factors:

Internal organizational factors:

o Resource constraints, including financial and personnel limitations

o A lack of focus and vision characterized by indifference and complacency

o Conflicting organizational priorities, citing that maintenance of legacy standards is 

burdensome

o Lack of attention and lack of knowledge of strategic planning and tactics, i.e., 

participants in standards development are often technical and not strategic planners

External factors

o Uncertainty over federal, local or international policy (legislation and regulations)

o Conflicting stakeholder objectives

o Change: keeping pace with industry, technology, security threats

o Concern that standards setting will stifle innovation

o Concern over IPR issues in emerging technologies

One U.S. government respondent noted that a lack of familiarity with the NTTAA was a contributing 

factor to agencies not elevating standards setting as a strategic undertaking that would merit the 

attention of high-level strategy setters.

 

4

Seven commenters responded directly to this question. Five represented standards setting 

organizations, one was from government and one an individual with experience in standards 

development.
13

Section 2: Perspectives on Government’s Approach to Standards 

Activities

What methods of engagement are used by Federal agencies to participate in 

private-sector led standards development?5

As described by the commenters, the U.S. Government engages in and supports private-sector led 

standards development in a variety of ways. Of the twenty-three respondents that addressed this 

question directly, most respondents had experience with more than one of the avenues for engagement 

described.

Government’s engagement is either in a Leadership Role or a Supporting Role: 

Federal Government Engagement as . . . Example . . . 

Convener/Coordinator 

Identifies needs and directions, useable standards, 

and architectures in cross-sectoral collaborations 

to meet national priorities

Smart Grid

Nuclear Energy Standards Coordination 

Collaborative

Technical Leader

Is a member of an SDO/SSO

Agency staff are leaders in SDO/SSO governance 

and program execution 

The U.S. government participates in a 

leadership role in standardization work by

private sector standards bodies (e.g., U.S.

government staff leadership in OGC 

technical committees)

Participant

Agency staff as members of a standards writing 

committee

Over 748 federal agency staff are 

members of ASTM standards committees

Facilitator

Includes contracting for services to enable 

standards writing

In Health IT: CDC and other agencies 

engage in direct contracts that result in 

the development of standards and 

implementation guidance

 

55

Thirty commenters responded to the RFI questions pertaining to how the U.S. Government engages in 

private-sector standards setting. Of those thirty respondents, 16 were standards developing/setting 

organizations, 5 from industry, 5 trade associations and nonprofits, 3 were federal agencies, and one an 

individual expert.
14

Implementer/Adopter

Selects and implements a private sector-developed 

standard or requires its implementation through 

regulation.

ASME standards on thermometers satisfy 

procurement needs of DoD and eliminate 

the need for a unique Federal standard

Funder/Enabler

Funds standards activity of an SDO or assigns an 

SDO to manage the process; enables

implementation of a standardized approach 

among a community of implementers

Intelligent Transportation Systems: DOT 

funded SDO project management

Health IT: National Library of Medicine

licensed access to the common 

vocabulary, SnoMed 

DOE funding for ASME Energy Assessment 

standards

Technical Advisor

Provides research and development to support 

standards development or develops test methods 

to support a technical standard

Homeland Security: U.S. Government

provided baseline test environment for 

DICOS

Coordinator of Federal Agency Needs

Formally collaborates to address a common 

problem, transferring this knowledge to an 

SSO/SDO

Federal Geographic Data Committee

Interested observer

On an ongoing basis, monitors developments and 

assesses opportunities for engagement

How transparent is each method?

All of the respondents agreed that the standards engagements driven by the ANSI-accredited model or 

fashioned on that model were transparent. Many respondents described the various aspects of the

standards programs that supported transparency, such as frequently updated webpages, public review 

of drafts for comment, and availability of documents. 

The method of federal government engagement that was viewed as least transparent was government

contracting of standards development work as there are few opportunities for input and monitoring by 

outside parties.
15

How effective is each method of engagement?

Twenty respondents described federal government engagement in standardization as “effective.” 

However, it was clear from the commentary that each approach pursued had its own strengths and 

weaknesses, and that the timing of the undertaking and the view of industry to the need and value of 

prospective standardization were important factors determining the success of federal government 

engagement. Respondents felt that the most successful engagements occur when industry determines 

that standardization is in their best interest and approaches the government for assistance. 

The particular approach taken by the U.S. government to engage in standardization can be driven by the 

maturity of the technology subject to standardization. One commenter (a standards setting 

organization) observed that in the case of mature technologies, direct participation is highly effective. In 

the case of emerging technologies a more indirect approach, such as providing funding to explore 

various approaches or convening meetings to explore the issues and dynamics at play, can be more 

fruitful in the short to medium term as the industry coalesces.

There was a consensus among commenters in the IT sector (five respondents) that government should 

avoid mandating standards as it can be disruptive and, in the end, counter-productive given the rapid 

pace of innovation in the technology sectors.

The timing of the standards engagement was also discussed. It was noted that engagement by the U.S. 

government at an early stage was most effective especially when the standard will support regulatory 

needs.

Overall, the sense of the respondents was that U.S. government engagement is highly valued, but 

government must be prepared to participate as a partner in industry-led standards setting.

