NFPA Journal

NFPA Journal®, May/June 2013

By Kathleen Robinson

The days of the ROP and ROC — Report on Proposals and Report on Comments, respectively — are over. Those longtime pillars of the NFPA standards-development process have been replaced by First Draft Reports and Second Draft Reports.

In fact, NFPA’s entire standards-development process has been re-engineered to not only take advantage of online technology, but also to make it easier for the public to participate in the process. It will also make life a little easier for those who use the codes and standards in their daily activities, such as building code officials and enforcers.

Development of the new process began in 2010, when the Standards Council began analyzing existing procedures in hopes of making them more user friendly. In addition, we created a central web portal where all standards-development information and procedures could be located. A little more than two years later, the old process is on its way out and the new process has made its debut. NFPA 1965, Fire Hose Appliances, is the first NFPA standard issued under the revised procedures.

All of these changes have been designed to make it easier for a wider audience to participate in the code-making process, says Amy Cronin, division manager for NFPA’s Codes and Standards Administration. “The new system is all about making the process more efficient, accurate, and easy to follow,” says Cronin. “An easier, more efficient process means better participation, and better participation means better standards. This is an important step for NFPA and for the people who use all of NFPA’s various codes and standards.”

Embrace of the Digital
The new process differs from the old in a number of ways, none more notable than the sudden subtraction of paper from the equation — no more giant ROP and ROC books to lug to the Association Technical Meeting every June. Public input, public comments, and notices of intent to make a motion (NITMAMs) are all submitted, and the First and Second Drafts of the revised standard and other information are published, online. Instead of trying to piece together the hundreds of proposals and comments so you can envision what the final standard would look like, you now have First and Second Drafts that give you a clear view of the way the final document will look.

As it always has, the standards-development process still takes place in two stages, formerly known as the proposal and comment stages and now known as the input and comment stages. The input stage differs from the proposal stage primarily in the way the technical committees respond to the proposed revisions made by the public. Previously, interested parties proposed revisions to a standard and, using forms designed for that purpose, submitted the proposals and the justifications to the appropriate technical committee, which reviewed the proposals and accepted, modified, or rejected them. The committees’ actions on each proposal were then balloted, and the accepted results were published as the ROP, a large paper document containing all the proposed revisions to all the codes and standards up for a vote in that particular revision cycle. The public is still invited to propose revisions, now called public input, but the preferred method is online. The committee meetings are used to craft revisions which are balloted to make up a complete, fully integrated draft of the revised standard, which is posted on nfpa.org as the First Draft.

“You don’t have to imagine what the document would look like, the way you had to do before,” says Michael Wixted, an associate engineer at NFPA. “Now it’s all there in front of you, in a much more streamlined form.”

The second stage of the process was and remains the comment stage. Previously, the public was invited to submit comments on the ROP, again on paper, which the committees accepted, modified, or rejected. The results of these actions were then published in the ROC, another large paper document. The new system allows the public to comment on proposed revisions by reviewing draft online. If a proposed standard or code receives no public comments, it goes straight to the Standards Council as a consent standard. If a document receives comments on the First Draft, the committee holds a Second Draft meeting to review, respond to, and vote on those comments and make second revisions. The revisions are then used to develop a Second Draft of the revised standard, which is again posted online for public review. The Second Draft essentially takes the place of the ROC.

Because the new comment stage serves as the formal public review and comment period during which the committee accepts, modifies, rejects, or holds each comment, any objections to the First Draft must be submitted at this stage. Anyone who feels that concerns raised during the comment stage were not adequately addressed can file a NITMAM to make an amending motion at the Association Technical Meeting. This allows the public to plead its case in front of the broader NFPA membership.

“Because the process is clearer, we are hoping fewer people will wait until the last minute to appeal,” says Cronin.

So rest in peace, ROPs and ROCs. The new process is simpler, more efficient, and more accurate than the old. It’s also faster: the just-issued NFPA 1965 was published 10 months earlier than it would have been had it been produced under the previous process.

Kathleen Robinson is editorial operations manager of NFPA Journal.

SIDEBAR
Access + Authenticity 

In addition to its new standards-development process, NFPA is addressing important intellectual property and copyright issues related to its codes and standards, steps designed to safeguard the integrity of the documents while allowing the easiest possible access. 

To make sure anyone can see an NFPA code or standard, even if they aren’t an association member, NFPA has introduced free access to all of its consensus documents at nfpa.org/freeaccess over the course of the past 10 years. The documents are in a read-only format, meaning the text cannot be copied or printed. Read-only PDF versions of NFPA codes and standards optimized for mobile devices and tablets are also available and are no longer locked with the FileOpen Digital Rights management utility, which kept many users from opening the PDFs on their iPads and Androids.

“NFPA strives to make its documents as accessible as possible, because we believe this is the best way to accomplish our mission,” says NFPA President James Shannon.

NFPA has also developed an authenticity program to ensure that the digital documents that are downloaded are the real thing and have not been altered in any way.

“When NFPA started offering our codes and standards for download on the Internet, we started to see an increase in counterfeiting and in cutting and pasting certain parts of the documents on other websites for the public to look at,” says William Geller, a senior project manager at NFPA. “Unfortunately, we found omissions of some very important contextual information and incorrect equations, which could lead to bodily harm or damaged property.”

To prevent that from happening, the Association took steps to help users verify that the code or standard they are using is genuine by affixing a stamp of authenticity to the front page of the document. Clicking on the seal, which contains the customer’s identification number, brings users to a verification database that includes all the NFPA documents in this program. This database tells users who bought the document and when.

“That way, anybody can verify that the document they have in front of them is an authentic NFPA document,” says Geller. “They can trust it.”

Documents may be unauthorized and may be inaccurate if they do not include the authenticity stamp, if user information is incorrect, or if there is no link to NFPA’s website. Users should stop referring to those documents and report them to NFPA’s Customer Service Department at 800-984-8500.