Clarification of rules when incorporating NIAP interps

[Tom Benkart <teb@coact.com>]

NIAP interps are considered recommended but not required.  This policy does 
not clearly state the rules by which the labs should evaluate PPs/STs when 
they include NIAP interps.  Hopefully the following questions clarify the 
issues - they all assume at least 1 NIAP interp is included in the PP/ST.

1. Is the PP/ST author required to incorporate relevant all NIAP interps as 
of a specified date (presumably the date of the kick-off meeting), similar 
to the requirement for international interps?

2. If the author is free to pick and choose individual NIAP interps (i.e., 
the answer to question 1 is no), is it permissible to reference a NIAP 
interp that has been superseded by another NIAP interp?  The time required 
to produce the document may be lengthy (especially for PPs), and the 
superseding may occur long after the author finished specifying the SFRs.

3. The specific instance prompting this email is inclusion of 
FAU_GEN.1.2-NIAP-0410.  NIAP-0347 relabels this SFR as 
FAU_GEN.1.2-NIAP-0347, in effect superseding just a part of NIAP-0410.  Is 
it Ok to still identify the SFR as FAU_GEN.1.2-NIAP-0410, or is it required 
to reference the more recent NIAP interp affecting that SFR?  A further 
complication is that NIAP-0347 does not supersede NIAP-0410, since 
NIAP-0347 only addresses a subset of the SFRs addressed by NIAP-0410.  One 
can argue that NIAP-0347 is flawed and should be redone so that NIAP-0410 
could be superseded, but that is not an immediate solution.

I favor a simple rule - if any NIAP interps are incorporated into a PP/ST, 
then the author must incorporate all relevant NIAP interps as of the date 
of the kick-off meeting.

Tom

Tom Benkart
Lab Manager
COACT, Inc.
9140 Guilford Road, Suite G
Columbia, MD. 21046
301-498-0150
Fax: 301-498-0855
teb@coact.com