Avoiding Redundancy and Duplication of Effort in Standards Development
The World Trade Organization’s Technical Barriers to Trade guidelines for the development of international standards are addressed frequently in this column, and for good reason. They are at the foundation of ASTM International’s procedures. They are policy. There is one, however, that I have never addressed here: coherence. Let’s take a look at it. The WTO/TBT Committee has set it down as follows:
“In order to avoid the development of conflicting international standards, it is important that international standardizing bodies avoid duplication of, or overlap with, the work of other international standardizing bodies. In this respect, cooperation and coordination with other relevant international bodies is essential.”1
Coherence is the avoidance of redundancy and duplication of effort within the standardization community. It is the practice of not starting a standards activity when one already exists; it is the practice of not replicating a viable standard. Replications create confusion and conflict in the marketplace. There are two kinds of replicated standards: those that are replicated exactly but bear another developer’s label, and those that differ only slightly from the original, but enough to warrant multiple manufacturing and conformity assessment procedures.
Both kinds encourage diversity in regulatory requirements and place costly burdens on exporters. Manufacturers who have to contend with diverging standards or standards labels — and the technical regulations based on them — are in an unenviable position. They must either forego markets altogether or, in worst case scenarios, re-tool, re-manufacture, re-test, re-label, re-package, and re-warehouse different sets of the same product.
Everyone will agree in principle that this is wasteful and degrades a liberalized marketplace, yet it happens all the time. We ought to know. ASTM International activities and ASTM standards are duplicated time and again.
Why? Duplicating an ASTM standard saves time. It also assures the developer that the “second” standard will not be a “second rate” standard, providing it retains its essential elements. It will still possess the ASTM assets of quality and consumer preference while carrying the second developer’s label. Besides being a questionable ethical practice, it’s an unwise business practice. It teaches the user and the regulator to buy a label and not a standard. It also sends the unconscionable message that it is somehow permissible to replicate the efforts of technical experts who got there first.
ASTM International requires that new technical committees consider the existence of ongoing activities before they can proceed. For example, ASTM technical experts who wanted to develop a standard to address glass fireplace incidents were directed to another developer, where a standard was already in progress. In another case, an ASTM technical committee was in the process of developing a standard specification for dedicated short-range communication, the technology used for electronic toll collections, when the committee realized that they needed to rely heavily on technology that was already within the content of an existing standard. Rather than duplicating large portions of the existing standard, ASTM transferred its activity to the original developer.
ASTM International standards also make normative reference to more than 1,000 existing standards. ASTM test methods for oxidation stability, sodium and potassium and methanol content, for example, reference standards developed elsewhere. This is what adhering to the principle of coherence means — making reference to existing standards, not duplicating them, not re-labeling them, not forming new committees where ones already exist.
The marketing power of labels is considerable. Granted, the ASTM International label is one of the most powerful in the world, and we’re proud of it, because it is more than a logo, more than a supposition. It has to be. As powerful as it is in the marketplace, the ASTM International label is granted no official imprimatur by a trade agreement or government policy. Our users must choose the standard on its own merits.
Those who re-label and use re-labeled standards rationalize this practice by claiming that one label is more politically astute than another, failing to recognize that it is the label they are promoting, not the standard, not its cutting edge technology, or its original developer’s ability to have the experts who created it also revise it rapidly and competently. This only reinforces the idea that one can — and should — predetermine the suitability of a standard without due consideration of the content.
Besides the disservice to the user, re-labeled and duplicated standards create unnecessary barriers to trade. That is why coherence is one of the WTO principles to follow when developing international standards. To ignore it is to ignore the principle that makes standardization — and its developers — credible.
James A. Thomas