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MilSpec Reform: Completed

An Interview with Gregory E. Saunders
Defense Standardization Program Office

When and why was MilSpec Reform implemented?

MilSpec reform was formally kicked off with a five-page memo signed by the Secretary of Defense on June 29, 1994. Secretary Perry saw that there was a great opportunity for more efficient use of the national industrial base if the Defense Department could wean itself from describing its needs in detailed, prescriptive design and move toward stating requirements in performance terms. His mandate to reform the military specification system established clear direction to move to performance specifications, and he backed up that direction with “teeth” in the form of a waiver requirement for use of other-than-performance-based specifications.

What were the objectives for the Reform action?

There were three primary objectives. The first was to eliminate non-value added, military-unique requirements and procedures; the second objective was to take advantage of commercial technology and process advancements; and the third objective was to facilitate defense firms’ diversification into commercial markets. It was apparent that we could no longer support a large segment of our industrial base that was responsive only to the DoD, and dependent on Defense dollars for survival. We had to fulfill more of our needs from the commercial base.

A significant way to move in that direction was to stop telling our contractors how to do things, but rather to state the desired results and let innovative, efficient corporate America devise the best ways to achieve the results. Our movement to performance based requirements and contracting grew out of these objectives.

The fourth and unwritten objective was to save money. Dr. Perry believed strongly that by achieving the primary objectives we would simultaneously save the department millions of acquisition dollars. He said that we should measure all actions contemplated in the name of MilSpec reform against these objectives as well as seeing if it saved money. If an action clearly suboptimized one of these, or was more costly on a life-cycle basis, then it was extremely suspect for implementation.

To what degree were the objectives achieved?

We translated Dr. Perry’s broad objectives into three goals for MilSpec Reform. The three goals were to establish a performance based procurement system; “fix” our library of documents; and create irreversible cultural change. Measuring results in even simple reforms is a difficult and inexact exercise, at best. In this case, we implemented many MilSpec reform initiatives at the same time that we were implementing dozens of other acquisition reform initiatives, and other factors such as base closings, a general economic boom, an explosion in technology, and shifting procurement budgets and priorities were also having major influence on the objectives we were trying to achieve.

We will probably never know just what impact MilSpec reform had on shifting to greater reliance on the commercial market or the broader national industrial base, but it is clear that there has been a major shift in that direction. It is also clear, however, that corporate consolidations and reduced procurement budgets have led to an industrial base that looks much different today than the one we were trying to influence at the beginning of MilSpec reform.

We do know that we achieved a great movement away from prescriptive specifications to performance specifications and a performance based procurement system, but we do not have a good measure for whether the impact of that has been good or bad. We do know that we have eliminated thousands of outdated documents, shifted thousands of MilSpecs out of our inventory and to the private sector, and technically improved many MilSpecs and standards. And there is little doubt that the culture has been altered so that we use far fewer standards overall, and we look first to voluntary standards where standards are needed. MilSpec reform clearly achieved its small- “g” goals—but it is unclear what overall impact that had on defense acquisition.

Were there any good and bad “surprises” in the Reform activities?

Oh sure—actually quite a few. One of the big surprises was learning just how dependent both U.S. industry and foreign industry was on our library of military specifications and standards. As we began canceling documents that were outdated and shifting documents from DoD control to private industry control we were besieged with letters and phone calls decrying these moves. Many seemed to think that the DoD had a responsibility to maintain documents, even though we no longer used them, in order to support private industry that depended on them. While we were sensitive to the disorder that some of our actions caused, our mission had been clearly defined—we were here to support Defense acquisition.

Further, as the resources to support our MilSpecs disappeared, we concluded that it was far better to eliminate documents that we could not maintain than it was to leave them in place without maintenance. The former sent users in search of replacements, but the latter had the danger of allowing users to unknowingly rely on obsolete documents and obsolete technology.

A second surprise came when we clarified our language in cancellation notices regarding superseding documents. In the past, it was DoD policy to point users to superseding documents by stating that ‘users should refer to such-and-such a document,’ but we did not mandate the use of superseding documents. However, since some users inferred that this was mandatory supersession, we changed our language to clarify that the choice of a superseding document was the responsibility of the user and that any replacement document cited on the cancellation notice was information only and users would have to evaluate the replacement document in the context of their application. This clarification caused a major ripple, especially in the aerospace industry. There was a strong wish by some industry sectors for the DoD to mandate a superseding document, thus reducing their risk and responsibility.

