3.8 Referencing Standards
The Interpretative Guidelines in Section 1 of Communications Alliance Standards provides guidance on how Standards are referenced within these Standards. All mandatory referenced Standards are listed in Section 3 References in each Standard. Mandatory referenced Standards are identified by version, typically by year of publication.
Voluntary referenced Standards and other voluntary documents (e.g. Guidelines) are generally listed in Section 3 References to provide a complete listing of all referenced documents in the Standard but it is optional for these voluntary documents to be listed. Voluntary references do not need to be identified by version but often are where a specific edition needs to be cited. Further guidance on dating references is provided in Dated or Undated References.
When considering how requirements are to be included in a Communications Alliance Standard and whether the Standard is to reference other publications, the following decision process is to be followed:
- Whether there is a need to reference a publication.
- What publications are to be referenced.
- How to reference a publication (including style, mandating and dating).
Deciding whether to reference a publication in a Communications Alliance Standard
Working Committees need to take into account the objectives of the World Trade Organisation’s Technical Barriers to Trade Agreement when considering whether to reference international (and internationally recognised) Standards or to develop nationally based requirements.
When referencing an international Standard (or other publication under consideration), consideration should be given as to whether or not there are sufficient resources and expertise available to the Working Committee in order to satisfactorily and accurately determine and identify that the requirements of the Standard are applicable and suitable for mandating under regulation in Australia.
At the end of the project, Working Committees are required to provide a report that includes a justification of any deviations from international/overseas Standards or Australian Standards (AS and AS/NZS) when a Standard is to be recommended for adoption under regulation by the ACMA.
Deciding on what publications to reference in a Communications Alliance Standard
In reviewing a publication for referencing in a Communications Alliance Standard, the following factors to be taken in account to determine the relevancy of the publication to Australian conditions and within our regulatory framework:
- the nature of the regulatory framework the publication has been developed to be applied under and how the publication has been called up under those regulations.
- the reason for the publication’s development. The history of the publication may help explain the rationale for its existence.
- the compliance processes that would apply in Australia (including testing, certification and labelling) to equipment if the referenced publication has been mandated in the Communications Alliance Standard.
- any impact to the industry and consumers (e.g. costs, delays, barriers to entry, risks to networks).
- Differences in the nature of regulatory environments should be taken into account. For example, it should be noted that European regulation is ‘principles’ based whereas in Australia, the regulatory framework is ‘requirements’ based.
In many cases Standards developed for application under European regulations would be acceptable for application as mandated requirements via Australian regulations calling up Communications Alliance Standards. There will however be cases where the mandating in Australia of requirements of publications developed for application in the European ‘principles’ based regulatory environment would not be appropriate.
NOTE 1: The European ‘principles’ based regulations direct that an item must comply with the principles set out in the legislation (e.g. EU Directive), not necessarily with the specific or relevant requirements in applicable standards. Furthermore, in some cases the item may quite legitimately comply with the principles of the regulation when, in fact, the item may fail to comply with a specific section/clause of relevant standards.
NOTE 2: The Australian ‘requirements’ based regulations specify that the only way to comply with the regulations is to comply with the applicable standards, or other applicable arrangements, prescribed in the legislation.
How to reference Standards and other publications
a) Referencing style
When considering how to reference Standards and other publications in a Communications Alliance Standard, the following approach is to be adopted:
- as the first option, reference the entire publication.
- as the second option, reference a specific requirement (or requirements) of the publication.
- as the last option, reproduce the relevant requirement (or requirements) in the Communications Alliance Standard.
Further guidance can be found in the Standards Australia Standardisation Guide SG-001 on ‘Preparing Standards’ and in the IEC/ISO Directives – 5th Edition, Part 2 Clause 22.214.171.124 on References to other Documents.
Referencing entire publications
When referencing another publication, it is recommended that the publication in its entirety be referenced. This is in recognition that the scope of the publication and often other parts of the publication need to be taken into account when considering a specific requirement or provision in that publication.
Care must be taken to avoid prescribing a mandatory reference to an entire publication that has voluntary or recommendatory clauses and thereby inadvertently mandating clauses that may be untestable.
Referencing specific requirements of publications
It is recognised that in certain situations referencing the entire publication (e.g. an ETSI Standard or ITU-T Recommendation) may not be the most appropriate method. For example where the referenced publication is large and the specific requirement of interest forms only a small part of the referenced publication.
In this case, the reference can be to a specific requirement of the publication, for example, a clause, a section, a table, a figure or an appendix. When referencing specific parts, the following needs to be taken into account:
- to avoid taking the referenced requirement out of context where it may be dependent on other parts within the referenced publication.