How could the methods be improved?6

Many responses addressed the need for improvements in federal engagement; the responses can be 

grouped into several broad categories: communication of government needs, coordination of 

engagement, designation of resources (including effective internal standards policies and strategies).

Communication of needs and coordination of engagement: 

Need better coordination of federal agency engagement

Need mechanism to assess and communicate success and failures

Engage early in the process of standards development

Project regulatory needs

Need better prioritization of needs and timelines

Provide feedback on voluntary consensus standards that have been developed

During rulemaking – need more transparency and communication of needs

Empower agency representatives

 

6 Of the 21 respondents to this query, 11 represented standards setting organizations, 4 were from the 

non-profit/trade industry sector, 3 from industry, 2 from government agencies and one individual. 
16

Improvements in internal policies and strategies:

Need more consistent interpretation and policy implementation across Federal agencies relative 

to government participation in standards development

Need incentives for staff participation

Need better mechanism for maintaining up to date standard references in regulation

U.S. government facilitation is needed to bring together cross sectoral industries – create a 

framework 

Government should not pick winners and losers, need market driven approach

Government should approach standardization from a global perspective rather than purely 

national 

U.S. government has a shared objective with industry

Need agency strategic plans with timelines

Engage with SSOs that use open, transparent and inclusive procedures

Choose and codify best standards to facilitate widespread use

Resource-related improvements:

Need more government participation

U.S. government should provide resources to support technology based standards development

Provide resources, data and analysis for standards development

Need sustained and properly resourced participation 

Need policy-level and technical representation from U.S. government

Become dues paying members of ANSI

Support engagement of federally funded state agencies

Support the need for standards curricula in formal education

What other methods should the Federal agencies explore?7

General: 

In areas without strong industry support, such as “orphan standards” in the accessibility and 

assistive technology arena, there should be a mechanism to request U.S. government

support. 

Agencies need a single department (office) within their organization to support standards in 

their mission area.

Do not consider a single coordinating point in the U.S. government because specific 

technical expertise is needed and a single coordinator would not be adequately capable.

 

7

Fourteen respondents addressed this question directly including seven standards setting organizations, 

four organizations from industry, two from the non-profit professional society/trade industry sector, 

and one from government. Responses were either general or technology sector specific.
17

Consider the model of a “request for proposal” for selection of a standards developer in 

emerging technology areas that cut across agencies

Consider the success of the model used in the development and adoption of state-level 

codes – all jurisdictions are engaged resulting in broad adoption and sense of ownership.

Consider promoting increased used of wiki-based tools in standards development.

Sector-specific: 

Health IT - continued engagement once standards have been developed – maintenance, 

updating, etc.

Health IT - provide support to virtual meetings which will bring more individuals to the 

standards table. 

Health IT - consistent with their charter, ONC Office of Standards and Interoperability should 

be coordinating federal agency policy and program including contracting, direct and indirect 

involvement.

IT - consider a process that is both open and global, prefer an international “design once, 

test once, single conformity assessment” approach.

ICT - Enhance ICT systems and supply chain security by improving ISO 15408 – Common 

Criteria for IT Security Evaluation

Smart Grid - NIST and FERC should consider the views of implementers such as state 

commissions and utilities, taking into consideration the potential for early obsolescence of 

deployed systems. 

What impact have Federal agencies had on standards activities?8

Most comments reflected a positive impact of federal agencies on standards activities with one 

comment being negative and two neutral.

The types of impacts described include a critique of government’s impact on the development of and 

use of standards that are created for purposes such as interoperability, technology advancements, and 

regulatory use (i.e. health and safety). Some commentary was non-specific or general.

In interoperability and technology deployment:

Government engagement (NIST) facilitates acceleration of standards development in the area of 

Smart Grid technology

Federal participation and support has been positive with agencies providing effective staff, 

content guidance, and funding to the development of Health IT standards. 

 

8

Responding to this question were 19 entities representing 12 standards setting organizations, two 

government agencies, two companies from industry, two from the non-profit trade 

association/professional society sector and one individual. 
18

Government engagement (National Geospatial Intelligence Agency) with staff and funding 

support has enabled the rapid development of geospatial standards for national and 

international use while addressing urgent government interoperability challenges.

Government successfully outsourced to an SSO numerous Health IT projects including Health 

informatics, Electronic Health Records, immunization registries, clinical data interchange 

standards, and other health data standards.

U.S. Government (NIST) provided effective leadership in the development of biometric 

standards in coordination with a major ICT standards developer. 

U.S. Government leadership (NIST) and government participation on cross-cutting technical 

committees in nanotechnology provides scientific credibility to standards development. 

Federal agencies’ obsolete policies and regulations impede progress and innovation in Health IT 

standards

Federal agency impact on standards development in the nuclear area has been mixed

Government mandated standards can alter the marketplace, resulting in reduced incentives for 

innovation and less optimal solutions for the affected technology sector.

In regulatory areas: 

Regulatory agencies have a large impact on the end use of voluntary standards through 

guidance documents and compliance schemes. 

Federal regulation and legislation results in mass adoption of standards by industry.

U.S. government participation directly impacts technical elements of standards including data 

requirements

U.S. government participation resulted in the establishment of a separate task group to address 

federal agency requirements (U.S. Customs and Border Patrol). 

