The critical facilities industry relies on industry standards to establish the minimum requirements necessary to design, build, and operate critical sites. Some of these standards get adopted by federal, state, and local governments through legislation as enforceable codes. So where do these standards come from, how do they get developed, and how are they maintained? Naturally, you first need a standard for developing and maintaining standards. This is the job of the American National Standards Institute, or ANSI.

ANSI has been around for quite some time. It was founded in 1918 by five engineering societies and three government agencies. Since then, it has expanded to now represent the interests of its membership of over 1,200 companies, organizations, institutes, agencies, etc. Per ANSI’s website, as of January 2018 there were 237 accredited standards development organizations (SDOs) and more than 11,500 American National Standards (ANS) with 90% produced by the 20 largest SDOs. These standards can relate to products, processes, services, systems, or even personnel.

Surprising to many people, ANSI does not develop standards. Instead, ANSI facilitates the development of standards by accrediting the processes used by organizations to develop formal standards, as related to their respective purviews and community needs. Once accredited by ANSI, these organizations become SDOs. The role of ANSI is to ensure standards are developed and maintained in an open and objective manner that “ensures that all interested and affected parties have an opportunity to participate in a standard’s development,” and that the development process be open, balanced, based on consensus, and follow due process. ANSI is to standards development what the referee or umpire is to sports; an unbiased, objective observer and keeper of the rules, who just wants to ensure a fair game.

ANSI is not a government agency. It is a private 501(c)3, nonprofit membership organization supported by both private and public organizations. Their mission is “to enhance both the global competitiveness of U.S. business and the U.S. quality of life by promoting and facilitating voluntary consensus standards and conformity assessment systems, and safeguarding their integrity.

ANSI officially represents the U.S. to the International Organization for Standardization (ISO) and (through the U.S. National Committee) the International Electrotechnical Commission (IEC). And of course, ANSI is a member of the International Accreditation Forum (IAF).

 

ANSI and American National Standards

The core tenant of the ANSI accreditation process is that prospective SDOs must comply with what is called the “ANSI Essential Requirements.” These requirements ensure American National Standards (ANS) are developed in a fair, transparent, and consensus-based process that is open to public scrutiny. The ANSI Essential Requirements are defined and described in a 27-page document last updated in January 2019 (at least as of the writing of this article also in January 2019). In short, these requirements include:

  • Openness (to all affected by the activity in question)

  • Lack of dominance (by any single “interest category, individual or organization”)

  • Balance (by seeking participation from diverse interests)

  • Coordination and harmonization (by avoiding and resolving conflicts between existing and proposed standards)

  • Notification of standards development (by public notifications of standards development activities)

  • Consideration of views and objections (meaning a good faith effort to address and resolve any objections or comments received from participants including public reviews)

  • Consensus vote (meaning formal, documented vote tallies)

  • Appeals (as in a formal process for the impartial handling of procedural appeals including whether a technical issue was afforded due process)

  • Written procedures (that describe the SDO’s standard development process, and made publicly available)

  • Compliance (with ANSI policies and administrative procedures)

Additional information regarding the ANSI Essential Requirements can be found at http://www.ansi.org/essentialrequirements.

My personal experience with SDOs and the development of standards is limited to my participation with the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE). Regardless, it is safe to assume other SDOs follow similar processes in order to be accredited by ANSI.

 

ASHRAE and critical facility related standards

ASHRAE has many committees and sub-committees including Technical Committees (TCs), Guideline Project Committees (GPCs), Standard Project Committees (SPCs), and Standing Standard Project Committees (SSPCs). Only the SPCs and SSPCs develop and maintain standards but often they include committee members who also work on relevant TCs and GPCs. It is common for related committees to include formal liaisons tasked with coordinating communications and collaboration between the respective TCs, GPCs, and other interested standard committees. These liaisons can extend beyond ASHRAE to include other industry and professional organizations such as IEEE, NFPA, ASME, etc. Some ASHRAE committees that relate to the critical facilities industry include:

  • TC-9.9 Mission Critical Facilities, Data Centers, Technology Spaces and Electronic Equipment

  • TC-7.9 Building Commissioning

  • Guideline 0-2013 The Commissioning Process

  • Guideline 1.1-2007 HVAC&R Technical Requirements for the Commissioning Process

  • Proposed guideline (GPC) 1.2 The Commissioning Process for Existing HVAC&R Systems

