Why consensus on standards & performance matters in commercial space
The development of standards may seem like a dry topic, but it also is crucial for any industry that wants to be safe and effective as it matures.
Before the railroad industry implemented gauge standards, cargo traveling between regions would have to be unloaded and moved to different trains when they entered a new area because the distance between rails no longer matched the size of the wheels of the train. From steel, to clothing, to cars, to pharmaceuticals, standards are a vital part of the growth and development of industries across the globe. This is already true for the burgeoning industry of commercial space.
For many years, the Commercial Spaceflight Federation (CSF) and the Commercial Space Transportation Advisory Committee (COMSTAC) have recognized the importance of developing industry voluntary consensus standards. A particular focus of standards and recommended practices was, and still is, human spaceflight safety.
Voluntary consensus standards are developed or adopted by a voluntary consensus standards body. A voluntary consensus standards body is a domestic or international organization that plans, develops, establishes, or coordinates voluntary consensus standards using agreed-upon procedures. Such a body is defined by openness, balance of interest, due process, an appeals process and consensus. Moreover, such standards comply with U.S. Office of Management and Budget Circular 119-A and National Technology Transfer Advancement Act guidelines and are the Federal Aviation Administration’s preferred means of compliance for the streamlining of existing or enacting new regulations.
Originally, CSF attempted to draft these documents on our own, with some success, but quickly realized that we needed to open up the process to make them truly consensus standards and a potential basis for future licensing or regulation. We also wanted to ensure participation from government stakeholders and entities outside of CSF.
After several attempts to produce these standards, first in-house, and then with external entities called Standards Development Organizations (SDOs) that professionally facilitate the standard writing process, in late 2016 CSF joined forces with ASTM International to stand up its Committee on Commercial Spaceflight F47. With over 12,000 standards in effect, as well as successful committees in areas touching commercial space (e.g., Additive Manufacturing, Aerospace & Aircraft) industry participants saw ASTM as the optimal SDO for such an endeavor. The collaboration was solidified, and the first official meeting of the technical committee was held in April 2017.
As of today, the committee has active participation and support from multiple industry voices, including non-CSF companies (e.g., Boeing, United Launch Alliance, academia (e.g., FAA’s Center of Excellence on Commercial Space Transportation and several universities), and government (e.g., FAA, NASA). Industry members include operators, spaceports, suppliers, general interest groups and consumers. Together, we consistently discuss how to better inform our ranks and expand F47’s membership to ensure that all relevant players are part of the conversation and standards development effort.
F47 has four industry-specific subcommittees that address various sub-sectors of the commercial space business: unmanned vehicles, spaceports, and human suborbital and orbital spaceflight. Work within the subcommittees is currently focusing on seven specific topics that are in various states of development. Four are still in the “Task Group” phase, meaning the topic area is being researched and discussed to better identify how to move forward to produce a relevant standard. Three are in draft standard form and continue to evolve in both content and form in preparation for the balloting process. In February 2019, F47 published its first standard, Standard Guide for Storage, Use, and Handling of Liquid Rocket Propellants. The standard was developed by the subcommittee on spaceports.
The choice of topics is driven by multiple factors. Within F47 there is a committee on road mapping that aims to develop the best path forward and the areas of most urgent need for standards. To form a task group, a member of F47 must be willing to take the reins and lead the effort. As the committee continues to grow in membership and participation, so will the road-mapping efforts and the breadth of topics that we are able to address.
It is a sign of commercial space’s success that there are multiple standards efforts popping up. Among these are qualified Standards Development Organizations compliant with the Office Management and Budget and National Technology Transfer Advancement Act guidance, notably SAE International, the American Institute of Aeronautics and Astronautics, the National Fire Protection Association, and others.
And there are organizations such as the International Association for the Advancement of Space Safety, who do not necessarily follow established voluntary consensus standards process necessary to be used as an FAA means of compliance. CSF and ASTM are currently in the process of compiling a global directory of SDOs, and will hold a summit to bring the relevant players together to discuss what has already been accomplished, what is currently being worked, and the best way to move forward efficiently and effectively.
Safety is of the utmost importance to the CSF, COMSTAC, and the members of ASTM F47. We are all working on standards to ensure that our industry is as safe as possible, even as we undertake inherently risky activities. For that reason, we have some concern about the risks of too many fragmented and potentially conflicting standards development efforts.
First, multiple, disjointed efforts could result in conflicting approaches, as well as duplication and attendant increased workload for all parties. We believe it is best to bring all players around one table to have an inclusive discussion so that everyone’s expertise and actual experience can be considered together.
Second, not all SDOs are in agreement about general standards parameters. We strongly believe that standards developed should be focused on creating the safest environment possible, need to be performance-based, and must represent an industry consensus.
Most entities are in agreement that safety is of the utmost importance when developing standards, but these last two considerations — that standards be performance-based and use industry consensus processes — are not always agreed upon.
Many historical standards provide requirements on what levels of safety need to be incorporated, but also how to achieve those requirements. Now, with the rapid emergence of new technologies, designs and concepts of operations, we must focus on the end result of safety, while allowing industry to pursue inventive ways of meeting standard requirements.
The U.S. commercial space industry is populated by bright and creative thinkers, and they are constantly innovating ways to improve upon traditional methods and procedures. Performance-based standards will always require the agreed upon level of safety to be met, but will have the added benefit of providing these safe outcomes in new and innovative ways, thereby increasing efficiency. By embracing flexibility in technological approach, they will ensure industry remains thriving and dynamic, rather than becoming static and bogged down in old approaches.
But perhaps the most important requirement for commercial space standards is that they reflect an industry consensus. IAASS and SAE recently published a document jointly with the designation of “standard” that had no input from commercial space companies. It was largely derived from the work of safety professionals, experienced in legacy programs in large government organizations. Although there are many good historical lessons we can learn from previous government missions and agencies, it is imperative that today’s standards reflect the newer ideas and innovations of companies actually trying to solve today’s problems … today and tomorrow.
Today’s space industry is more diverse and entrepreneurial than most historical programs and organizations, and we are trying to go further and faster. The established industry consensus process gives consumers their just voice, along with producers and suppliers. The industry consensus process is also a requirement for the FAA to adopt the document as means of compliance for licensing, regulation or both. Any responsible standards effort requires that today’s professionals from throughout industry help create, and therefore collectively “own,” the standards they are developing.
Overall, COMSTAC, CSF, and ASTM F47 are dedicated to ensuring a commercial space industry that is safety focused, forward thinking, and a world leader in technology and achievement. We believe that the efforts within ASTM F47 are moving us, slowly but surely, in the appropriate direction, and we are dedicated to ensuring the relevant voices are included in these discussions and efforts.
MICHAEL LOPEZ-ALEGRIA CHAIRS THE ASTM F47 COMMERCIAL SPACEFLIGHT COMMITTEE. JANE KINNEY IS CSF’S DIRECTOR OF BUSINESS OPERATIONS. OSCAR S. GARCIA IS S47 MEMBERSHIP SECRETARY.
Interested parties are encourgaged to join in the discussion by attending meetings or joining ASTM. An in-person meeting of the F47 committee was held April 12 in Colorado Springs in conjunction with the 35th Space Symposium. Contact Jane Kinney ([email protected]) and Oscar Garcia ([email protected]). Further information can also be found www.astm.org.