Tuesday, December 9, 2008

More comments on TM0497

After reviewing the TM0497 reaffirmation ballot changes to that document and after thinking about this over the weekend, I am now strongly leaning towards voting negative and at that same time sending a ballot nullification/disqualification request e-mail, with my reasons for that stance (i.e., technical not editorial revisions, etc.), to the NACE STG 05 Technology Coordinator, STG 05 Chair, and TG 020 Chair (see links below). A point that was stated noting that NACE really does not want TM0497 withdrawn is a very good point. There is also a good chance, in this case, that NACE will immediately start rewriting TM0497 no matter which way the vote goes. I agree that the best outcome would be to have TM0497 reaffirmed as originally/currently written (under a new/second reaffirmation balloting process) – not with the changes made just prior to this first balloting process, at least a portion of which I now believe need to be nullified/disqualified. If enough folks vote negative, NACE will be in a difficult position and will most likely want to either go completely back to the original wording or will want to otherwise negotiate to make allowances for everyone’s concerns.

http://web.nace.org/Departments/Technical/Directory/Committee.aspx?id=e1dc32a6-5fef-db11-9194-0017a4466950

Information from NACE Technical Committee Publicaitons Manual

From NACE Technical Committee Publications Manual:


2.3 For the purposes of determining the type of revisions made to a document or draft document, and thereby determining whether a revision requires ballot, reaffirmation, etc., the following definitions shall be used:

2.3.1 Technical revision—A revision that impacts (a) the systematic procedure by which a complex or scientific task is accomplished using the document or (b) the conclusions reached after using the document.

2.3.2 Editorial revision—A revision intended to make the document suitable for publication without altering the technical intent of any portion of the document. The revision is usually grammatical, typographical, or explanatory in nature or is a revision to the document’s format.

2.3.3 Major (technical or editorial) revision—Extensive, numerous, or any revision(s) that alter the substance or intent of a document.

2.3.4 Minor (technical or editorial) revision—A few specific revisions that do not alter the substance or intent of a document. To be adopted, all technical changes must be balloted.


3.9.5.5 The letter ballot shall provide for three types of votes:

3.9.5.5.1 Affirmative. The voter may note perceived editorial errors and their corrections.

3.9.5.5.2 Negative. The voter should show a perceived technical inaccuracy or omission in the draft standard or address points dealing with perceived ambiguity or a lack of clarity that result in perception of a technical inaccuracy.

3.9.5.5.2.1 A negative must be accompanied by a written comment (relevant to the portion of the document being balloted), preferably including technical explanation and justification.

3.9.5.5.2.2 A negative must include a suggested revision or action that would serve to resolve the negative.

3.9.5.5.2.3 Votes received that do not meet these criteria shall be handled in accordance with Paragraph 3.9.8.6.

3.9.5.5.2.4 The Task Group is not required to consider negative votes (1) without comments or (2) accompanied by comments not related to the proposal under consideration, i.e., the revisions or draft being balloted. Such votes shall be recorded as “negative without comments” without further notice to the voter. Comments shall not be solicited from the voter, and such votes shall not be recirculated to the STG(s).


3.9.5.6 Votes not meeting any one of the following criteria shall not be accepted:

3.9.5.6.1 The vote must be signed; however, if the ballot was sent to the voter via a personal e-mail address, or if the voter has a personal e-mail address registered with Headquarters, the vote may be submitted and accepted via e-mail from that e-mail address. A personal e-mail address is one that is accessible to an identified individual. A group e-mail address is accessible to two or more people. Online votes must be properly submitted using a member number or password set up within the NACE online voting system.

3.9.5.6.2 The vote must be returned by the deadline stated on the ballot or, in the case of a Headquarters-issued deadline extension, by the extended deadline.

3.16.1 Minor editorial changes may be made at any time when the intent and/or technical content of the standard (or section thereof) is not changed. Examples of minor editorial changes would be items such as:

3.16.1.1 Correcting typographical errors in text or data.

3.16.1.2 Changes in product designations that are not a result of changes in the composition of the product that was included in the approved standard.

3.16.1.3 Additions required when an item that requires a “note” or “caution” because of safety conditions or changes in safety or environmental considerations is discovered.


3.16.3.1 Negatives cast against proposed major editorial revisions must provide an explanation of the perceived editorial inaccuracy and a suggested revision or action that would serve to resolve the negative

3.16.4 Editorial changes (excluding minor typographical errors) should be published immediately in Materials Performance and an errata sheet added to all copies of the document sold until it is reprinted.


3.17.3 Reaffirmation

3.17.3.1 If a standard is to be reaffirmed in its existing form or requires only minor editorial changes, the proposal to reaffirm (or to reaffirm with editorial changes) shall be distributed in the same manner as described in Specific Technology Group Review and Approval (Paragraph 3.9) for reaffirmation approval with a four-week deadline for letter ballot response. Concurrently, the proposed reaffirmed standard shall be distributed to RPC for editorial review.


