Best Practice Recommendations for Submitting Comments on Draft Standards

Best Practice Recommendations for Submitting Comments on Draft Standards

By Karen Reczek, Social Scientist within the Standards Coordination Office (SCO) at the National Institute of Standards & Technology

Almost every standards developing organization (SDO) provides an opportunity for anyone who has a material interest in the standard to comment. This commenting process can occur numerous times in the development of the standard, including during ballot within the hierarchical levels of an SDO and again at a public comment period.  SDOs all use different names to delineate the groups that draft and vote on standards, e.g., Subcommittee, and Main Committee or Working Group and the Committee, or a Task Group and Consensus bodies.

Reviewing Draft Standards

All reviewers notice different things. Certain content is more important to some reviewers than others. These are some of the advantages to obtaining comments from a diverse group of stakeholders. Some of the disadvantages can include reviewers commenting on specific technical areas when they lack expertise in the subject and some reviewers who want every document to be written in the writing style they prefer.

What should you look for when reviewing standards?

    • Title/Scope: Does the title and scope match the text of the standard?
    • Terminology: How words are defined is critical to the use of a standard. Terms clarify the use of words in the context of the document. Are the terms clearly defined? Are there terms that should be defined that are not? If so, a recommended definition should be included.
    • The use of “Should” vs. “Shall”:  These words are important to consider when commenting. Users of the standard will be expected to adhere to all Shalls. You should consider whether something is a “requirement” or not.
    • Clarity and specificity of the document: Is the meaning of the text clear and concise? Are there important steps in a process or procedure that seemed to be missing?
    • International differences: When reviewing international standards, text may not be applicable to all countries due to difference in jurisdictional practices. Some of these sections may need to be more general so that all countries can follow the standard.
    • Use of proprietary terms and/or requiring specific products/equipment to be used: Most SDOs frown upon this type of specificity but sometimes the authors may not be aware. SDOs generally have policies on use of copyrights, trademarks and patents.
    • Grammar, typos, misspellings, and figure errors:  While minor, commenting on these types of observations can improve the quality of the standard.

How to Comment

Submitting comments on standards is an integral part of the development process and use of a Commenting Template is one way to ensure effective participation in that process. [3] Most SDOs require the use of a template to submit comments. Some SDOs do not, but it is always good practice to use a template. When the template is used correctly, all comments submitted can be collated and appear in the same order as the document and will aid the group in reviewing all comments submitted on the same section, at the same time.

This template usually takes the form of a “table.”  Header information is also useful, that spells out the number/title of the proposed standard, the ballot number, if applicable, and the name/organization submitting comments.

The table itself should include:

    1. An indication of the page and clause/section related to the comment. This makes it easier for the reviewer to identify the specific text/section for the comment.
    2. The type of comment. ISO and IEC offer the following categories that can be used.
      • General (G) these comments normally address larger areas of the document being reviewed. They include paragraphs or sections so confusing that pointing out a specific sentence or issue is virtually impossible. General comments overlap technical problems in many cases.
      • Technical (T) technical comments are comments that affect the technical accuracy of the document.
      • Editorial (E) editorial comments, as an example, identify typographical errors, misspellings, or improper sentence structure and similar problems, to mention a few.
    3. The current text in the standard. Again, this is so it is clear to the reviewer what text the commenter is addressing.
    4. The proposed text that the commenter is suggesting replace the current text. This could include “deletions” and “insertions” as well as edits.
    5. The reason why the commenter is suggesting the change.
    6. Resolution/Observations. Most tables include a place for the reviewer to note the disposition of the comment.

An example of the ISO/IEC Commenting template [4] is below:

Image of a comment table used by ISO

How to Write Comments

Best practice is to provide “suggested text” and a rationale. Some SDOs do not allow comments that say “revise text” or “text not clear” without suggested replacement text. Your comment will be more likely to be considered if you provide a suggested revision or if it’s a missing term, as stated above, provide a suggested definition. The proposed change should be clear and actionable and address the issue raised in the comment. It is possible that comments without a proposed change will not be acted on. [1]

Do not be condescending or “snarky.” No one wants to feel attacked. Make sure the tone of your comment is professional and focuses on “facts” and do not make it personal.

Make sure when you note the “type” of comment, you code those that aren’t as critical as “editorial” and try to reserve your important comments that you feel strongly about, as “technical.”

What Happens to Your Comments?

SDOs require that any comments received during the comment period shall be considered. Resolution of comments is also required. Resolution includes noting whether the comment is persuasive (requiring a modification and reballoting of the standard); non persuasive (rejection); editorial changes, or not relevant.

Another best practice if you are the reviewer of the submitted comments, is to reach out to the Commenter to discuss and understand their comment, especially anything that is not clear to you as the reviewer. This can be done via phone or email and goes a long way to making the commenter feel “heard” even if the group ultimately does not accept the comment. At minimum, there should be a written record of how the comment was ultimately resolved by the group.

There is no greater satisfaction than having your comment considered and found persuasive that the language is changed. This does not always happen and shouldn’t discourage you from continuing to comment. This is all part of the standards development process. Win some, lose some. Take comfort in the fact that you took the time to review and submit thoughtful comments to improve the standard. Sometimes doing the right thing is satisfaction enough.

[1] How to Write Standards: Tips for Standards Writers, 2016

[2] Form and Style for ASTM Standards, October 2018

[3] ISOT Guidance Note 2017-03 – Comments and the ISO Commenting Template, ANSI ISO Team (ISOT)

[4] ISO/IEC Commenting Template, Template for comments and secretariat observations

Ready to comment?

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