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Post Brexit - Why are we still permitting CENELEC etc to influence how we govern our own engineering affairs?

There seems to be a repeating mantra throughout the youtube presentation which becomes irksome if you listen for long enough. It seems that we just adopt, or rather 'harmonize' without question and then defer the responsibility for decision making back to CENELEC rather than think it through and act for ourselves.

How is it that we allow the tail to wag the dog? Isn't it time that we departed from harmonization and went our own way?

Comments welcome

Parents
  • Looking at how the discussion has evolved, I think there are a couple more things worth saying about electrotechnical standards work.

    First, any low-voltage wiring regulations are a tiny part of what CENELEC does. And national standards in wiring continue to be honoured (there is no participating country which would want it any other way. Building wiring is quite fiercely national, which is why road warriors have to carry all those adapters for their laptops).

    Second, there is a need for harmonisation of standards. People designing, building and marketing electric door mechanisms  for industrial plant need to conform with RF standards and functional safety standards and half a dozen others, and where these say different things there is an engineering problem which is only soluble if someone undertakes harmonisation. If it's not to be CENELEC, it would have to be brought all in-house in the UK, and BSI couldn't do that because the companies whose employees sit on their committees wouldn't agree to pay for duplicate work. BSI wouldn't pay its own staff for duplicate work either. It is just common sense not to pay to do the same thing someone else is already doing when you can just join in on that effort for a lot less money. 

    Third, the idea that "we" need a voice/don't need a voice, etc, does not fit with the requirements for working on standardisation authoring committees. Members (called "experts" in the jargon) who are authoring a standard sign an undertaking to represent no entity except their own engineering best judgement. Not their nation. Not their company. And there is no restriction on the number of members a country may nominate. When a Project Team has authored a standard, it goes out for comment (maybe many times) to National Committees (the BSI is the UK National Committee) and NCs can compile comments as they will and forward those comments via the IEC (or CENELEC) to the PT. There is a requirement that all comments forwarded to the PT must be answered.

    Fourth, where nationality comes in is solely with proposal and adoption of standards, not with authoring. There is one vote per NC. So all participating countries are equal. Also, at TC meetings there are representatives of NCs, one per NC, who can introduce/comment issues which their NC wants introduced/commented under guidance from the NC. These are all functions which are well removed from the content of standards themselves (except for voting accept/reject on a standards draft sent out for vote).

    Fifth, in my experience in standards committees, people align on common interests or common views. These may, and do, fall by country. There are certain topics in functional safety concerning which I have experienced country alignments, but these are opportunistic. Much more often I have experienced experts promoting the business model of their own, usually large, company. Large companies and their wishes do drive a lot of this stuff (not least in the amount of money they are willing to spend in supporting meetings, which in the case of IEC were all over the world; here, there has been a welcome recent change to remote meetings via Zoom, meaning that people such as myself without huge travel budgets can participate more continuously and more effectively). 

    Sixth, some of my colleagues (and I, at times) think electrotechnical standardisation is broken. Too often, the people nominated as "experts" are not in fact technically expert (or sometimes even at all experienced) in the subject matter of the standard. There are company shills. There is no quality control on the documents produced except for NC comments and a requirement they be answered (note: not resolved, but answered). Here, EU Framework projects proffer a much better model. There is an independent expert review every year, in which three independent experts, who are indeed technically expert in the subject matter, review the deliverables and accept or reject them. Rejected deliverables must be revised. The reviewers I have worked with on EU Framework project reviews have all been technically very capable and discerning. Whereas some of the international standards with which I have been involved have been/are hopelessly inadequate from the point of view of a subject-matter expert. An independent review committee with the power to say "this is crap" and why it is crap could have helped in a number of cases. For an example, see https://scsc.uk/rp154.15:1 (accessible through https://scsc.uk/Proceeding in the February 2020 proceedings) or, if you don't want to register with SCSC, a preliminary version is available at https://www.researchgate.net/publication/333479542_IEC_TR_63069_Security_Environments_and_Security_Risk_Analysis It is one of my most-read publications on ResearchGate. The eminent John Knight (RIP) also addressed the issue of standards quality in the SCSC Symposium proceedings in February 2014 (but here there is no way around registration) available from https://scsc.uk/scsc-126

  • Peter,

    Having read your comments I find that you seem to have a cynical view of Standards Development. Unfortunately I can confirm that it is my experience also, though in addition to those attending meetings who are not technically expert I have also met others who most definitely are and learned much from them.