When the U.S. government is engaged, the (financial data) standards developed address a 

broader range of business needs.

The U.S. government (CPSC) model of strategic and effective engagement brings data and 

technical expertise to the effort resulting in the rapid development of safety standards. 

Mandatory standards can inhibit competition and investment 

Other sectors and general comments:

Federal agencies have provided funding to underwrite important standards development and 

have provided highly productive staff to the effort. 

The government (NIST) assisted the sealants industry with critical technical support and 

facilitated the development of test methods for architectural sealants which no single company 

had the ability to do.

Government programs have a large financial impact: i.e., a large percentage of business in 

Health IT comes from federal programs.

Current standards policies have resulted in increased use of voluntary standards, “has made 

government regulation and procurement more efficient and globally relevant” and has 

benefited both the government and regulated community
19

U.S. government engagement provides a positive effect on the standards developing activity by 

bringing a different perspective, data, and resources to the effort. 

Government engagement shortens the standards development timeline.

Government engagement ensures that government needs are being met (ICT services, 

applications and products).

Government plays an important role in advocating a multiple-path approach to the 

development of international standards.

How well do Federal agencies coordinate their roles in standards activities in 

the sector of interest?9

Most of the comments received as a direct response to this question suggested that overall government 

agencies engaged in standards activities lacked coordination of their roles. 

Negative 

In Smart Grid, there was a perceived lack of FERC engagement.

In Health IT, while several federal agencies have engaged competently at the technical 

committee and leadership levels, across agencies “coordination is very poor” and there is “little 

or no coordination.”

In emerging technology areas, there is a need to “better coordinate and optimize federal 

resources” in support of commercialization.

In nuclear technology, the government is not proactive in implementing policies, procedures 

and programs.

Overall there is an observed lack of coordination or weak coordination across federal agencies.

In nanotechnology, communication across federal agencies is limited.

Positive

In intelligent transportation systems there is good coordination across agencies.

In the import arena, there is excellent coordination between Customs and Border Patrol and 

agencies that rely on trade data.

Digital Imaging and Communications in Security (DICOS) standards development efforts are

coordinated across federal agencies.

When Federal agencies have been involved in standards setting efforts in a

technology sector, how has the progress of standards setting efforts in this 

technology sector changed after Federal agencies became involved?10

Respondents described both positive and negative influences on the progress of standards setting 

efforts as a result of federal engagement in standards development in a range of technology sectors 

 

9

Twelve entities responded to this question including eight standards developing organizations, two 

from government, one non-profit/professional society and one individual. 

10 Fourteen respondents, including 11 standards setting organizations, two government entities, and one 

individual addressed to this question
20

including smart grid, health IT, geospatial, nuclear, cable communications and aerospace. The 

respondents offered a number of views on the impact of U.S. Government engagement on the progress 

of standards setting:

Positive:

Federal engagement can accelerate standards development.

Significant contributions of federal resources and knowledge during standards development 

helps to develop, guide, and shape the standard.

Federal engagement results in increased adoption of the standard.

As long as the government and the private sector have a shared vision, federal engagement is 

not negative.

Standards development runs more smoothly when federal agencies are involved.

Negative:

Ineffective participation results in a lost opportunity for the government.

Too much information (brought to the table by the government) can slow standards 

development.

U.S. government participation can slow or impede standards development.

Government contracting problems can slow standards development. 

U.S. government adoption of standards can result in “fossilization” of technology and hamper 

innovation.

Are Federal agencies generally receptive to input from other participants in 

standards-setting activities? Does receptiveness tend to depend on whether 

the Federal agency is a regulator or a customer?

Overall, government agencies were viewed as being receptive to input from others and working well 

within the standards framework to the benefit of all participants.

Only one commenter reported a difference in the character of the federal agencies’engagement based 

on the agency’s regulatory responsibilities, noting that “occasionally a regulator (state or federal) will 

look at issues solely from the perspective of jurisdictional enforceability, rather than as drivers for 

improvements in safety, technology, performance, or global relevance.” 
21

In those sectors where Federal agencies play a significant role in standards 

activities, how valuable and timely is the work product associated with this 

effort?11

The consensus among the commenters was that the work product that results when the government is 

significantly involved is both timely and valuable. One commenter observed that the progress can be 

delayed due to the wealth of information that government contributes to the process, but that the 

quality of the final product benefits significantly as a result of U.S. government contributions. 

A commenter from the SSO sector, in a position to observe the contributions by several agencies 

participating in standards setting activities, advanced that U.S. government agencies would benefit from 

having a clearer understanding of the policies undergirding government participation in standards 

development, in particular the NTTAA. This commenter observed that “Inconsistent application of the 

tenets of the National Technology Transfer and Advancement Act (NTTAA) and its implementing 

instructions delays the timely development of standards relevant to the needs of federal agencies.”

 

11 Eight commenters responded to this question: seven standards setting organizations and one 

individual.
22

Section 3: Issues Considered During the Standards Setting Process12

Part 1: Technology, competition, the impact of innovation, etc.

Twenty-seven commenters spoke to issues including: technology, competition, the impact of 

innovation, trade issues and foreign regulations. Many of the standards setting organizations 

responding to the RFI noted that their organization’s operating procedures provide explicit guidance to 

their standards committees on these matters.