Third, as we cancelled or turned over to the private sector thousands of military specifications (in DoD, a specification describes a product, a standard describes a process, engineering practice, or discipline), many in industry told us that they did not want performance specifications at the piece part level; they did not want design freedom for parts because of the potential damage to logistic supportability. We heard many times that we would have gotten most of the benefit of MilSpec reform if we had stopped with reform of just a few dozen standards.

Fourth, as we moved away from giving very precise guidance on how to do things such as configuration management or soldering, some in industry didn’t quite know how to react and so they continued to use the military methods. Worse, many in DoD did not know how to evaluate alternative processes and methods. We’re getting better at this, but with complex acquistions it is still a very complicated issue.

How was Reform received by DoD’s internal engineering staff, prime contractors, and subcontractors?

To begin with, change is never easy or comfortable. Our engineering community felt secure in developing and using MilSpecs. They knew they worked. To shift from detailed MilSpecs to performance specifications meant risking that a product might not meet your requirement because you overlooked some important detail. For example, requiring that a product be made from a specific material is simple and you know that it works. But it also limits the possibilities and does not allow the contractor to use alternative materials that may work as well or better and at less cost. The downside from the government engineer’s perspective is that if you don’t require a specific material, you have to specify a multitude of performance requirements, such as strength, flexibility, corrosion resistance, flammability, and many other factors. There could well be characteristics inherent in a specific material that, if you fail to require in a performance spec, will allow a choice of material that could result in failure.

Segments of our engineering community also did not feel comfortable in converting MilSpecs to voluntary standards because of the fear of not having final control over the requirements. Of course, in reality, we still have control—if a voluntary standard, MilSpec, or any other technical document does not meet our requirements, we either will not use it or we will modify it in the contract. While I doubt if MilSpec Reform was ever warmly embraced by our engineering community, I think to a large extent, it was accepted as necessary since there were clearly not enough resources to maintain the technical currency of all of the detailed military specifications and standards.

On the industry side, the reaction was definitely mixed. For those companies whose business was entirely or largely defense, their engineers felt very comfortable with the familiar MilSpecs. Initially, they did not feel comfortable with our new direction. Some still do not feel comfortable. But others have either adapted or embraced the new design freedom they have. On the other hand, for those companies who dealt little or not at all with the DoD, MilSpec Reform opened up all kinds of possibilities and allowed us to expand our supply base further into the commercial sector.

Will DoD now resume the in-house development of its MilStds/Specs?

To paraphrase Mark Twain, the rumors of the Defense Department getting out of the specs and standards business have been greatly exaggerated. We never stopped writing and maintaining the documents necessary for Defense needs. Secretary Perry made it very clear in the press conference where he first launched MilSpec reform, there will continue to be circumstances where MilSpecs need to be written and maintained.

It is a fact of life that the military places unique stresses on products, must be capable of operating in unique battle environments, and must achieve unprecedented levels of mission reliability and readiness. That means that sometimes we will have to write specifications to describe products that exceed the normal demands of the private sector. We will sometimes stretch performance to the very edge of what is possible. We will demand some degree of standardization that may not be profitable, but which is necessary to ensure interservice and coalition interoperability.

So, yes, we will continue to write some specs and standards—but only where they address truly military- unique requirements, and to the largest extent possible, we will write these documents in performance terms. As we continue to lose the resources we need to maintain this kind of technical support, we will continue to increase our reliance on the private sector and especially on the private sector standards development community where we can share and leverage our resources and technical expertise.

Will there be any change in how they will be developed now as opposed to before the Reform?

A few changes: New documents will be justified by a verified need to develop military (as opposed to voluntary) standards before we start. They will be much more nearly performance based from the beginning. We will continue to try to meet our standardization needs through voluntary standards organizations to the greatest extent possible—for all of the reasons mentioned previously.

What role do you now see for non-government standards developing organizations such as ASTM in meeting DoD standards needs?

