Re: CC request for interpretation: testing while in normal mode?

["NIAP Interpretations Board" <ccevs-nib@nist.gov>]

The NIB engaged in considerable discussion about the points raised in the 
original communication and in the follow-on barrage of email.  We will not 
attempt to deal with every point, but do have a few statements to make to 
bring some sort of closure to parts of the debate.  

First, we also would agree that a definition of "TSF" would be very helpful to 
the CC community.  Accordingly we will work to clarify this through NIAP 
interpretation process, which will result in a submission to the CCIMB for 
international concurrence.  

Second, it is premature to draw any conclusions from the actions (or lack 
thereof) of the foreign labs.  Various attributes have been ascribed to the labs 
that are not necessarily correct or consistent.  There are differences between 
how our scheme operates and how their schemes operate.  In particular, the 
mechanisms to ensure consistency, both internal to those schemes and in 
their external interactions, differ for each nation.  Hopefully, all the schemes 
will become more consistent as time goes on.  

Last, while the NIB has no written charter as of yet, one of its goals will be 
"not to raise the bar"; which is to say, not interpreting the requirements to be 
stronger or more restrictive than intended.