- to review the terminology used, specifically the defined terms, to avoid any confusion or ambiguity with unfamiliar or foreign terms.
- to avoid referencing clause numbers as they may be subject to change in subsequent editions of referenced documents. Ideally the title of the referenced clause is to be cited.
Alternatively, referencing the ‘applicable requirements’ of a Standard places the onus of identifying the relevant applicable requirements on the user of the Standard and their professional judgment. Although this is a typical technique used to avoid undue referencing of multiple requirements, by reducing the specificity of the reference, the potential for the misapplication of requirements, either intentionally or unintentionally, increases. It is recommended that the technique of referencing ‘applicable requirements’ is to be only used in cases where the risk of introducing ambiguity in the requirements is not increased.
Reproducing requirements in publications
It is recognised that in certain situations referencing a publication or part of a publication may not be the most appropriate mechanism for including a specific requirement in a Communications Alliance Standard and that reproducing the requirement may have more utility.
Although reproducing parts of publications in Communications Alliance Standards is not recommended as the preferred approach, if the Working Committee is considering this approach, the following needs to be taken into account:
- the trade-offs in reproducing the information from the source publication rather that referencing it (e.g. the benefits in readability and utility of the Standard versus increasing the length and the risk of introducing errors and inconsistencies in the Standard).
- the likelihood that the information may change in the sourced publication. This may potentially lead to misalignment of requirements and add to Standards development costs down the track.
- copyright considerations of the sourced publication.
b) Mandatory versus voluntary references
When prescribing mandatory requirements via a reference to another publication, typically a Standard, the requirements in that Standard need to be assessed against the regulatory and compliance framework where that Standard is applied.
Requirements specified via mandatory references must be prescriptive and testable. The requirements should not be ambiguous and should be enforceable. This is in recognition that the compliance of customer equipment under current legislation is based upon meeting all the mandatory requirements of the relevant Standards called up under the Telecommunications Labelling Notice.
The publication being considered to be referenced may not be appropriate to mandate in Australia because it may be that the publication was developed as a voluntary or guidance type publication without any intention for it to be mandated under regulation.
Standards Australia, the IEC and the ISO all allow the use of ‘undated’ and ‘dated’ references for both normative and informative references. It is recognised that because of the nature of Communications Alliance Standards and the fact that they are usually mandated by regulation it is most likely that ‘dated’ references will be the most appropriate however, it should also be recognised that in some instances it will be appropriate to use ‘undated’ references. Both ‘undated’ and ‘dated’ references can be to either the whole document or a specific requirement of that document.
Where the reference is to a Standard listed in the Telecommunications Labelling (Customer Equipment and Customer Cabling) Notice 2001 (the TLN) and the reference is not to a specific clause number in that Standard, then the reference should be undated. This approach takes into account that the version of the Standard listed in the TLN would take precedence. A statement in the ‘Interpretative Guidelines’ section at the front of the Standard is to be inserted to reflect this approach.
As this approach was introduced in 2011, future reviews of Standards should take into consideration these types of references, in particular references to the AS/NZS 60950 safety Standard.
The use of undated references needs to be assessed for the benefits (i.e. not having to update references as the referenced publications are revised) against the possible risks (future revisions of the referenced publication introducing unwanted changes). The Working Committee also needs to recognise that the applicability of subsequent editions or amendments of referenced Standards is a matter for determination by the users of the Standard, employing their professional judgement. Users of Communications Alliance Standards should be encouraged to investigate the possibility of applying the most recent editions of the undated reference document(s).
Consideration also needs to be given to the frequency that a referenced document is revised and any implications for references in the Communications Alliance Standard that would prematurely become out-of-date.
Finally, consideration needs to be given to referenced publications in the publications referenced by a Communications Alliance Standard, also referred to as ‘sub-referenced’ publications, to ensure that these sub-referenced publications are appropriate.
In summary, references are to be dated unless it is for:
- informative references;
- references to Standards listed in the TLN where the reference is not to a specific clause number; or
- it is accepted that it will be possible to use all future changes of the referenced document for the purposes of the referring document.
d) Sourcing referenced publications
When referencing a Standard or other publication in a Communications Alliance Standard, consideration needs to be given to its access and availability. Publications from internationally recognised bodies such as the ITU, ETSI and the IEC/ISO are readily sourced and only the publication designation is required to be cited in a Communications Alliance Standard.
If the source of a referenced publication is likely to be not obvious to the user of the Communications Alliance Standard, then the Working Committee should consider providing further information in the References section of the Standard to assist in identifying the source of the referenced publication.