Each sector should have been addressed in an analysis. The burden is on NIST to demonstrate how this proposal would impact small businesses in each industry sector. Advocacy will address a few of these industries. No factual basis has been provided regarding the costs or impact of this rule on the registrars. NIST has proposed QAS accreditation for registrars, similar to that used for final inspection certification.
Accreditation is usually a complex, timely and costly process for laboratories and registrar firms.
While the industry generally agrees that coordinated, streamlined accreditation is valuable for serving the domestic and international marketplace, the industry must have early and detailed information about the process and the costs. However, in this rulemaking, NIST must analyze the impact on small businesses in the registrar industry. The May 1998 deadline does not provide time for registrars to meet capacity. The expense of accreditation is a serious matter for a registrar which may invest large amounts of time and money for expertise development, administrative oversight and scientific or engineering personnel. However, this investment will be made by all of the potential registrars if the market is developed in a steady, thoughtful manner.