However, many commenters then elaborated on areas of concern related to the topics suggested. 

For example, in discussing the impact of technology, a number of commenters expressed the opinion 

that the government should avoid picking winners and losers in areas of technology standardization. It 

was suggested that when there is a government interest in standardizing in a technology, the 

government should identify and clearly describe its standards needs and objectives and let the market 

provide the solutions as market forces will enable the “right” standard to emerge. In developing 

technology standards, a number of commenters advised that accessibility issues must be considered 

early in the standards development cycle. 

In issues of competition and innovation, federal agencies were often perceived to “handicap” 

competition, “inhibit innovation” and “shortchange consumers.” This was attributed to the effects of 

premature standardization, vendor lock-in, and technical regulations that can result when regulators 

take a narrow view focusing solely on agency interests during standards setting. A number of 

commenters also noted that to promote innovation intellectual property rights must be protected 

during standards development so innovators have sufficient incentives to engage in and actively 

contribute to standardization work.

A respondent noted the federal government’s lack of promotion and support for U.S. standards

internationally has a detrimental effect on the competitiveness of U.S. products. For example, in the 

HVAC sector, it was reported that U.S. influence (and competitiveness) has waned as a direct result of 

non-participation of government experts in related ISO work. 

Regarding standards overlap and duplication, several approaches to mitigate this issue were described:

It was reported that federal agencies working in several technology areas provide a direct 

coordination role that minimizes overlap and duplication. These areas include nuclear energy, 

 

12 Respondents to this question were asked to describe how various factors (intellectual property rights, 

technology, competition, innovation, foreign regulations, overlap and duplication of standards, and the 

impact of international standards) are considered in the standards setting process and how these issues 

might impact standardization processes and outcomes. Fifty-one respondents commented on this 

question. Factors related to intellectual property rights received most attention and are summarized in 

Part 2 of this section. 
23

Smart Grid, nanotechnology, and hydrogen and fuel cell technology involving NIST and the 

Department of Energy. 

ANSI’s Project Initiation and Notification System (PINS) is used by many, but not all, standards 

developers responding to the RFI, to announce standards projects in advance and call for 

stakeholders, including federal agencies, to provide input on overlap and duplication. 

The use of formal Standards Panels helps minimize overlap and duplication. 

It was also noted that U.S. government employees often bring knowledge of existing standards 

to the table. 

Some standards developers conduct an environmental scan prior to initiating a new project to 

identify areas of overlap or redundancy. 

Finally, one SSO stated that the proliferation of standards development organizations has contributed to 

overlap and redundancy and urged the government to assert more leadership to promote coherency in 

standards development.

With respect to foreign regulations, most of the commentary centered on a description of the issues 

encountered rather than describing how the issues were addressed and /or resolved in standards 

development activities. Commenters offered that:

Foreign regulations can be barriers to regulatory convergence for new technologies; 

U.S. government should work to eliminate non-tariff trade barriers by promoting use of 

international standards in technical regulations 

The U.S. should work to harmonize U.S. standards and with other international standards 

organizations, national standards bodies and international trading partners.

U.S. government should seek full implementation of the WTO TBT agreement and require 

incorporation of previously agreed upon international standards principles into its legal 

framework. 

U.S. government, in collaboration with other stakeholders, should promote the U.S. standards 

system internationally so there is greater understanding globally of the U.S. system’s strengths 

and benefits ; 

Standards developed by U.S. domiciled standards developers are often used as the basis for ISO 

standards and should also be promoted as input to foreign regulations. 

The European Commission welcomes the effort to implement a coherent standards system that 

does not overlap or duplicate international standards.

There is a perceived lack of communication between ISO technical standards work and many 

U.S. standards developing organizations

Globally oriented consortia tend to naturally operate well outside and beyond national 

standards bodies.

The Food and Drug Administration supports international standards while many agencies ignore 

them.

The U.S. government should support the development of international standards which reflect 

U.S. interests, and which will help to preempt the proliferation of regional standards.
24

The U.S. should find better ways to represent national interests in international fora and the 

U.S. should be active on foreign standards bodies.

The U.S. government should work to counter “not invented here resistance” and promote global 

interoperability. 

Aligning U.S. standards practices and interests with standards setters outside the United States

can be a challenge, for example: the EU prefers open standards and open source software 

products in procurement; China requires use of indigenous developed technology and wants to 

discount royalty payments in procurement.

Part 2: Copyright13 and intellectual property rights14

Patents in standards

Respondents noted that a range of approaches help address the complex interplay between patents and 

standards, and that having this flexibility enables industry to provide solutions that are timely meet the 

needs of the specific technology sector and the participants in that sector. Eight respondents indicated

that the approaches which balance the rights of IP holders to recover their investments in developing IP 

with those of parties interested in licensing the IP provide adequate incentives to IP holders to put 

forward their IP for consideration in standardization. 

According to respondents, with a few exceptions the current system in the United States has worked 

well with few instances of patent hold-up among thousands of standards that have been developed. 

