Professionals working in the aerial adventure industry need to be literate regarding standards that are applicable to their job and jurisdiction. In the interest of working with the best standards possible, we should all contribute to the development and maintenance of these standards, too. Contributing can mean everything from sitting on a committee to simply making time to read, comment, or vote on draft standards as they’re released.
Unfortunately, many professionals, especially those new in their careers, run into barriers to participation in standards development processes. They often don’t know how or when there is opportunity to weigh in on a standard. And even if they do know, it can be intimidating—how do they know if their feedback is valuable to the process and the professional community? This is problematic.
Fortunately, any interested professional can overcome these barriers with a little education, some proactive outreach, and a bit of collaboration with peers.
Opportunities To Contribute
All standards developers—ASTM, ACCT, PRCA, ISO, etc.— have some form of timeline to ballot, comment, or vote on draft standards language. Some standards developers do much of this work primarily by committee only, and others, such as ATSM, use a more open-to-the-public process. How much input you might have prior to a draft standard being released for feedback will depend on your depth of involvement within a specific standards-writing organization.
Committees and working groups. If you would like to get involved at the draft language development stage, you will need to join a committee or working group. Depending on the organization, opportunities to help write and wordsmith draft language can sometimes be limited, but they do exist. The best way to find these opportunities is to be proactive. Reach out directly to the standards writing organization to see if volunteers are needed or if seats are opening within a working group or committee.
If you’re unsure of whom to contact, don’t overthink it. Send an email to a general address and ask to be connected to the correct party. If the organization writes many types of standards, be sure to cite the topics or standards that you’re interested in. Your outreach should be welcomed—these organizations run on the help of volunteers, after all.
Public comment periods. Contrary to the smaller group work, once a draft standard is released for feedback there is usually no limit to how many people can participate. Some organizations even require a critical mass of stakeholders to respond to the draft language for it to be adopted. At this feedback stage, the biggest barrier is simply knowing how and when a draft standard is released, how long you have to respond, and how you submit feedback.
Let’s dive into the many ways that this process happens across our industry standards.
ASTM INTERNATIONAL (ASTM)
ASTM F24 Committee on Amusement Rides and Devices (“ASTM” / “F24” – www.astm.org/committee-f24) is responsible for several standards for our industry, with just a few being F2959, F770, and F2291. These standards are continuously developed by F24 subcommittees and task groups.
Regular meetings specific to each subcommittee or task group are held via video conference to develop ballots that propose changes or new standards, and there are biannual (every other year) in-person meetings for the entire F24 committee where deeper dives and broader collaboration between groups is typical.
Anyone is welcome to attend and participate in meetings, no membership required. Attendees only need to register so ASTM knows who participated and can add you to its email list for standards updates. An ASTM membership is, however, required to vote and comment on ballots through the online system.
Given the number of standards being managed under the F24 umbrella, balloting happens typically on a bimonthly basis at minimum, with notice of each ballot cycle sent directly to voting members via email.
Click here to become a member.
AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI)
ANSI accredits organizations as standards developers, and those standards developers’ individual standards development procedures vary. The two accredited standards developers relevant to our industry are ACCT (Association for Challenge Course Technology) and PRCA (Professional Ropes Course Association). It is important to pay attention to each organization’s written ANSI procedures to ensure you understand the details of how each process works.
The ANSI/ACCT 03-2019 Challenge Courses and Canopy/Zip Line Tours Standards revision process allows for a 45-day public comment period for a standard that is distributed electronically, and a 60-day period if distributed in print only. When there is a draft standard out for public comment, ACCT announces the information through its email list, social media, and other channels. Additionally, you can both search for and sign up for notices on any standards development activity on the ANSI website (https://www.ansi.org/resource-center/standards-action).
Interested observers can virtually attend most ACCT “ANSI Consensus Body” standards development meetings by first filling out an observer agreement online, at least seven days in advance. Observers must, however, keep their microphones muted and speak only if asked to by the chair.
