Standard Setting and HS/EM


The best known standard to the HS/EM community IMO is NFPA 1600 which can be found at:

http://www.nfpa.org/assets/files//PDF/CodesStandards/1600-2007.pdf

Developed over two decades it is what is called a voluntary standard although it has been officially adopted by many organizations.

OMB Circular A-119 concerns itself with voluntary standard setting organizations and participation of federal organizations and individuals in those organizations.

OASIS is another organization doing useful work.

The problem as always is enforcement. Neither DHS nor FEMA  have units set up to see what could be accomplished by adoption of certain private voluntary standards but instead operate on a hit or miss basis.

One organizations recommended flood plain management standard that should have been adopted officially through regulation long ago is the Association of State Flood Plain Managers standard of NO ADVERSE IMPACT meaning no development in the 1% annual occurrence floodplain or designated floodway that would have any adverse impact on other structures or create new flowage restrictions.

Floodways of course are a bit tricky to regulate since they represent political not engineering decisions. A community can mow dow the forest on one side of the river to promote channel efficiency and prevent flooding on the developed side. Not a good choic but technically on that the NFIP regulations would allow. Or a community could build a flood wall or levee on its side of the river and adversely impact the community on the other side.

I long encouraged through the ETHICS IN GOVERNMENT program participation of experts within FEMA [and yes there are still a few] to participate in these private standard setting organizations as individuals as long as they made clear their participation was as an expert individual and they were not promoting a formal FEMA position. But I also wanted them to identify and bring to FEMA management the issues raised during meetings of the voluntary standard setting organizations and if appropriate have FEMA sponsor an official position to be considered by the organization.

Basically, DHS and FEMA have almost NO COMMERCE CLAUSE regulatory authority meaning the statutes they adminster are grounded in other clauses of the Constitution. I always was and still am interested in the legal issue of whether the National Security community has some sort of regulatory or implied authority to impact commerce or national security. This is somewhat arcane but clearly some things do impact commerce when the National Security community adopts some kind of performance standards in their dealings with contractors or the public.

Hopoing more efforts to develop useful standards will occur. Credentialing [sic] is another area where an NFPA standard has been adopted and is also very useful.

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About vlg338

www.vacationlanegrp.com
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