FURTHER COMMENTS FROM DR RICHARD AYNSLEY

Thank you for your work in developing the draft recommendations in relation to the Memoranda of Understanding between the Australian Government and Standards Australia, and NATA.

I have concerns that your recommendations are inadequate, namely:

a) There is lack of appreciation of how other trade and professional bodies might be encouraged and used to develop standards for Australia as they are in so many other countries; and 
 
b) The lack of guidance on how Standards Australia can carry out your recommendations in section 8 Assessment; governance and processes.  Without some guidance, to government, as to how Standards Australia can implement your recommendations, Standards Australia will make their own interpretations of how to handle the recommendations and we will not have achieved much at all - after all these concerns have been raised before and have not been adequately addressed.

a) Development of Standards by other Bodies
 
This is a well developed process in other countries.  The developing bodies are usually professional or trade organizations with their unique body of knowledge.  This process overcomes many of the problems you have identified with Standards Australia.  Standards Australia can set the guidelines for development of standards – as does ANSI and ISO – for standard setting bodies to follow.   A long established example of a respected standards developing professional organisation is ASHRAE

Standards Australia restricts its membership of technical committees to people from specific groups not according to expertise.

One should not overlook the economies and timeliness of standards development by other organisations. 

b) Guidance to Standards Australia on how they can and should improve their governance and processes

In my previous submission I cited examples of how other standards organisations selected their members for their standards committees. For example:

i. ISO technical committee comprises experts from member countries, in particular those that enforce the standards.  Selection is not based on market share or product groupings.

ii. ASHRAE selects committee members after consideration of detailed applications from these people, including their expertise in the specific area and their category of employment – user, producer, or researcher/representative of testing authority.   ASHRAE is free to tap several experts within their organisation rather than the limited number in a Standards Australia committee.  Very few experts cover the entire field under development for a standard.  There is often a need to tap several experts for a short period.  

Some established ideas as to how the standards development process  should be managed follow:

•	Standards are developed by experts 
•	Proposed members submit their qualifications in detail, following guidelines. This includes a clear statement of potential conflict of interest, and employment category - producer, user or academic/testing organization representative.  
•	The Committee chair is selected from the membership and changed regularly [every 2 years] according to specific rules.
•	Committee members are divided into voting and non-voting membership.  
•	Voting Committee membership is limited in term [2 years] and is rotated with non-voting members who then become voting members.
•	An independent administrator sits in on meetings to make certain the regulations are observed.  
•	The Chair is expected to remind members of their obligations under the regulations at each meeting.
•	A certain standard of behaviour is expected of the Chair and members, and enforced by the administrator.
•	Members are treated with respect at all times, and consideration given to minimizing member costs by, for example, using electronic communications.
•	Every committee member is given an equal chance to present input at the meetings.
•	Draft standards are submitted to relevant interest groups for feedback on the content of the standard. It is expected that companies, laboratories, consumer groups with an interest in the standard will be consulted and their input taken into account. 
•	At this stage the draft and comments become public documents.  There is an assumption that the work of the committee is rationally based and can be defended and therefore should be made public.
•	Feedback on the draft is reviewed by the committee and any corrections made.  
•	Public reviews of published standards are conducted regularly [4 - 5 years] by independent persons who are normally from the same trade or professional organisation but not part of the original development process.
•	The committee is obliged to give consideration to review submissions and respond with considered remarks.  Submissions cannot be ignored.
•	Standards adopted by a central standards body, such as ANSI or ISO, are subject to their further assessment criteria.
•	Any disputes must be dealt with by an independent panel.

Dr Richard Aynsley
August 18, 2006