The ANSI/PRCA 1.0-.3-2014 Ropes Challenge Course Installation, Operation, and Training Standard is managed under “Constant Maintenance” as an American National Safety Standard. This means that minor changes and updates can be made to the standard by the PRCA Consensus Body without a formal public comment period. Substantive changes to the standard or any standards development in a new area would require a public comment period.
PRCA does provide a form where comments can be submitted at the end of each chapter of the standard, and the organization can make changes suggested by individuals quickly without offering a public comment period because its accredited procedures and auditing requirements as a Safety Standard are different from, for example, ACCT. Unfortunately, a copy of these forms is not available online.
ACCT and PRCA also publish standards, guidelines, procedures, explanatory notes, definitions, and other reference documents that are not ANSI standards. These will either not carry the ANSI logo, or will be cited within a larger document as being excluded as part of the ANSI standard. These publications are accomplished via different processes and timelines than those used for development of their respective ANSI standards.
Neither organization appears to have a published and/or publicly available and documented process for how they create and publish their non-ANSI standards-related documents.
Some ACCT volunteer work groups do have “terms of reference” that outline their internal processes and minimum requirements for operation. However, these terms, as well as how the groups are composed and maintained, vary group-by-group. Click here for more info on the standards related groups for ACCT.
At this time, PRCA does not list any committees for its non-ANSI standards-related work online, but it does maintain industry advisories and certification opportunities.
CLIMBING WALL ASSOCIATION (CWA)
Climbing Wall Association (CWA) standards are written by committee, and membership on the committees is open to those interested in or affected by the standard. Currently, CWA has three active standards committees: The Engineering Standards Committee, the Operations Standards Committee, and the Certification Standards Committee.
CWA has a published policy for the development and maintenance of Climbing Wall Association standards, last revised July 6, 2007. While not accredited by any organization to write standards, CWA nonetheless follows processes similar to those of ASTM and ANSI in its standards development activities. For example, CWA requires and adheres to the principle of non-dominance in its standards development process such that it works to maintain a balance between various interest categories when completing work.
Most CWA standards meetings are open meetings and visitors are welcome to attend if they submit a written request to the chairperson 10 days in advance. Visitors can interact with the committee(s) and their discussions but may not vote. For a standard to pass committee, it must do so with a 75 percent approval of committee members. If approved by the committee, CWA offers a 30-day minimum public comment period, and all negative comments must be addressed as per policy.
INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO)
ISO standards such as 21101:2014, 21102:2020, and 21103:2014 are developed by the International Organization for Standardization (ISO). A new ISO standard typically goes through a multi-step process that includes a development stage in which a working group prepares a working draft that is reviewed and approved by a parent committee, and an enquiry stage where the draft is shared with the ISO secretariat and circulated to all ISO members who have 12 weeks to comment and vote.
The document is approved if two-thirds of the P-Class members (i.e., participating country technical committee members) are in favor, and not more than 25 percent of the votes cast are negative. This step may repeat itself if required. A second comment period, if required, is typically limited to eight weeks. Once the standard is approved, it is published by ISO as an international standard.
EUROPEAN COMMITTEE FOR STANDARDIZATION (CEN)
The European standards bodies (CEN and CENELEC) publish several relevant European Standards (EN) for aerial adventure parks and ropes courses such as 15567-2 2015 and 15567-1:2015+A1:220, amung others.
The process of drafting an EN standard starts with a proposal. If a proposal is accepted, the relevant committee will discuss the need and merits of the request. If a need is found, the public is notified and can comment. A proposal is adopted if a simple majority and 71 percent of the weighted majority of the voting national organizations vote in favor of the proposal. If approved, a committee and/or several subcommittees will be formed to complete a draft.
