Withdrawal of FIPS / Usage of ISO standards

From: "richard l. hogan" <Richard=L.=Hogan%dpi%hqnmd@mcmcban6.er.usgs.gov>
Date: Tue, 29 Oct 96 9:20:26 CST
Subject: Withdrawal of FIPS

I have received a number of e-mail messages announcing that the National Institute of Standards and Technology (NIST) intends to withdraw 32 Federal Information Processing Standards (FIPS). Some of these messages have suggested that there are implications of this action that should be discussed.

As Chair of the FGDC Standards Working Group, the International Representative for ANSI's GIS Standards Committee (X3L1), and as part of the NMD HQ oversight for the maintenance of FIPS 173-1, I have had an opportunity to discuss this issue on a number of occasion from a number of different points of view, incuding direct talks with NIST about the implications for the Spatial Data Transfer Standard (FIPS 173-1). For what it is worth, I thought I would pass on my perspective.

One of the pieces of legislation that, according to NIST and the Department of Commerce, enabled the FIPS program was rescinded this year. The law - sometimes referred to as the Brooks Act - contained specific requirements for establishing uniform standards for information processing in the Federal government and for making those standards mandatory in Federal procurement actions. OMB Circular A-119 further clarified that mandatory Federal standards took precedence over voluntary national and international standards. Now, as a result of treaty negotiations making the Untied States part of the World Trade Organization, the Books Act has been replaced with new legislation that requires Federal agencies to consider voluntary international and national standards FIRST in procurement actions and to cite Federal standards only when no appropriate international or national standards exist.

In many cases FIPS have international (ISO) or national (ANSI) standard equivalents. For example, FIPS 123 (Data Descriptive Format for Information Interchange) is also ISO-8211. The change in legislation requires Federal procurements to now cite ISO-8211. Previously, we were required to cite FIPS- 123. As a result of this change, NIST has recognized an opportunity to make government "work better and cost less" by withdrawing any FIPS that already has an equivalent ANSI or ISO specification or any FIPS that is not mandatory; i.e., is just a guideline. What remains on the "active" FIPS list are mandatory Federal standards which currently have no ANSI or ISO equivalent; for example, the Spatial Data Transfer Standard (FIPS 173-1) and the Government Information Locator Service (FIPS 192).

NIST is not withdrawing important standards like Pascal, FIPS 109; SGML, FIPS 152; or Hydrologic Unit Codes, FIPS 103. The proper way to look at this action is that NIST is withdrawing the Federal designation of these standards in favor or their national or international standards designations; ANSI X3.97-1993 for FIPS 103, ISO 8879 for FIPS 152, and ANSI X3.145-1986 for FIPS 103. From a user point of view, this action by NIST is nothing more than a way to assure the designation change required by the new legislation.

However, we can expect other actions by NIST resulting from this new legislation. Future action will likely have more impact than this initial action by NIST. Specifically, NIST will begin to move the standards remaining on the "active" FIPS list toward approval as national and international standards as appropriate. For example, NIST is already cooperating with the National Mapping Division to gain ANSI approval of the Spatial Data Transfer Standard (FIPS 173-1). As these FIPS are approved as national and international standards, the FIPS equivalent will be withdrawn, further shortening the FIPS list. NIST does have a long-term goal to phase out the need for a FIPS program.

Specific to FIPS 173-1, NIST has decided that it will not process any revisions because it is currently being considered for ANSI. This decision creats a short-term problem for "official" approval of profiles for the SDTS while it is still in committee with ANSI. However, most profile activity is currently being done within the FGDC, so SDTS profiles will now be approved using the FGDC standard process and then forwarded to ANSI when appropriate. NIST may take a similar position for other FIPS as well.

Probably more interesting to the FGDC and Federal agencies in general are some of the proposed changes to OMB Circular A-119 that have been precipitated by this legislation change. The circular continues to encourage Federal participation in the standards development activites of formal standards development organizations (SDO's) like ANSI and ISO. However, Crircular A-119 revisions now require that Federal participants coordinate their input to SDO's and that every effort be made to establish a single Federal position within these bodies. It further requires that when a single Federal position cannot be established, that all Federal participants be informed of the various positions and the reasons for them. The Circular is not specific about how this coordination is to be achieved, but it should be apparent that for geographic information or geospatial data standards the FGDC is logical place for the singular Federal position to be established. I suggest that the FGDC will now have to take on a much more active and important role in ANSI X3L1 and ISO/TC211 and that Federal agencies' main avenue for input to these SDO's should be through the FGDC.

Revised Circular A-119 also makes it clear that "Federal standards" should be developed as a last resort. Federal agencies and committees (like the FGDC) are encouraged to make every effort to create needed standards through participation in volundary SDO's rather than in Federal committees. The FGDC standard process already requires development groups to seek out related national and international standards before proceding with development of an FGDC standard, but it will now have to consider moving work to appropriate voluntary SDO's whenever possible. The FGDC Standards Working Group has already done this in the case of the revision of the FGDC Metadata Standard, which has been moved to ISO/TC211. The change to Circular A-119 encourages an increase in this practice.

I hope this adds some understanding to what is happening with the FIPS program and Federal standards development in general.

Richard Hogan

The second message discusses the relationship between FIPS 123 and ISO 8211, in light of NIST's announcement of their intention to withdraw FIPS 123.

(I have paraphrased some of it slightly - I beg Richard Hogan's forgiveness for any lack of sense that has thus been introduced. The original email to Kim Burns-Braidlow was dated 1996-10-30.)

FIPS 123 is equivalent to the 1985 version of ISO-8211, which is not the current version. This is another good reason for withdrawing FIPS 123. When the new version of ISO 8211 appeared, it was inspected to see if there would be any problems referencing the new version if this approach was chosen. It was decided that referencing the new version would not invalidate anything in the current standard and would offer the added benefit of providing additional capability that might be useful in the revision of the raster portion of the standard. As a result the references to FIPS 123 were all changed to ANSI/ISO 8211 - 1994 in the ANSI draft version of the SDTS.

The following points apply:

1. There is no difference between FIPS 123/ANSI/ISO 8211 - 1985 and ANSI/ISO 8211 - 1994 as implemented in the TVP. All the reference to FIPS 123 in the TVP could be changed to ANSI/ISO 8211 - 1994 without affecting any translators.
2. Future versions - specifically the ANSI version - of the SDTS will reference only the ANSI/ISO 8211 - 1995.
3. SDTS does not use all the functional capability of FIPS 123 or ISO 8211. As a result only some of the changes made to ISO 8211 have an effect on the SDTS implementation of it.
4. Changes to ISO 8211 between the 1985 and 1994 versions generally do not apply to any present or future vector implementations.
5. Changes to ISO 8211 between the 1985 and 1994 versions will affect raster implementations and will generally make those implementations much simpler. However, since no raster implementations were defined before the change, translator development is unaffected.

Many thanks to both Richard L. Hogan and Kim Burns-Braidlow for the above.

Last modified: Tue Aug 26 15:00:00 BST 1997