DIS29500: BRM Process Unfair for SMEs?


The Issue

The fact that ECMA dispositions on National Body comments are only being made available through a password protected website has been widely reported (one example of many). The BRM convenor notes that this is due to the confidential nature of National Body comments (scroll down to the heading ECMA secrecy). While I had been aware of this before it has only occurred to me this week (while preparing for an informal working group meeting on DIS29500 arranged by Standards Australia – I am an OSIA representative) how difficult this makes it for small organisations to participate sensibly.

The reason is that, during the first phase leading up to the vote, it was easy to leverage off those parts of the specification that other people had commented on publicly. This, in effect, meant that everyone could take the benefit of everyone else’s work. Small organisations could therefore identify relevant issues from those identified by others. Not only did it allow taking the benefit of others’ work it also permitted the incremental improvement of it.

BRM Process Makes Review Much Harder

The BRM process radically changes that dynamic. Now the documents are confidential and, if they are confidential it is hard to comment on them publicly. As such each organisation which is pariticipating in a National Body consultation process is on its own.  With each prevented from interacting with others – collaboration is, in effect, banned. Each is left to trawl through the large number of dispositions to try to make what sense it can out of them. Without seeing other people’s views on the various dispositions it is very difficult to know which are significant and why (and which are insignificant and why not) – or even which dispositions relate to important issues identified in the lead up to the initial vote. The comparatively short time between the availability of the dispositions and the BRM (about 6 weeks or so) compounds this difficulty.

Of course, this gets back to the size of the document. A document one tenth of the size would probably be manageable under this process – even by a small organisation although it wouldn’t necessarily be pleasant. DIS29500 simply inspires despair. Presumably National Bodies will also be in a similar situation. Unless they have a substantial team that they can devote to the process how can they hope to adequately parse the dispositions – and any regressions that they create?

Is this Process Unfair to SMEs?

This creates the additional complication of whether a National Body, if it is required to take into account the interests of small and medium businesses and/or consumers, can reasonably fulfill that obligation under this process (for example, in Australia, the Productivity Commission’s November 2006 Research Report on Standard Setting and Laboratory Accreditation recommended that Standards Australia should “improve the balance of interests represented on technical committees by… increasing the participation of small business,…and other community interests“). If SMEs cannot parse the disposition in the time available, they cannot adequately understand its consequences and cannot therefore adequately represent their own interests to their National Body.

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