Once a draft is complete, it will be made available for public comment. In most cases, the public has two months to provide comments. This step may go through two or three rounds before having a final draft that will earn enough public support. In a separate vote, 71 percent of the weighted majority must approve the draft for it to become a standard. Once approved and published, EN standards carry the full weight of the law in all adopting EN countries.
Reviewing and Commenting on Draft Language
Once you understand how to participate in a particular standards development process, you need to be prepared to review, interpret, and evaluate draft standards language.
People reviewing and commenting on standards notice different things based on their role in the industry and how they view and interact with the world. Certain content is simply more important or relevant to some people than others. For example, designers may focus on the math and harmonization with other construction standards, builders and installers might focus on the ease or difficulty of application to installation practices, and operators and trainers may not care about the installation or inspection standards at all and focus only on the use of the structures with others.
This is why standards developers need to obtain comments from a diverse group of stakeholders, and it is also why you needn’t be an expert in every area before you participate in the process. Your feedback on the topics in which you do have experience is valuable—even if you don’t weigh in on every area.
Regardless of the areas you choose to provide comment on, there are common considerations for evaluating draft standards language that you should be aware of.
What Should You Look for When Reviewing Standards
Title/Scope: Does the title and scope match the text of the standard? Does all the content in a section belong in that section, or in the standard altogether?
For example, according to its scope, ACCT Chapter 1: Design, Performance, and Inspection “…establish[es]requirements for the design, performance, and inspection of elements and associated equipment for Challenge Courses, Aerial Adventure/Trekking Parks, Canopy Tours, and Zip Line Tours.” Based on that description, standards regarding requirements for training or certification would belong in a different chapter.
If you are reading draft language that doesn’t seem to belong under a particular scope, you should 1) comment or vote negative for the inclusion of that language, 2) suggest a change to the scope so the topic fits within that section, or 3) suggest the language be incorporated into an appropriate section of the standard that has an applicable scope.
Terminology: How words are defined and understood is critical to the use of a standard. Definitions clarify the use of words in the context of the document. Have any uncommonly used terms been clearly defined? Are there terms that should be defined but are not? Are any definitions that are needed to accurately interpret and comment on the standard included as part of the draft, and/or should they be?
If the list of definitions is not included in the document for review, you will need the newest published version of the standards developer’s definitions, and/or research the term using an online legal dictionary in order to accurately read and interpret the standard.
Clarity and specificity of language: Is the meaning of the text clear and concise? Can it be accidentally interpreted to have more than one meaning? Are there important steps in a process or procedure that seem to be missing? As a professional in the field, you should be able to read and interpret the standard with relative ease if it is a topic you are familiar with. If you cannot, determine whether the language is clear and matches the intent of the writers, or if it could use some editing. Never hesitate to suggest clearer, simpler language.
“Should” vs. “shall” and similar nuances: Certain words are important to consider when interpreting and commenting. For example, users of the standard will be expected to adhere to all instances of “shall” and “shall not,” while “should” and “should not” are merely recommendations.
When you encounter these words—and others that determine permissions and obligations—consider whether the guidance in question should be a requirement or a suggestion.
Generally, here are some words to pay attention to:
- Shall, or Shall Not = Requirements
- Should, or Should Not = Recommendations
- May, or May Not = Permissions
- Can, or Cannot = Capabilities
Additionally, “explanatory material” included in a standard is not itself a standard, and the words “shall” or “shall not” generally do not belong in these subsections.
Using words like “shall” and “shall not” in the wrong places can lead to confusion between text that is non-mandatory but rather strictly meant to help people understand meaning, with an actual standard to which one may need to strictly adhere.
Measurements, weights, and listed strengths: These numbers matter, and standards should utilize a consistent measurement system throughout (i.e., metric or imperial). If conversions are provided, have they been checked for accuracy?
Grammar, typos, misspellings, and figure errors: While minor, commenting on these types of observations can improve the quality of the standard. Not everyone sees these, so if you identify copy editing errors, don’t be afraid to point them out.