  • Proposed guideline (GPC) 1.6 Data Center Commissioning

  • SSPC-300 standard 202 Commissioning Process for Buildings and Systems

  • SPC-127 Method of Testing for Rating Air Conditioning Units Serving Data Center (DC) & Other Information Technology Equipment (ITE) Spaces

  • SSPC-90.1 Energy Standard for Buildings Except Low-Rise Residential Buildings

  • SSPC-90.4 Energy Standard for Data Centers

When a standard has been drafted by an SPC, it must be submitted to ASHRAE for approval to be released for public review and comment. There are three types of public reviews:

Advisory Public Review (APR)

  • All comments considered supportive and therefore no responses required
  • Must subsequently go out for a Publication Public Review (PPR)

Publication Public Review

  • Committee must respond to each comment unless decision is to submit a revised draft for another full PPR

  • Responses to each comment must be either:

  1. Accepted (as submitted; w/minor change; or “in principle”)
  2. Rejected (except as noted; or rejected outright)
  3. Deferred (out-of-scope; or submitted after the formal due date)

Independent Substantive Change (ISC) Public Review

  • SPC submits a revised draft that clearly indicates all substantive changes and conducts a limited PPR

  1. Only comments addressing an ISC change require a response. Comments regarding the unchanged aspects do not have to be addressed or responded to.

The standard approval process starts when the SPC submits the final version of the standard (following the public reviews) to the ASHRAE Standards Committee (which helps SPCs manage the standard development process in compliance with ANSI requirements). If everything is in order, the ASHRAE Standards Committee forwards the proposed standard to the ASHRAE Board of Directors (BOD) for approval and publication. If approved by the BOD, you now have an ASHRAE standard, but we are not done yet. ASHRAE next submits the standard to ANSI for review and approval including assurances the standard was developed in accordance with ANSI requirements. Assuming ANSI approves the standard, you now have an American National Standard (ANS). For building standards, there is an additional step where the standard is submitted to the International Code Council (ICC) for approval and adoption.

Using the development of ASHRAE standard 90.4 Energy Standard for Data Centers as an example, the development process took a total of about three years to complete, from the initial approval for establishing the SPC-90.4 committee until gaining ANSI/ASHRAE approval and publication. SPC-90.4 held the first committee meeting on Jan. 4, 2013. The SPC-90.4 committee included members of TC9.9, SPC-127, SSPC 90.1 Mechanical Subcommittee, and recognized data center industry experts. These included representatives from professional engineering firms, vendors, manufacturers, commissioning firms, and owners/endusers, etc. The draft standard was approved for issuance for public reviews beginning in February 2015 with the following results:

  • The initial draft was released for first “publication public review” (PPR) in February 2015 with over 660 comments received

  • A revised draft was released for a second public review in September 2015 with over 170 comments received

  • Another revised draft was released for a third public review in February 2016 with 110 comments received

  • Another revised draft was release for a fourth public review in March 2016 with only 11 comments received

  • After addressing the final 11 comments, SPC-90.4 voted to approve the final draft on June 25, 2016, and forwarded it for final approval which was granted by the ASHRAE BOD on June 30. The final “appeals window” closed in July 2016 without any appeals being filed

  • ASHRAE subsequently submitted Std-90.4 to ANSI and to the ICC for adoption in late 2016.

The work of SPC-90.4 was completed with the approval and publication of standard 90.4. ASHRAE considers standard 90.4 of such importance that is has been placed under what is called “continuous maintenance” and has re-constituted the committee as a Standing Standards Project Committee, or SSPC-90.4. As such, the standard can be updated and revised at any time via addendums with the expectation that it will be republished in its entirety every three years.

So how can you get involved with the development of ASHRAE standards? First, sign-up for ASHRAE’s electronic notification of any formal actions including PPRs for any standard of interest via “Linkserve” on the ASHRAE website at https://www.ashrae.org/resources--publications/free-resources/listserves. Second, participate in the public reviews by submitting comments on proposed standards via ASHRAE’s “Online Comment Database” (OCD). These forms as well as instructions on how to submit can be found at https://www.ashrae.org/standards-research--technology/standards--guidelines/continuous-maintenance

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