One respondent noted the importance of distinguishing between true patent hold-up and the lack of 

agreement over licensing terms which would be considered a commercial dispute rather than patent 

abuse. Other respondents recommended that SSO IPR policies should do more to mitigate the risk of 

opportunistic licensing behavior by patent holders participating in standards-setting activities. A 

number of respondents noted that the flexibility afforded by the current system has enabled the United 

States to assume and maintain a leadership position in the global economy in the information and 

communication technologies related sectors.

Four respondents (all SSOs) noted that their rules either do not permit or discourage the inclusion of 

patented or business confidential technologies in the standards their organizations develop. A 

respondent suggested that due to the “patent thicket” it may not be possible to exclude all patented 

technology – e.g., certain standards may require the implementation of hundreds of patents.

 

13The sixteen respondents who touched upon copyright and sales of standards related issues include 11 

organizations with standards setting activities, 3 companies, and 2 respondents with an interest in the 

issue.

14 Of the responses that provided perspectives on aspects related to patents in standards, 13 

respondents are involved in standards setting activities, 8 are trade associations or professional 

societies, 9 respondents are companies, while 4 respondents may be considered to be 

organizations/individuals with an interest in the issue.
25

Some major themes

A number of respondents stressed the importance of transparency and clearly defined IP policies. 

Respondents also noted that the federal government should not mandate a single IPR approach for 

standards (in general, or for standards it is considering for its use), and that a mandatory IPR policy, even 

for standards that the government is considering for its use would have a stifling effect on innovation, 

and potentially adversely impact the willingness of IPR holders to participate in standardization.

Several respondents also noted that given SSOs are often best positioned to help articulate IPR policies 

for standards that they develop to strike an appropriate balance between the interests of its members, 

its standards users, IPR holders and licensees, SSOs have an inherent interest in getting this right.

With respect to mechanisms that enable inclusion of IPR in standards, 12 respondents discussed 

mechanisms for disclosure of essential patent claims and disclosure of licensing terms. A number of 

respondents voiced support for voluntary disclosure of licensing terms, with two noting that disclosure 

of maximum licensing terms can bring greater predictability and certainty to implementation costs. 

However, five respondents disagreed with any mandatory ex-ante declarations of maximum licensing 

terms, expressing concerns that such ex-ante mandatory disclosure requirements could potentially 

disadvantage the IPR holder if other parties engage in buyers’ cartel-like behavior to extract the lowest 

possible licensing terms from the IPR holder. Eleven respondents also noted the role of licensing 

commitments whether on RAND, FRAND or royalty free terms.

Multiple respondents observed that IPR licensing considers a set of complex questions and licensing 

engagements are not simple one-to-one negotiations. IPR holders license IPR for defensive and/or 

revenue producing reasons; RAND terms provide IPR holders the flexibility needed to accommodate 

these various objectives. One respondent disagreed, noting even when IPR holders commit to license 

their IPR on RAND terms, the negotiation process lacks transparency to those who are not party to the 

negotiation, and this permits patent holders to negotiate with potential licensees one-on-one from a 

position of strength. This commenter noted that this factor can be particularly disadvantageous to a 

newcomer that does not have their own portfolio to trade. Noting instances of disputes and lawsuits 

between implementers and companies claiming to own essential patents regarding whether particular 

licensing terms do or do not comply with RAND and the potential costs to the federal government, 

another respondent noted that RAND terms provide federal agencies with little visibility into future 

licensing costs that the government could incur, either directly or indirectly in the prices they pay when 

they purchase products that implement standards.

One respondent noted the challenges associated with the use of standards from multiple sources with 

different licensing terms when implementing standards in complex technologies. Others felt that this is 

not a significant issue.

15 . One respondent noted that the uncertainty of disclosure in the standards 

 

15 A recent study that identified 251 technical interoperability standards implemented in a modern 

laptop from multiple SSOs was cited in this context. Evaluating the IPR policies of 197 of these 251 

standards, the authors noted that 75% of the standards were developed under RAND terms (including 

RANDz), 22% under royalty-free (RF) terms, and 3% were licensed through patent pools. 
26

setting context has created opportunities for strategic behavior, such as “the ambush of standards by 

nonparticipating third parties”, an issue that is outside the direct control of SSOs.

Suggestions from respondents relating to IPR in standards

Respondents made various recommendations to the federal government relating to aspects of IPR in 

standards, including recommendations specific to SSOs own IPR disclosure, negotiations and licensing 

rules. The recommendations implicating government participation are summarized here, and this 

summary does not reflect any federal government position on their merits. These recommendations 

include (in no particular order of importance, and representing the various perspectives):

The federal government should not mandate a single IPR policy for standards it may wish to use, 

or consider for use, for its purposes. It should take an inclusive view of the spectrum of IPR 

policies, and not promote one approach over another.

Revise OMB Circular A-119 to potentially: 

o announce a federal preference for standards created under rules that permit, encourage 

or require participants in standards development to state their maximum licensing 

terms during the standards development process

o encourage federal adopters to select standards created using negative declarations, i.e. 

requiring participating patent holders to identify patents essential to the standards that 

they are unwilling to license

o favor adoption of standards created under IPR policies that require transferees of 

essential patents to be bound by licensing commitments given by their predecessors in 

interest

o clarify that a RAND or RF licensing commitment prohibits participants from seeking to 

enjoin implementers of standards, at least until an objective third party such as a court 

or arbitrator has determined that the patentee has offered to license on reasonable 

terms

Clarify ambiguities and consider current SSO practices, which may not conform with the literal 

terms of OMB Circular A-119

Relating to OMB Circular A-119, the federal government should clarify that reference to RAND in 

the Circular should be the minimum that federal agencies should require before they choose to 

adopt a standard, and that federal agencies are encouraged to include IP-based considerations 

in their selection of particular standards for federal adoption, including whether the standard 

were created using IPR policies that provide agencies, and vendors from which they purchase 

products that implement standards, with predictable IPR licensing terms.

