Why Do We Need an SDO if We Have the OSAC?

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Bradford J. Wing, MS, Secretariat, AAFS Standards Board

SDO is a term meaning Standards Development Organization. OSAC stands for the Organization of Scientific Area Committees. The AAFS has established an SDO called the AAFS Standards Board (ASB) that works closely with OSAC to develop voluntary consensus standards, technical reports, and best practice recommendations.

OSAC is administered by the National Institute of Standards and Technology (NIST). OSAC publishes the Registry of Approved Standards and the Registry of Approved Guidelines for the forensics community. Each document listed in the registries is required to be based upon sound scientific principles and to have been developed in a consensus-based process. OSAC has 23 subcommittees, each focused upon a specific area of forensics. These subcommittees are responsible for determining which documents to submit to the Registries, but also to identify gaps and needs in standards and related documents. Another function of the subcommittees is to identify research needs and publicize these needs to Federal agencies.

The term “voluntary consensus standards” is the key as to why the ASB was created and why OSAC needs the cooperation and participation of the ASB and other SDOs. In 1995, Congress passed a law called the National Technology Transfer and Advancement Act (NTTAA). This law states, “All federal agencies must use voluntary consensus standards in lieu of government-unique standards in their procurement and regulatory activities, except where inconsistent with law or otherwise impractical.” This also has a trickle-down effect, since Federal grants involving standards are also subject to NTTAA. The important point for this discussion is that OSAC was not created to generate voluntary consensus standards. The NTTAA and the policy document explaining it (available at http://www.nist.gov/standardsgov/omba119.cfm#3) define the processes required to develop a voluntary consensus standard:

  1. “Openness
  2. Balance of interest
  3. Due process
  4. An appeals process
  5. Consensus, which is defined as general agreement, but not necessarily unanimity and includes a process for attempting to resolve objections by interested parties …”

The ASB meets these criteria. In fact, it has been accredited by the American National Standards Institute (ANSI), which requires adherence to the principles defined above. OSAC is not an SDO and will not become an SDO. While an OSAC subcommittee may identify a gap in existing standards for a field, and even develop a draft document for submittal to an SDO, it is the role of the SDO to ensure that the procedures are properly followed so that the requirements of the NTTAA for voluntary consensus standards are met.

The ASB accomplishes this by forming Consensus Bodies (CBs). Currently, there are 13 such CBs (Anthropology, Bloodstain Pattern Analysis, Disaster Victim Identification, DNA, Dogs and Sensors, Firearms and Toolmarks, Footwear and Tiretracks, Forensic Document Examination, Friction Ridge, Medicolegal Death Investigation, Patterned Injury, Toxicology, and Wildlife Forensics). With the exception of Patterned Injury, these exactly correspond to OSAC subcommittees. The CBs are made up of individuals from different backgrounds, which are characterized by “interest categories,” of which we have eight: academia, consumer groups, general interest (typically lawyers and judges), laboratories and testing facilities, producers, subject matter experts, user/government, and user/industry. This helps to ensure balance of interest – one of the key requirements for an SDO.

CBs (which develop the standards) hold meetings open to all interested parties and are comprised of experts from the eight interest categories listed above. There is a defined process to develop the documents – ensuring due process, including an appeals procedure. Each document is put out for public review, so that any interested party – even if they do not participate on the consensus body – may comment on the document. The consensus body is responsible for adjudicating any issues that may arise during the review. Consensus must be reached among the members of the consensus body for a document to be adopted. In addition, the Board of the ASB must approve the document prior to submission to ANSI (which allows a standard to become an American National Standard).

This is all well and good, but it still doesn’t answer the question of why the AAFS now has an SDO.

When the OSAC was established, it became apparent that some fields in forensic science had existing relationships with SDOs – such as in fire science and gunshot residue. Others may have had professional organizations (such as the American Board of Forensic Odontology) which had issued guidance documents. In some fields, there were Scientific Working Groups (SWG), such as in DNA. However, the standards and best practice guidelines produced by professional organizations and SWGs do not meet the requirements of the NTTAA for being voluntary consensus standards. OSAC approached several professional groups, including AAFS, to see if any were interested and capable of establishing an SDO to generate voluntary consensus standards.

The AAFS accepted the challenge and created the ASB. The ASB CBs have close relationships with their corresponding OSAC subcommittees but the CBs may also generate documents on their own. Some documents may be proposed directly by professional organizations, or even by individuals not associated with OSAC.

The CBs need assistance in determining the scientific underpinnings that must be included in the ASB standards and best practice recommendations. CBs will typically reach out to OSAC subcommittees to provide the necessary scientific and operational foundation for the requirements in a standard or best practice recommendation.

Once a standard or best practice recommendation is finalized by the ASB, the corresponding OSAC subcommittee may refer it for inclusion in the appropriate Registry – thus completing the loop of interrelationship of OSAC subcommittees and ASB CBs.