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.
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?
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.  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:
An example of the ISO/IEC Commenting template  is below:
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. 
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.”
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.
 ISOT Guidance Note 2017-03 – Comments and the ISO Commenting Template, ANSI ISO Team (ISOT)
 ISO/IEC Commenting Template, Template for comments and secretariat observations
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