Bigger! In many areas we have adopted most of the standards that are currently available that can meet our needs. What we see now is the need to develop standards that meet not just DoD needs, but the needs of other government agencies as well as the needs of other industries facing issues of high reliability, harsh environment, and long service life. For example, the Navy worked with an ASTM committee to develop testing standards for mechanically attached pipe fittings in order to take advantage of a lower cost, more efficient process [see the case study on page 20]. But an even bigger challenge for DoD, industry, and for the voluntary standards community is how to do more with less. There are fewer dollars, fewer people with less time, fewer opportunities to travel to meetings. We must find ways to actually increase the production of needed standards while simultaneously reducing the resources and the time needed to produce them.

Does DoD exercise any control or approval over the revisions made by SDOs to MilStds/Specs over which the SDOs now have jurisdiction? If not, what does DoD do when the revision does not meet agency needs?

We exercise the same control that any other participant exercises—participate on the committee, vote on the document, and the option not to use it if it doesn’t meet our needs. We’ve never wanted to be anything other than an equal partner in the standards development process. We shouldn’t be given any special treatment, nor should we be ignored. We are a part of the user community and should not expect any special authority to approve or influence documents simply because they originated under a DoD cover.

To what degree do “international” standards play a role in DoD acquisitions and standards development activities?

Small but increasing—especially in the information technology area. We do most of our international standards work through NATO or other treaty organizations. But as we look to greater and greater use of voluntary standards, and as we find ourselves in an increasingly global marketplace to meet our defense needs, it is increasingly important that the standards we choose to use are recognized and respected globally. In some areas this has meant looking to ISO and IEC for international acceptance. In many other areas we find that both our U.S. military specs and standards, and the standards of the standards developers with whom we participate, are de facto international standards. They enjoy international acceptance and benefit from international participation irrespective of where the originator is domiciled. Almost as with automobiles, the identification of a standard with its country of origin is beginning to lose significance. We are more interested in standards that meet our needs and support the U.S. industrial base than we are in where the SDO of jurisdiction is located.

How many active MilStds/Specs exist now that MilSpec Reform is over?

This seems like such a simple question, but it does not have a simple answer. When we began MilSpec Reform, we had just under 30,000 active military specs and standards. When we completed our MilSpec Reform efforts in January 2001, we had a little over 8,000 detailed military specs and standards, which we intend to retain for now, and about 2,400 military performance specs. But perhaps an even better way to look at the data is to examine the total “pie” of documents used in Defense acquisition [see Figure 1]. Before the beginning of reform, a full two thirds of the documents in regular use were detailed military specs and standards, with about 12% simplified Commercial Item Descriptions and 13% adopted voluntary standards. At the conclusion of reform about one third of the documents in regular use are military, 20% are CIDs, and over a third are voluntary standards. So the pie has gotten smaller, and the proportions of the pie have moved in the directions that we wanted them to move.

What is DoD policy on encouraging and supporting its military and civilian personnel’s participation in non-government SDO’s activities?

The DoD is a leader in both participation with non-government standards developers, and in use of the resulting standards. The first formally issued defense policy was issued nearly 40 years ago and it has been department policy to participate in and use nongovernment SDOs ever since. In the late 1970s, the OMB Circular A-119 was developed at the suggestion of DoD participants in the Interagency Committee on Standards Policy, and it was modeled on the Defense policy. Today, the current administration continues to believe strongly that it is both our responsibility, and to our great benefit, to continue active involvement in all levels of voluntary standards activity and to use the voluntary standards that result from this mutually beneficial activity.

With MILSpec Reform behind you, what are some future directions for the Defense Standardization Program?

Given that future U.S. defense budgets will continue to be constrained and that we will increasingly need to work with allies, it is essential that we focus on developing standards that will allow U.S. forces to be interoperable with each other and with our allies. There is growing emphasis on establishing standardization agreements with our treaty organization allies to make such interoperability possible. Sometimes these agreements are full-fledged standards, but often times, they are simply agreements to use an existing voluntary standard. For example, the NATO fuel standardization agreement identifies ASTM D 3699 as one of the acceptable standards for kerosene.

