Standards and Industry Leading Practices What to Know, What to Do January 13, 2010

1. Standards and Industry Leading PracticesWhat to Know, What to DoJanuary 13, 2010 Jim Dieter, CPPM CF Sunflower Systems Director of Strategic Programs

2. FAR 52.245-1 • The contractor shall initiate and maintain the processes, systems, records, and methodologies necessary for effective control of Government property, consistent with voluntary consensus standards and/or industry-leading practices and standards for Government property management.

3. FAR 52.245-1 • The contractor shall initiate and maintain the processes, systems, records, and methodologies necessary for effective control of Government property • This is the most important part!!! • “Control” not “management” • “necessary” and “effective” • I don’t see “excellence” in there anywhere….

4. FAR 52.245-1 • consistent with voluntary consensus standards • and/or industry-leading practices and standards for Government property management. • Not “IAW”, but the less stringent “consistent with” • One or the other, or both…

5. FAR 52.245-1 • consistent with voluntary consensus standards

6. Relevant Standards • UN – UNSPSC • UPC/GS1 – Barcode/Identification • ISO – ISO 9001 (Customer Supplied Product) • IEEE – EPEAT Standard • EPA – Energy Star • DoD – Military Standards

7. ASTM E53 • Receiving • Location • Levels of Control • Process Maturity • LDD • Physical Inventory Standards Covering:

8. ASTM E53 Standards Covering: • Terminology • Cannibalization • Guiding Principles • System Outcomes • Mobility

9. ASTM E53 • Utilization and Disposal • Movement Velocity • Life Cycle Cost • Career Development • Asset Prioritization Standards Covering:

10. ASTM E53 Standards • Applicable to any property holding entity • Efficiency and effectiveness • Standard outcomes, processes and expectations while allowing operational and management flexibility • Incorporation into property industry approaches, products and software

11. Adoption of Voluntary Consensus Standards The National Technology Transfer and Advancement Act of 1995 (Public Law 104-119) and OMB Circular A-119, mandate the use of Voluntary Consensus Standards in lieu of Government-unique standards

12. GSA BULLETIN FMR B-18PERSONAL PROPERTY (July 17, 2008) • “Voluntary consensus standards are a valuable tool for the personal property manager as they represent the collective wisdom of federal and private sector experts covering topics not addressed in law or governmentwide regulations.”

13. FAR 52.245-1 • and/or industry-leading practices and standards for Government property management.

14. Ever Try Goggling “ILPs”(and Variants)? Search results are all about us! No definition, not even on Wiki We made this up!!!

15. Courtesy of Dr. Goetz • “What is an Industry Leading Practice??? – There was and is no Statutory or Regulatory definition of Industry Leading Practice – There is no “Official” FAR definition of an Industry Leading Practice • Note – that is correct, even the Government does not define every term it uses in a regulation – as there are some terms that are ASSUMED to have a general meaning. In this presentation we will discover that the term Industry Leading Practice DOES NOT have a universal definition! – In point of fact, after doing an exhaustive web search of the term it was discovered that the term is used most often as a “BUZZ WORD” in advertising to establish legitimacy for one’s application or product. – So, since no “official” definition exists it is important to note that we can “BORROW” or appropriate from OTHER applications or bodies of knowledge.” * http://www.npma.org/ArchivedPubs.aspx

16. Jim paraphrasing Doug… The government has no idea what this term means

17. Dr. Goetz’s Attempt at a Definition • “Industry leading practices (ILP) are generally accepted processes, including best practices, that have been proven throughout related businesses, to be managerially and economically effective, efficient, and successful at meeting particular objectives of a contractor’s management system, and where specified, in compliance with the required Government Outcomes. The ILP should be based on empirical research, evidence and literature pertaining to that business practice, product or system as a “leading” practice. In order for a process to become an ILP, it should be widely used. Generally, there should be supporting historical data from an accepted source, e.g., trade publications, literature, etc., to support that process as being repeatable, efficient, measurable, and verifiable.” * Bolding added

18. Dr. Goetz’s Conclusion “We should not just accept a statement that process “X” is an ILP without SUPPORTING EVIDENCE.”

19. AIA Definition • “Industry Leading Practices and Best Practices are methods, processes, or practices about which one or more of the following pertain: • It produces desired results; • It leads to exceptional performance; • It is recognized by an industry expert or group of industry experts; • It is deemed so by an organization's customers; and/or • It is clearly a new or innovative use of personnel, resources, or technology.”

20. Apologies to AIA(If I was Them, I’d Try This Too) • It produces desired results; [It works] • It leads to exceptional performance; [It works well] • It is recognized by an industry expert or group of industry experts; [Somebody likes it] • It is deemed so by an organization's customers; and/or [Works for customers] • It is clearly a new or innovative use of personnel, resources, or technology.” [New]

21. Why? FAR 52.245-1 presents a choice between two alternatives (VCSs and IPLs) IPL is not defined anywhere Therefore the path of least resistance (and most autonomy) is to define ILP in a way that works best for the person offering the definition Result – the lowest possible threshold Goal – successful audits

22. Where We Are Now… So, a contractor needs to do one or the other or both. What’s the easiest thing to do? What you’re already doing! So, use ILPs rather than VCSs, and you’ve met the FAR requirement. All you have to do is justify (current) practice as “Industry Leading Practice”!

23. IOW,… Business as usual? Is this a good thing? How do you sell your management on doing it better when you can get by doing less? Stay out of trouble or contribute to the success of the organization? Compliance or excellence?

24. Conclusions • VCSs • Widely used, understood, and recognized • Provide “certainty” • Use is easily defensible • ILPs • Little or no agreement • What makes it an ILP? A “story”. (IOW, explanation required) • Ultimately, not any different than,… • “This is the way we do it.”?

25. Thank you! Jim Dieter Sunflower Systems

26. Just in case anyone wants to think about this even more…

27. What About “Best Practice”? “A best practice is a technique, method, process, activity, incentive, or reward that is believed to be more effective at delivering a particular outcome than any other technique, method, process, etc. when applied to a particular condition or circumstance.“ (Wikipedia)

28. Best Practices • “A given best practice is only applicable to particular condition or circumstance and may have to be modified or adapted for similar circumstances. • In addition, a "best" practice can evolve to become better as improvements are discovered.” (Wikipedia)

29. Best Practices – Another Definition “Methods and techniques that have consistently shown results superior than those achieved with other means, and which are used as benchmarks to strive for. There is, however, no practice that is best for everyone or in every situation, and no best practice remains best for very long as people keep on finding better ways of doing things.” (BusinessDictionary.com)

30. Leading Practice “Term used in place of best practice where it is inordinately difficult to identify or implement the best practice.” (BusinessDictionary.com) IOW, “Leading Practice” <“Best Practice”