Standards numbering: Standards use a lot of alphanumeric references (ex. A.1.2.1) to help readers identify specific standards and their place in the overall standard. An error in this numbering/identification system can render sections of a standard difficult to use—or entirely useless and irrelevant. As with typos, identifying these minor corrections can help create a clean, accurate standard.
Naming specific products or using proprietary intellectual property: Organizations generally have policies on the use of copyrights, trademarks, and patents in their standards. Generally, standard accrediting bodies frown upon the inclusion of this type of specificity. Sometimes, though, standards authors may not be aware they have referenced something proprietary or used a brand name instead of a generic term. Whenever you see specific product names or the use of others’ intellectual property, double check to see if a) that is allowed, and b) there is a good reason for such specificity.
Illustrations and tables: Standards often include illustrations and tables to assist readers in understanding concepts. These illustrations need to be in the right place, properly referenced, clear to the reader, and have the appropriate approvals for use if owned by others.
In some cases, upon review of a draft standard, you may identify an area where an illustration is not provided but would be helpful. If you have the technical skills, you can create and submit items for use. Or, if you know of an existing illustration or table and gained permission from the owner to use it, you can suggest that it be used.
Referenced standards: References to other standards need to be verified during revisions as other standards also go through revisions and the current standards or citations listed may no longer be relevant. Referenced standards need to be accessible to be reviewed for applicability, and sometimes this is a hurdle depending on an individual’s access to various standards. Remember that you can always phone a friend for help if you think they might have access to a standard that you don’t. They may not be able to share it with you, but they can at minimum discuss it with you so you understand the benefits or drawbacks of referencing other industry standards.
International differences: When reviewing standards used internationally, it’s important to note that some items may not be applicable to all countries due to differences in jurisdictional practices. This is especially true when citing specific governmental agencies, jurisdiction-based authorities, or types of insurance. Some sections may need to be revised to be more general in nature so that all participating countries can utilize the standard.
For example, citing the Occupational Safety and Health Administration (OSHA) in an international standard isn’t effective since a work safety authority by this name does not exist in all countries. In these instances, using more generic terminology like “worker safety regulations applicable to your jurisdiction” or sometimes even simply adding “if applicable” can make a more inclusive and usable standard.
Following policies, processes, and procedures: Organizations that develop standards (accredited or not) should have written policies and procedures as well as style guides that direct their standards development process. It’s important that you understand the process you’re participating in, and how to address any missteps on the organization’s part —because they do sometimes make mistakes. Not following procedures can impact public comment periods and may void an entire comment period or ballot altogether, requiring a re-submittal in line with policies.
Official ANSI Standards Developing Organizations (SDO’s), in addition to their own policies, need to adhere to ANSI’s overarching ANSI Essential Requirements. Style guides for writing standards may not be published online but can be requested from the standards developer directly.
Some other resources on this are:
- ASTM Form & Style Manual
- ACCT ANSI Procedures
- CWA Policies & Procedures
- EN Process Through Enquiry Stage
- ISO Stages & Resources for Standards Development
How To Comment
Submitting formal written comments on any draft standard is an integral part of the development process. They may be the core feedback mechanism for an organization’s process, they may be required when casting a particular type of vote, or they may just serve as a channel where industry folks can provide helpful information.
Use of the organization’s published comment form (typically made available along with the draft language) is suggested. Alternatively, a template or spreadsheet of outside design that captures all the organization’s required information may be acceptable, but always double check with the organization before using an alternative submittal.
Comments can generally be categorized in four ways, and thinking about which type of comment you are writing can help you be clear in your intent:
- General (G): These comments normally address larger areas of the document being reviewed. They include paragraphs or sections that may not be in an appropriate part of the standard, are confusing, have poor structure, or are unclear. Pointing out one specific sentence or issue to be edited may not be possible. General comments overlap technical comments in many cases because the content of the section is technical in nature, in which case you may have two or more separate comments on the same content.