While considering standards for inclusion in standards frameworks that the federal government 

may be developing for its purposes (e.g., addressing national priorities or for procurement 

activities), the federal government could consider creating a check list to determine whether 

SSOs developing the standards in question have an IPR policy consistent with the requirements 

of OMB Circular A-119. A high-level check list developed in conjunction with the stakeholders,

 
27

including SSOs could identify issues potentially blocking the implementation of specific 

standards being considered by the federal government, e.g.:

o any declarations of unwillingness to license essential patent claims on RAND or RF terms 

o any known IPR lawsuits, threats of litigation, or settlements involving the standardized 

technology 

o set time frames for early opt-out of participants who may not be willing to license 

essential claims on a RAND basis 

o policies relating to continuity of licensing commitment, if made, even after the 

participant withdrawal 

o any requirements that bind the employers of individuals participating on an individual 

basis in standards setting 

o policies relating to transfer of patents that include essential claims, and including 

patents transferred in bankruptcy

o whether royalty rates and the determination of the “reasonable” element in RAND 

licensing would be based upon the contribution of the particular patent to the value of 

the device in which it is implements, or the value of the entire device

The federal government should take into consideration whether the SSOs developing standards 

that it is interested in have IPR policies, and whether these policies are easily and publicly 

accessible. The federal government should also encourage SSOs to make easily accessible 

associated additional documentation such as patent self-declarations, essential claims, patent 

licensing commitments, letters of assurance, any notices of objection, exclusion, or exceptions 

to licensing commitment under the SSO’s IPR policy, etc.

The federal government should provide clear and uniform guidance by which developers (e.g., 

entities operating government laboratories or facilities, entities funded under research or 

development contracts, etc.) can take ownership of government-funded inventions (under 

Bayh-Dole or similar provisions), if the developer is subject to a RAND commitment to license 

necessary patent claims.

To provide certainty to government-funded developers who may seek royalties for inventions 

they develop related to technologies of interest to the federal government, the federal 

government could provide guidance on when royalty-free license rights apply.

The federal government should license patent claims made by government employees (or 

otherwise owned by the government) that are necessary to implement a government-supported 

standard, under royalty-free or RAND licensing terms.

Copyright and sale of standards

Responses relating to copyright and sales of standards addressed three major issues, including:

Business models based upon revenue generated from sales of standards

Seven respondents addressed how sales of standards support various business models of SSOs. 

Responses indicated that sales of standards often are a significant revenue source for standards 

setting organizations, and enable low these organizations to keep the fees for 

membership/participation low, thereby reducing the barriers to participation in standards setting.
28

Observing and protecting rights of copyright holders

Six respondents discussed aspects of observing and protecting the rights of copyright holders, 

including observing the appropriate provisions in OMB Circular A-119. Three called upon federal 

agencies that use standards developed in the private sector to respect the IP of the standards 

setting organizations developing these standards. One of these responses noted that agencies 

should provide proper attribution when using these standards. Three respondents noted provisions 

within OMB Circular A-119 requiring that “...if a voluntary standard is used and published in an 

agency document, your agency must observe and protect the rights of the copyright holder and any 

other similar obligations...” 

Access to standards

Different aspects of access to standards and availability of standards for review and/or use were 

also discussed within the responses – reflecting the current debate about enabling access to 

standards to all parties, particularly if the standards in question may be used in support of rulemaking or may otherwise be adopted by state or local governments. Some of the responses have 

noted the high cost of standards as a barrier to access of standards. One response (state 

government regulatory authority) notes this to be a particularly significant issue, as they are charged 

with adopting standards by statutory authority, and observe that the high cost of the standard is a 

barrier to their ability to review the standard in question. Three respondents (all standards setting 

organizations) noted how they enable free or minimal barrier access to their standards to interested 

parties, using different mechanisms. These methods of access including access to the complete 

standard for free, or access to the standard in order to review the standard. 

Three respondents also discussed various issues relating to free access to standards. Three

respondents suggested that in case of standards with significant public use, the federal government 

could support SDOs through grants that could in turn enable free or very low cost access to the 

standards. One response noted that in cases where federal agencies have significantly supported 

the development of standards, including through federal grants/contracts/funds, etc., and 

significant agency staff time (e.g., in agency staff leadership and participation of standards activities) 

then the resulting standards should be made available to the public for free. 