    My one niggle with what you have said is the comment " There is one vote per NC. So all participating countries are equal." This is certainly true with IEC but I believe that with CENELEC the votes are weighted so votes from larger countries such as Germany and France (and of course UK) carry more weight than votes from smaller countries such as Luxembourg and Malta. Perhaps someone can confirm (or otherwise) this.

    I would also point out that some National Committees seem to merely submit a positive vote to everything raising doubts about whether they are actually reviewing the draft standards so this is another way in which the process can fall down. If 80% of NCs give a positive vote it can override the remaining 20% saying "this is a load of ****!"  The fact that the comments need to be answered doesn't prevent the PT merely responding by saying "we disagree with this comment". Fortunately I have not been involved in any standards work where this has been likely since those NCs who properly review the work are also those who provide the experts on the PT.

Reply
  • Peter,

    Having read your comments I find that you seem to have a cynical view of Standards Development. Unfortunately I can confirm that it is my experience also, though in addition to those attending meetings who are not technically expert I have also met others who most definitely are and learned much from them.

    My one niggle with what you have said is the comment " There is one vote per NC. So all participating countries are equal." This is certainly true with IEC but I believe that with CENELEC the votes are weighted so votes from larger countries such as Germany and France (and of course UK) carry more weight than votes from smaller countries such as Luxembourg and Malta. Perhaps someone can confirm (or otherwise) this.

    I would also point out that some National Committees seem to merely submit a positive vote to everything raising doubts about whether they are actually reviewing the draft standards so this is another way in which the process can fall down. If 80% of NCs give a positive vote it can override the remaining 20% saying "this is a load of ****!"  The fact that the comments need to be answered doesn't prevent the PT merely responding by saying "we disagree with this comment". Fortunately I have not been involved in any standards work where this has been likely since those NCs who properly review the work are also those who provide the experts on the PT.

Children
  • Why should we continue to 'harmonize' at all? Surely, wiring practises in the UK should be wholly unrelated to those on the continent, or indeed the rest of the world, so who pushes for hamronisation and mandatory adoption of harmonised wiring practises? If you wish to harmonise standards for export products then fine, but regulatory practises for wiring methods etc? Who is gainig from this?

    "Give me a committee of one and I'll get things done" Winston Churchill.

  • You seem to be focused on wiring to the exclusion of other electrotechnical engineering topics. End 2021, CENELEC had 7713 active standards. How many of those do you think concerned low-voltage wiring in buildings?

  • Having read your comments I find that you seem to have a cynical view of Standards Development.

    Let me amplify. My comments may substantiate your observation, or may not.

    I have worked over more than a decade with between 100 and 200 colleagues in German electrotechnical standards and about 150 international colleagues on IEC standards.

    During that time, I have had four main projects. First were (a) describing "formal methods" so that people using IEC 61508, the functional safety standard, to devise SIL 3 and SIL 4 safety functions knew what it was they were supposed to be doing, and (b) replacing a technically very poor Annex of IEC 61508 on the statistical evaluation of SW through operational history with something technically more solid. The outlines of both of those efforts were clear to me, as well as to UK colleagues, in 2010. In 2022, both of them are (I hope) nearing fruition (meanwhile, all my UK colleagues have lost interest, although they may still be interested in the outcome). That is a huge amount of time for what technically should have been very straightforward projects of a few person-months. And there have been some absolutely miserable experiences along the way, such as deliberate, continual sabotage of a committee I convened in 2016, which has not been reconvened since that experience, despite acknowledgement of considerable interest in its nominal subject matter. 

    Other tasks were (c) revising the guidance on human factors issues in IEC 61508, which seems to have been successful (although I have so far declined to propose reconvening the IEC PT which had been working on it for a separate standards document); (d) incorporating cybersecurity considerations into functional safety standards. (d) seems to have completely failed as a technical endeavour. The references I have given explain how, technically. Politically (that is, in terms of how committees have reached "decisions"), let me say I have endured some very inappropriate behaviour, and I am not alone in that view.

    The paths to rectification are slow and laborious. They may also work, but I don't personally intend to spend a decade on it with (d) as I have done with (a) and (b), largely because I think events will overtake the thoughts of participants in standards committees. I am happy to work on cybersecurity in safety-related systems and consider it a priority, but I am no longer prepared to work with company shills. For example, Martyn Thomas and I have a paper about to come out on the detailed implementation of the NIS regulations. The work has been favourably received by legal reviewers. We did it originally in 2018, when my attempts to present it in a German standards advisory group on cybersecurity were filibustered by reps/shills of a specific company.

    All this is familiar stuff to politicians. But I am not a politician and don't care to turn into one.