- Technical (T): Technical comments affect the technical accuracy of the document. If you have specialized knowledge in a specific area, you may find yourself commenting on technical details, specific procedures, norms within related industries, and necessary or missing information.
- Editorial (E): Editorial comments affect how the content is presented. They identify typographical errors, misspellings, improper sentence structure, mislabeling, and similar problems.
- Procedural (P): Procedural comments are about whether the organization followed its accredited and/or published policies and procedures.
When writing a comment, state clearly and rationally why you are making a specific suggestion or voting a certain way. Comments like “I don’t like this,” “this is too difficult,” “this is too expensive,” or “I won’t be able to comply,” will likely get rejected outright for not being relevant and not containing alternative language.
Always provide reasoning as to how or why the language or changes will affect standards users, and specifically why that is good, bad, unsafe, inaccurate, or otherwise. The content drafters need to be able to understand your perspective in order to engage in a productive dialogue, or amend the content and submit it back to you for additional consideration. Do not be condescending or snarky. No one wants to feel attacked, and tone can impact reception, i.e., a good point badly made may not be well received. Make sure your comments are professional in tone, focused on facts, and do not make the feedback personal.
“Suggested language” comments are one of the best ways to help everyone gain consensus and move a standard forward. If you understand the intent of the writers but feel the text can be clearer or better in some way, doing the work to provide suggested language is far more effective and proactive than simply criticizing the text. Remember that suggested language comments could include deletions, insertions, minor edits, or completely new paragraphs or sections as needed.
What Happens to Your Comments?
ANSI SDOs, regardless of their unique policies, are required to consider any technical comments received during the comment period and address them prior to closing out the comment period. Alternatively, procedural comments on how the standard is being developed can be submitted at any time. Both types of comments require consideration by the standard developer, but keep in mind that consideration might include that your comment is incomplete and/or irrelevant if you didn’t follow all the steps the SDO requires.
Regardless of the quality of your submission, a formal resolution of your “negative” or “negative with comment” vote is typically required. Resolution includes noting whether the comment is persuasive (requiring a modification and re-balloting of the standard), non-persuasive, a simple editorial change, incomplete, or not relevant.
ASTM. When voting negative on an ASTM ballot, a comment explaining your negative vote is mandatory. A representative who is involved with that ballot may contact you to discuss your negative vote. Depending on whether you’ve been deemed persuasive or not, you may be asked to consider alternate language, to remove your negative vote, to propose new language, or to delay your requests to a later stage, or you may even be informed that the ballot is being removed completely. The decision on what to do in these situations is yours and should be thought about carefully.
General. In any event, organizations have procedures dictating how they must respond to comments on a draft standard. It is important that you understand these requirements so that you can adhere to that process and ensure that the organization is, too. Remember, if you disagree with the way your vote or comment was handled, organizations also have procedures for appeal. Know them and use them if needed.
Most critically, if you receive communication about your comment, you must respond to that communication within the timeframe specified by that organization’s procedures. Responses not received within required timelines can be interpreted as a closed matter.
You might also just get a notification (and sense of satisfaction) that your comment was considered persuasive and the next publication or draft submittal of the standard will include your suggested changes. Don’t be discouraged from continuing to participate if this doesn’t happen, though. It’s meaningful that you took the time and submitted thoughtful comments to improve your industry standards.
Additionally, you don’t have to wait for public comment periods to comment. Most standard setters will accept feedback when it’s received and will record and file the comment for review and consideration when appropriate.
Lastly, don’t read standards alone. Read them together with coworkers or peers. When possible, get the key stakeholders of your organization involved. They will interact with, interpret, and think about the draft differently than you, providing a multi-faceted review.
The dialogue generated will not only help each of you and your operations have a better understanding of the standard and how to implement it, but you might also identify significant potential impacts of standard revisions on your daily business operations or bottom line.