But the world is becoming an increasingly complex place. In the past, when the primary threat was the Soviet Union, we only had to worry about being interoperable with a limited number of stable allies. But given the turmoil in the world today, we are facing situations of revolving coalitions of allies, which makes interoperability of equipment more difficult. One way we can mitigate this difficulty is through standards that have global use. While we may have different motivations than those of our colleagues in industry, we are very much in tune with the mantra of “one standard, one test, worldwide.”

Another major area of focus is our effort to reduce our logistics footprint. By that, I mean reduce the mountains of supplies and parts that our forces bring with them to conduct and sustain a military operation. We hope to achieve this goal by improving our logistics support information systems and by doing a better job of standardizing spare parts, components, and equipment. One of the reasons we take mountains of supplies is because our current logistics support system largely uses isolated, independent, and sometimes incompatible systems, processes, and data. Our field commanders don’t have confidence that the supplies they need halfway around the world will be delivered in time.

What we are trying to do is develop an automated, collaborative logistics support information system that will give field commanders an unprecedented capability to order, monitor, and if necessary, redirect supplies in a timely and efficient way. Getting the same information to all of the different manufacturers, vendors, transporters, and military units is a complex problem and one that will demand standards to ensure we are all working toward the same solution.

The other issue of reducing the variety of parts we use across weapon systems involves having true industry-wide standards and doing a better job of applying those standards. Right now, we have a situation where either there are multiple, incompatible standards or a company chooses to use nonstandard parts. In either case, we end up having to take countless varieties of spare parts with us to a combat area because of this lack of standardization. In the past, we have always allowed our program offices and contractors to make their own decisions about using standards. While we have no intention of taking away this flexibility, we are in the midst of developing an automated “roadmap,” which will provide government and contractor engineers with guidance on preferred, and in some cases, mandatory standards. It is our hope that with information readily available about the effect on logistics support, weapon system designers will make “smarter” decisions when it comes to applying standards.

Another relatively new standards thrust for the DoD is consortia standards. Traditionally, we have limited our non-government standards participation to formal consensus standards organizations. But because of the critical need to develop and incorporate new technology into our weapon systems as quickly as possible, we have become involved in consortia standards organizations. We aren’t driving these consortia standards organizations, but when we see industry sectors heading in that direction, we are joining them, and in some cases, sponsoring the necessary research and standards.

A final future direction for us is in the area of knowledge management for standards and standardization. A few years ago, we made a major leap forward when we began making our government specifications and standards available over the Internet. But ultimately, we are looking to have a one-stop, online standards information portal where, once you enter, you never have to leave to get the information you need. Such a portal would include:

• Online access for all government specifications and standards;
• Access for DoD employees to voluntary consensus standards and consortia standards;
• Application data to determine where and how standards are being used;
• Links to all statutory and regulatory requirements for standards;
• Access to the responsible individuals or organizations that can answer questions or address problems concerning specific standards;
• Online coordination of government specifications and standards;
• Hyperlinks to standards referenced in solicitations, contracts, technical manuals, drawings, policy documents, and any place else.

Obviously, such a portal is an ambitious undertaking and not one likely to be accomplished all at once or in the near term. But we consider such a knowledge management system to be essential and every year we will be a few steps closer to achieving this goal. //

Copyright 2001, ASTM

See the Defense Standardization Program Office Web Site.

Gregory E. Saunders is director of the Defense Standardization Program Office (DSPO) at the U.S. Department of Defense in Fort Belvoir, Va. He is responsible for all facets of implementing MILSpec Reform and for policies and procedures of defense standardization including the development and use of Qualified Manufacturers Lists, the use of industry standards, development of performance specifications, and Commercial Item Descriptions. He is vice chair of the Defense Standardization Council.

A member of the ASTM Board of Directors, Saunders served on the ASTM Committee on Technical Committee Operations (COTCO) from 1988 to 1990, and he served as chairman of the former Committee F10 on Food. He has also been active on Committees F15 on Consumer Products and F26 on Food Service Equipment.

Saunders has served on the Technical Standards Board and the Aerospace Council of the Society of Automotive Engineers, as a director on the ANSI Board, and he has chaired the ANSI Government Member Council and the Standards and Data Services Committee.