Ballots, call for comments, contributions : how to write good contributions ?
Contributing to standardization can feel overwhelming at first. Whether you’re spotting a mistake, clarifying ambiguous wording, or proposing a new approach, there is a way to turn your insights into actionable contributions.
Contributions can come in multiple shapes, but we can identify 2 main types : Comments and Contributions.
1) Ballots and Comments
First, identify the types of ballots :
Approval ballots (PWI, NWIP, ENQ, FV)
- Purpose: Vote to approve or reject a draft standard at key stages.
- Your role: Approve, disapprove, or abstain. Justify your vote, especially if you disapprove. Provide clear, actionable comments on technical content, structure, or wording.
- How ? : use your NSB’s portal to comment and vote.
Calls for comments (1st WD, 2nd WD)
- Purpose: Gather feedback on draft standards before final approval.
- Your role : Provide clear, actionable comments on technical content, structure, or wording.
- How ? : use your NSB’s portal to comment and vote.
Generally : deadlines are strict, and missing them means your feedback might not be taken into account.
What is a comment ?
Commenting in standardization is now done on OSD, a tool that helps working groups work collaborate online. Typically, a comment has :
- a clause and/or a line number : so we know to which part you are referring (be as precise as possible)
- a type : editorial (when you spot a spelling mistake), technical (when your comment changes the meaning of a sentence), general (when you address a problem that occurs in the whole standard)
- a comment : short, clear sentences that describe the problem
- a proposed change (optional, but strongly recommended if you’d like your comment to be taken into account) : wording that fits into the text, that fixes the problem addressed in the comment.
How can you improve your comments ?
1) Start with some context :
Your comments are read by other experts and project leaders that do not necessarily share your background, your sector’s challenges or even your precise area of expertise. When you have a technical objection to a clause, it is important that you provide in your comment enough context so that your readers can understand your point of view.
Also, indicate the source of your rationale if applicable (other standards, research papers…).
2) Be precise :
State very precisely the sentence that bothers you, using the line-numbering of the documents. The more precise, the less time project leaders and other experts will lose time trying to locate your comment. Reference exact sections, tables, or clauses in the draft that you object to.
3) Actionable, when relevant :
A comment that points out a problem and offers a solution (“proposed change”), even partial or imperfect, will be more welcomed than a comment that just leaves the work to the project leaders. A solution can take the shape of :
- “Delete sentence XXX”
- “Replace Should with Shall”
- “Move clause A to the Annex”
But also can propose new text : “Delete XXX and add ‘YYYY'”
Even imperfect wordings can strike a discussion!
4) Aim for consensus :
This general piece of advice in standardisation can sound vague to a new standardisation expert. Aiming for consensus means that your comment and your solution can relate to the most of the stakeholders of the standard. For example, referencing existing and widely used standards can be a way to aim for consensus. Also, this means thinking about different types of organizations (associations, SMEs…), different sectors and imagining a solution that is flexible enough to be adapted to a number of situations.
“The human-oversight section is unclear.” ⇒ “In Clause 6.2, the term ‘encryption key’ is ambiguous. “symmetric encryption key” is used in EN 12345 and is more precise.
Proposed change : replace line 123 with ‘The organisation shall use a symmetric encryption key’ .”
5) Be present :
Your comments will be processed during a Comments Resolution Meeting. Your presence to these meetings is a very good way to defend your position and explain to other experts your point of view. You can also address directly their questions. To be sure to attend, monitor closely the agendas of your WG.
What happens to the comments I submit through my mirror committee?
Comments from mirror committees are compiled and sent to the project leader once the comment phase is over. The project leader reviews all comments and starts a comments resolution meeting (CRM) phase, where each comment receives a response: “Accepted”, “Rejected”, “Noted”, or “OBE” (overtaken by events). During these meetings, the project leader may:
- Discuss comments directly.
- Prepare a “Proposed disposition of comments” (PDoC) file, associating each comment with a proposed response. These responses can be debated by sending a reconsideration request to the project leader. It is strongly recommended to attend comment resolution meetings to defend your comments or explain your position to national experts present.
- A Reconsideration request is basically a comment of a comment. It has the same structure. You first refer to the exact comment that you would like to be reconsidered, then explain why the rationale provided by the Project leader is wrong, or misses the point, and provide additional information on why the conclusion of the Project leader should change.
2) Contributions
A contribution is any form of input that is given by experts to the Project Leader during drafting stages (after NWIP, after WD, after Enq).
Commonly used structure
Even though there is no formal template to contribute to a standard, an effective contribution usually consists of a text document that has the following sections :
1) Title : should be precise on the purpose of the contribution
ex : Contribution on fundamental rights on AI Risk Management
2) An author (or a group of authors) and their affiliation
ex : A. Durand (AFNOR) and L. Doe (BSI)
3) A short introduction describing the problem with the draft
ex : The current draft overlooks the identification of the fundamental rights…
4) A rationale that describes your point of view
ex : In a high-risk context, we believe that the provider is responsible for addressing the risks linked to fundamental rights…
5) A proposed change that can be directly incorporated
ex : Replace Clause 6.1 by “The provider shall incorporate fundamental rights impact analysis in the risk management document….”
How to send your contribution ?
Once your contribution is written, you should send the editable document to the Secretary, Convenor and Project Leader by email. The Secretary or Convenor will make it publicly available in the CEN Portal and it will be attributed an identification number, for example N123 (we call this : “to NDoc a contribution”).
Your contribution needs to be published in the portal, so that other members of the working group can review it. A discussion on your contribution should then be scheduled on the agenda for the next meeting.
A few tips:
- Share draft contributions with colleagues (from your National Committee or the Working Group) to get feedback before submitting,
- Share real-life examples from your industry to support your opinions,
- Referencing other relevant published standards might strengthen your contribution,
- If relevant, you can offer different options as proposed changes
- Follow the drafting rules : view the Drafting rules for standardisation article
- Send your contribution in advance of the next meeting, to give both the project leader and the other members time to review it
- Be available at the meeting where your contribution is discussed to present it and defend your position to the other members
➡️ Here are 2 quick quizzes to assess your understanding of this article : first steps in standardisation and writing standards for beginners
➡️ For advanced users, here is a quiz to assess your understanding of standardisation : writing standards – advanced