Five Myths About MilSpec Reinstatement
Setting the Record Straight
Recently there has been discussion both in U.S. Department of Defense circles and in industry about the reinstatement of Military Specifications and standards that were canceled during the MilSpec reform that began in the 1990s. As often happens, the truth embodied in the discussion has become distorted and exaggerated. I’ve even heard it suggested or implied that DOD will be bringing back hundreds of canceled documents, replacing hundreds of adopted nongovernment standards with Mil Standards, and will stop working with nongovernment standards organizations and participating on committees. I’d like to address a few of these myths and to try to set the record straight.
1. The DOD is about to reinstate a bunch of MilSpecs to replace nongovernment standards adopted during acquisition reform.
This myth stems from a decision last year by the Defense Standardization Council (a senior level group chaired by the deputy assistant secretary of defense for systems engineering with senior representatives from the military departments and several defense agencies) to assess whether the DOD requirements in key systems engineering disciplines — such as quality, reliability, maintainability, configuration management, manufacturing, logistics and a few others — were being adequately addressed at an enterprise level. There are several working groups now assessing the details of this, and one possible outcome may be the reinstatement (with significant updates) of a few military standards. In some cases, it may result in a decision to replace an adopted nongovernment standard with a government standard, but if that happens at all, it will likely be the reinstatement of less than a dozen government standards. And, of course, another likely outcome may be adopting existing, revised or new nongovernment standards.
The truth is the Department of Defense relies heavily on standards and specifications developed by the private sector. Nearly one-third of the documents listed in the ASSIST Database (the official repository of DOD specifications and standards) are nongovernment standards. Over 75 percent of the standards listed in the DOD Information-Technology Standards Registry, which are mandated for use in DOD to ensure the interoperability of information-technology systems, are nongovernment standards. Nongovernment standards are cited by the thousands in our technical data packages, cataloging information, contracts, technical manuals, policy documents and elsewhere. The idea that the DOD might reinstate a significant number of MilSpecs to replace nongovernment standards currently in use would not make good technical, economic or practical sense.
2. The nongovernment standards adopted by DOD are inadequate and unusable.
The overwhelming majority of nongovernment standards have satisfied DOD requirements for many decades. If there are inadequacies, the usual remedy is to ask the nongovernment standards technical committee to make changes to the standard, which they are generally willing to do. In some cases, the inadequacy of a nongovernment standard may have been the result of the philosophy adopted by the DOD during MilSpec reform in the mid- to late-1990s that requirements should be stated in such a way as to allow contractors broad latitude to meet those requirements. In some cases, requirements were written more as guidance than as a requirement that could be placed on contract. While our preference and our policy remains one of stating requirements in performance terms to the greatest extent practical, as we have gained more experience with writing performance requirements, it may be necessary to revisit some of those requirements and rewrite them to ensure satisfactory results.
3. The DOD is retreating from the National Technology Transfer and Advancement Act and OMB Circular A-119 on using voluntary standards.
The DOD continues to be the leader in the federal government in the use of nongovernment standards. (We prefer the term “nongovernment standard” to “voluntary standard,” but we are referring to essentially the same thing.) In its August 2010 report on federal agency use of nongovernment standards, the National Institute of Standards and Technology indicated that in fiscal year 2009, the DOD replaced 112 government specifications and standards with nongovernment standards, which led all federal agencies. We remain firmly committed to the principles of these federal government-wide policies and we demonstrate it in our daily practices.
4. The process for reinstating canceled MilSpecs and MilStds is undefined.
The process for reinstating canceled MilSpecs and MilStds is clearly defined in DOD 4120.24-M, Defense Standardization Program Policies and Procedures. Simply stated:
- A canceled MilSpec can be reinstated by a DOD preparing activity with approval from the lead standardization activity and if there are no “essential” comments received during coordination. Note that we differentiate between specs (which generally describe products and processes) and standards (which generally describe engineering disciplines).
- A canceled MilStd can be reinstated by a DOD preparing activity with approval from the lead standardization activity and if there are no “essential” comments received during coordination, and the cognizant standardization executive for the preparing activity concurs.
- If the DSC made a joint decision about canceling a document, then the DSC must approve reinstatement. A list of these very few documents is available at www.dsp.dla.mil/APP_UIL/content/documents/MilStds_Requiring_DSC_Approval.pdf.
Reinstatement of a canceled MilSpec or MilStd is a rigorous process, but that’s a good thing.
5. It’s cheaper to develop and maintain a MilSpec and, once completed, MilSpecs are free.
The development of technical documentation of almost any sort is a time consuming, exacting process requiring research, validation of findings, coordination with peers, careful composition and so on. This is true whether the document being produced is a military document or a nongovernment standard. MilStds are not free. The subject matter experts devoting time to research, validation, coordination and composition do not work for free.
The Department of Defense, and the American taxpayer, are fortunate to have some of the world’s brightest scientists, engineers and other technical experts working for us. When they spend their time to develop the technical requirements that eventually become part of a MilStd, it may be transparent because they already work for us. But it is definitely not free. Similarly, the time spent by peers to review, comment on and develop consensus on these technical documents adds up to many hours of work. The infrastructure needed to maintain records and configuration control, provide the database, and oversee the policies and procedures costs money.
It is a principle of technical work developed by public employees that the public has paid for the work, therefore the resultant material should be made available without additional charge. This is not the same as saying it is free — it is just provided to the public without charging again. Yes, we pay for nongovernment standards, but we also pay for MilSpecs. There is no free lunch.
Gregory E. Saunders is the director of the Defense Standardization Program Office, Fort Belvoir, Va. The 2007 chairman of the ASTM board of directors, Saunders is a member of ASTM Committee F07 on Aerospace and Aircraft.
Reprinted with permission from the July/September 2011 issue of the Defense Standardization Program Journal, Defense Standardization Program Office, Fort Belvoir, Va.