Ownership of copyright

Two responses touch upon copyright ownership of standards that are developed with either significant 

federal agency staff participation or by federal contractors. One response recommends guidance and 

clarification for situations where a standard has been developed in a private sector organization, with 

significant resources of the federal government and the help of federal government contractors. A 

second response notes that: “. . . copyright ownership in standards can be further complicated by the 

Government's participation in standards development. Any work ‘prepared by an officer or employee of 

the U.S. Government as part that person's official duties’ are not subject to copyright per sections 101 

and 105 of the Copyright Act - Accordingly, while the Government's participation in standards 

development activities may be valuable, SDOs may wish to limit Government's role in standards 

development to minimize the risk that the Government could be considered a co-author of a standard 
29

unless there are changes to the Copyright Act that would allow standards co-authored by the 

Government to retain copyright protection.”
30

Section 4: Adequacy of Resources16

Most respondents expressed the need for better and more consistent federal commitment to standards 

development within the existing private-sector led framework. 

Participation in standards setting

Nearly two-thirds of respondents focused on the adequacy and quality of participation in standards 

activities. Many suggested that greater and sustained participation by the U.S. government both 

domestically and internationally is needed, along with the commitment of time and travel funding. 

Several commenters noted that the engagement of technical experts --offering “contributions of 

valuable expertise, knowledge, and time”-- is essential for developing a successful standard.

Federal funding support for standards development

Increased federal funding commitments were desired by many commenters. Specific suggestions 

included: 

providing additional resources to the private sector standards setting organizations through 

increasing the level of dues charged to federal agencies so that they more closely track 

corporate dues; 

providing grants for reserve funds; 

providing grants to standards setting organizations to enable them to make standards available 

for free, particularly those standards referenced in regulations; and 

working to ensure multi-year funding commitments for standards development engagement. 

Federal government funding for targeted standards development projects was also identified as a tool 

for enabling strategic standards work. Examples include:

seed funding to initiate projects similar to the Smart Grid effort; 

timely short-term bursts of funding to enable completion, maintenance and access to critically 

needed standards that must be completed in a short timeframe; and

creation of an “evergreen fund” to provide loans to standards developers to underwrite 

essential technical projects. 

In specific technology areas, suggestions for additional federal funding included the support of licensing

and tool development costs for international interoperability in Health IT standards, support of a Smart 

Grid standards pilot project, and federal funding to identify the work needed to enable an expedited 

development schedule in nuclear energy standards. 

Besides direct funding and participation, several commenters recommended in-kind support of 

standards development including use of federal testing and conference facilities to help lower costs of 

the standards development process. Additional suggestions included recommendations for 

improvements in resources such as the creation of a clearinghouse of global standards and those in 

 

16 Thirty-seven respondents provided input related to the adequacy of resources invested in the standards setting 

process. Commenters included representatives from standards setting organizations, individuals, non-profit 

organizations including trade associations and professional societies, and industry. 
31

development, and, as has been used successfully in the past, the strategic use of federal purchasing 

power to create markets for goods that meet targeted standards. 

Management of standards development

The need for adequate and coordinated management of standards development efforts was expressed 

including providing additional support to NIST for its role. 

In Health IT, resources are needed for a “coordinated strategy across the private and public sectors.” 

The imposition of arbitrary deadlines has a negative impact on the quality of standards development 

efforts and creates unnecessary pressure which can impact the attainment of consensus. The use of 

standards development strategies and technology tools to enable greater participation, creation of 

incentives for small and medium sized businesses to participate, as well as employment of an 

ombudsmen model were recommended. 

A few commenters opined that that the government does not need to allocate additional resources than 

what is already provided. One standards setting organization expressed the opinion that “federal 

funding is not a significant factor in the development and deployment of standards (but strategic 

government engagement is).” Others observed that government support is uneven noting that some 

agencies, such as the Department of Defense, have committed adequate resources while many civilian 

agencies have not. Another commenter suggested that a review of current federal resource allocation 

practices could result in more consistent (and effective) engagement. 

Participation by state-level agencies and small and medium sized businesses is critically hampered by 

travel and staff costs which, over time, become prohibitive. As a consequence, the perspectives of these 

constituencies are absent during the standards development dialog at the national and international 

levels.
32

Section 5: Process Review and Improvement Metrics17

Lessons learned

The respondents offered “lessons learned” in three areas:

Standards engagements

There is no universally applicable approach; each opportunity must be evaluated independently

A cross-collaborative standardization model provides the process and framework for public and 

private sector stakeholders to work together to address issues of national priority

All stakeholders must be engaged early in the standards development process to ensure market 

relevance; 

Stakeholders must embrace a shared vision

Government’s role in standards setting

Should engage at an early stage in standards development

Must clearly articulate its goals and objectives

Should regard standards engagement as an investment by offering expertise, resources, and

tools needed to advance implementation of standard s

Standards development

Standards work must be managed as any other significant project with milestones, deliverables, 

etc. 

Standards writers must unambiguously define system specifications prior to standardization

In most cases “lessons learned” are incorporated as appropriate into an organization’s procedures and 

processes, and shared with volunteers and leadership, resulting in ongoing organizational 

improvements. One large standards developer reported that it now uses formal market research to 

determine the market relevance of proposed standards and conducts pre-standardization technical 

analysis to support standardization criteria as part of its standardization activities.