3.17.3.3 If the standard is not reaffirmed by two-thirds (2/3) of all the sponsoring STG members, excluding abstentions, in either a written or meeting ballot, the standard shall be considered in need of revision or withdrawal.


3.17.4.1.1 If technical changes to a standard are proposed, they shall be substantiated with technical information by the submitter. Such documentation should be retained in the Task Group’s files.


3.17.5.5.3.1 RPC shall serve as the final arbiter when determining whether revisions are editorial or technical.


3.17.5.7.1 Minor technical revisions to NACE standards do not require ratification by the Board of Directors.



12 APPEALS PROCESS FOR ALLEGED PROCEDURAL INFRACTION

12.1 Persons who have directly and materially affected interests and who have been or may be adversely affected by a substantive or procedural action or inaction of NACE with regard to the development of a proposed standard or report, or the revision, reaffirmation, or withdrawal of an existing standard or report shall have the right to appeal the alleged procedural infraction. He/she should notify in writing the TCC chair and Headquarters, with copies to the Technology Coordinator, sponsoring STG chairs, and Task Group chair.

12.1.1 The written notification shall contain all substantiation of the perceived infraction and clearly state the portion(s) of the Technical Committee Publications Manual and/or NACE policies that was (were) alleged violated.

12.1.2 Headquarters must receive the notification within four weeks of the perceived infraction.

12.1.3 The notice must contain only perceived procedural infractions.

12.1.4 Procedural appeals include whether a technical appeal was afforded due process.

Monday, December 8, 2008

More Comments on TM0497

Either way can have a negative outcome

If we vote negative because of the changes, it can allow NACE to start immediately revising TM0497 based on the current proposed/revised SP0169 (since TM0497 was not reaffirmed), which I believe will completely remove the -850 mV “On” criterion from the picture (both from SP0169 & from TM0497). If we vote affirmative, then the potentially detrimental (weakening) changes will go forward. However, there will be a longer (lag) time, before any further revisions are made to TM0497, while they wait on the results of the SP0169 balloting process. At least reasonable portions of the -850 mV “On” criterion approach will remain in TM0497 for a time.

I haven’t completely thought it all through yet. At first glance at this moment, I would have a tendency to vote affirmative and then send NACE a note/letter stating that I believe the changes and the balloting were inappropriate, noting that I believe part of the changes constituted technical, not editorial, changes and, therefore, the whole voting/balloting process should be nullified/discarded.

More Comment on TM0497

Question:
If we vote "Affirmative", are we agreeing with the changes they are proposing to TM0497?

Should we vote "negative" and try to keep the original document without the proposed changes?

I didn't completely understand the comments on the blog. Is that person saying to vote negative?

I have already submitted my vote, but it appears that it will let you change your vote. I would guess that you can change it until Dec. 9.

Other comments on TM0497

I couldn’t disagree more.



There are subtle but significant changes to TM0497 that weaken this document and constitute technical not editorial changes. NACE by-laws do not allow reaffirmation of standards if technical changes have been made.



I have requested that NACE suspend balloting and am awaiting a decision on this matter.



Some have requested that NACE postpone any changes to TM0497 until SP0169 is resolved. I support this effort, as the documents are complimentary. If TM0497 is to be reaffirmed, it should be done without changes in the same manner that SP0169 was reaffirmed.

Jim Chmilar comments

Richard, IF you do not agree with the “document as is” then I do not understand how you can vote to re-affirm?

I, myself believe the document needs to be improved TODAY and will be voting to not re-affirm it, because it needs additional information on measurement techniques and that does not depend on the state of SP0169.

The present draft version of the revisions to SP0169 (which is still in TG 360 committee draft stage as everyone knows) I believe does expand the criteria to include the new one that some are proposing, ie a potential valve of –850 mV without consideration or correction for IR drop. Please read all of section 6.2.3.1 which includes a listing of FOUR criteria in 6.2.3.1.1 to 6.2.3.1.4 and in particular 6.2.3.1.3 which is proposed to say “Criteria that have been shown to successfully control corrosion on piping systems can continue to be used on those piping systems” and 6.2.3.1.4 “Other criteria that can be demonstrated to achieve the corrosion control objectives of the operator.” Do these two criteria not allow all those who have been using 850 ON without any correction, or 300 Millivolt shift, or E log I to be in-compliance with the standard?? No need to answer this now, I am sure I will be hearing it when the SP0169 ballot comes out.



It is time for well wishes and hope everybody enjoys the coming Christmas Season.

Cheers

Jim Chmilar