\|/ William R. Simpson
@ @
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Dr. William R.
Simpson
Institute for Defense Analyses
703-845-6637
4850 Mark Center Drive
fax
703-845-6848
Alexandria, VA 22311-1882
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-----Original Message-----
From: Arnold, James L. Jr. [mailto:JAMES.L.ARNOLD.JR@saic.com]
Sent: Tuesday, March 02, 2004 9:42 AM
To: Multiple recipients of list
Subject: Minor RI Issues (#3, #4, & #38)I want to point out a couple relatively minor issues I have come across in the course of applying international interpretations.
RI#4 was finalized 11/12/2001 and RI#38 was finalized 10/31/2003. However, RI#38 indicates that the text as a minimum is to be removed from ACM_SCP.*.1C while RI#4 restated those requirement previously for another purpose and that text was incidentally removed. Hence, this aspect of RI#38 seemed to have been overcome by events. Note that examples such as this (and the conflict between final #141 and draft #178 that I also recently identified) make me wonder whether the CCIMB is working against the base CC rather than the internationally interpreted version.
Another issue is found within RI#3. That interpretation indicates that the CEM is to be modified as follows:
1. A new action is inserted after paragraphs 659, 938 and work unit ACM_CAP.4-6, corresponding to the new element.
2. The text of the current work units ACM_CAP.2-7, ACM_CAP.3-8 and ACM_CAP.4-9 (and their supporting guidance text) are moved below this new action.
3. The text of the current work units ACM_CAP.2-7, ACM_CAP.3-8 and ACM_CAP.4-9 are replaced with the following:
"The evaluator shall examine the configuration items to determine that they are identified in a way that is consistent with the CM documentation."
As far as I can tell, an alternate procedure to get the same result would be to insert the action per 1, delete the work units identified in 2, and insert the new work unit defined in 3. Basically, 2 says to move a current work unit and then 3 says to replace the current work unit. So, unless the definition of move means to copy, it seems the original work unit is lost. Note that I dont think this is what was intended.
Basically, I think both of these issues may be indicative of a problem with the presentation of international interpretations in general. Specifically, it is not clear that describing an algorithm for changing the text is better than simply presenting the resulting text. Leaving it to those who apply interpretations could increase the potential for misapplication of interpretations.
Also, I have previously challenged the national interpretation board with the problem of intersecting interpretations and as indicated above examples are starting to appear internationally. Hence, I recommend that the CCIMB should figure out how to avoid this problem (e.g., interpretations are to be applied in the order they are approved, future interpretations include are based on - all previous related interpretations, interpretations are carefully constructed so as not to overlap or conflict). Furthermore, it would be helpful to reviewers to understand any adopted model(s).