Performance metrics

Commenters described a variety of performance metrics to measure the success of a standards setting 

activity and the impact of standardization work:

 

17 Twenty-four respondents provided information on lessons learned and performance metrics used to 

quantify the effectiveness of the standards-setting. Half of the respondents were standards developers 

(consortia and SDOs); the rest were an equal mix of Government, industry, and nonprofit/trade 

associations, and individual experts.
33

Measuring the success of a standard: adoption, use, impact

Size of specification (pages)

Measures of use: Number of products implementing/testing in initial stage; Number of products 

implementing/testing after one year

An objective measure of “ease of implementation”

Requests for interpretation 

Requests for training

Documented use of the standard in regulatory frameworks

References in the scientific and professional literature, including peer reviewed articles 

Sales volume

Proposed revisions under consideration

Use/implementation of the standard in global markets (sales, mou’s)

Use of the standard in regulatory frameworks

Measuring success of standards setting processes: efficiency, inclusiveness, timeliness

Participants: Number of participants in the development process; Number of balloters

Committee Performance and Budget tracking

o Total numbers of projects underway; percentage completion of each project; 

percentage completion to schedule; active projects completed in the year; projects with 

scopes defined; projects approved; percentage schedule adherence, overall; how 

quickly is the standard available (elapsed time from project inception to 

release/publication); committee membership and meeting attendance

One commenter (from the geospatial community) indicated that a formal study was conducted 

to document the impact of standards setting in that sector. The 2005 study, funded by NASA 

and conducted by Booz Allen Hamilton, compared proprietary and standards-based large scale 

implementations. The study showed that geospatial standards delivered significant operational 

value and cost savings.
34

Appendix 1: Commenters to the NIST Request-for-Information released 

December 8, 2010

1. The American Association for Laboratory Accreditation (A2LA)

2. Accredited Standards Committee (ASC) X12

3. Advaiya

4. Aerospace Industries Association/Strategic Standardization Forum for Aerospace 

5. Air-Conditioning, Heating, and Refrigeration Institute 

6. Alliance for Telecommunications Industry Solutions 

7. American Bar Association, Section of Science and Technology Law

8. American Council of Independent Laboratories 

9. American Intellectual Property Law Association 

10. American National Standards Institute 

11. American Nuclear Society 

12. AMIA

13. Anonymous individual

14. ASME 

15. Association for the Advancement of Medical Instrumentation 

16. Association of Home Appliance Manufacturers 

17. ASTM International 

18. AT&T

19. Aware, Inc.

20. Barbe, Louis

21. Bechard, Sue, et al

22. Beneficial Designs, Inc.

23. Cable Television Laboratories, Inc.

24. California Public Utilities Commission and Public Utility Commission of Texas

25. Center for Disease Control and Prevention/The National Institute of Occupational Safety and 

Health (CDC/NIOSH)

26. U.S. Chamber of Commerce

27. Cisco Systems and Research In Motion 

28. Cohen, Howard J.

29. Computer and Communications Industry Association 

30. Consumer Electronics Association 

31. Davis Wright Tremaine, LLP

32. Deere & Company

33. Department of Veterans Affairs 

34. Ebelhar, Ronald

35. Electronic Commerce Code Management Association

36. Epic

37. European Commission DG Enterprise and Industry Unit C5 - Standardisation

38. Federal Geographic Data Committee (FGDC)

39. GE Energy, Digital Energy

40. GE Healthcare Systems

41. GTW Associates

42. Health Level Seven International (HL7)

43. HIMSS Electronic Health Record (EHR) Association

44. IBM 
35

45. Illumination Engineering Society of North America (IESNA)

46. Information Technology Industry Council 

47. Intel Corporation

48. Intellectual Property Owners Association 

49. Intellegere Foundation

50. International Code Council

51. IPC-Association Connecting Electronics Industries

52. JISC Center for Educational Technology and Interoperability Standards 

53. Jordan, Tom

54. Laing, Patrick G.

55. Layer 7 Technologies

56. Loud, James

57. Lumeta Inc.

58. Maden Technologies

59. Marks, Roger B.

60. Medical Imaging and Technology Alliance 

61. Microsoft Corporation

62. National Academy Foundation 

63. National Council for Prescription Drug Programs 

64. National Electrical Manufacturers Association 

65. National Fire Protection Association 

66. National Geospatial-Intelligence Agency

67. National Institute of Standards and Technology (NIST) Sealants Consortium

68. Newborn Coalition

69. North American Energy Standards Board (NAESB)

70. Open Geospatial Consortium

71. Open Secure Energy Control Systems, LLC

72. Organization for the Advancement of Structured Information Standards (OASIS)

73. Porterfield, Donivan R. 

74. Purcell, Donald E., The Catholic University of America

75. Qualcomm Incorporated

76. SAE International 

77. SAP AG

78. Schneider Electric

79. Society of Cable and Telecommunications Engineers 

80. St. Luke's Episcopal Health System

81. Stanley Security Solutions, Inc.

82. Supply Chain Risk Management CS1 Ad Hoc Working Group

83. TechAmerica

84. Telecommunications Industry Association 

85. The Artisan School Center

86. Trusted Computing Group (TCG)

87. Turner, Jim

88. U.S. Pharmacopeia 

89. Underwriters Laboratories, Inc. 

90. Updegrove, Andrew, Gesmer Updegrove LLP

91. Villanova, Villanova

92. X-Y Public Mapping Project