ANSI D20 REVIEW 1 SUMMARY 2 CHALLENGES OF SUPPORTING OF ANSI D20 STANDARD. Contents

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1 ANSI D20 REVIEW Contents 1 Summary Challenges of Supporting of ANSI D20 Standard Proposals Users of D DOT Requirements Legal References to D Other References to D Adendum of References Highway Safety Act ANSI Withdrawal Process SUMMARY Discussions about keeping the American National Standards Institute (ANSI) accreditation for the D20 Traffic Records Systems Data Dictionary and maintaining Accident/Crash and Roadway elements. 2 CHALLENGES OF SUPPORTING OF ANSI D20 STANDARD When D20 was first established, the ANSI process for developing standards through consensus was selected. The ANSI name not only provided a respected label, but also provided a mechanism for creating a standard that supports data definitions used across industry, federal and jurisdictional organizations. There are a number of challenges with the current D20 maintenance process: 1. The ANSI procedures require any changes to an ANSI standard to be an open to public comment. Due to the required duration of the review periods, this often takes months to complete. This means D20 often lags behind the definitions currently in use. 2. Gathering a consensus body to review D20 changes is also a challenge. Subject matter experts are busy people and have difficulty committing their time to a review. 3. In addition, subject matter experts will often already have reviewed the changes because the changes to D20 come from changes to applications and they will already reviewed the application changes. (Finding volunteers to repeat review work is hard). AAMVA ANSI D Status 1

2 4. The majority of D20 changes come from application changes supported by AAMVA. A change will be proposed, reviewed, and accepted into an application. That same change is later proposed to D20. At the time of the D20 review, it is too late to make a change to the application, so feedback from the D20 review is unlikely to be incorporated. In effect, the D20 effort is a review of editing in the application changes, rather than a review of the content. 5. AAMVA is aware of changes in the Driver and Vehicle areas, but is not aware of any changes Accident/Crash or Roadway areas. This is because AAMVA supports applications exchanging driver and vehicle data, but does not support Accident/Crash and Roadway applications. Consequently, D20 has not been receiving requests to revise the Accident/Crash or Roadway areas. The result is that the Accident/Crash and Roadway areas have a number of out-of-date definitions in D The standard maintainer of D20 must spend significant time and effort to manage the reviews and the publication of a new standard, and must find time when resources are available to work on a new edition. This can lead to delays in publishing a new edition. 3 PROPOSALS Towards improving the accuracy of the D20 standard and improving the review process, AAMVA proposes the following: 1. Continue publishing a Data Element Dictionary. 2. Discontinue accreditation of the ANSI D20 dictionary. This would reduce maintenance costs and allow updates to be incorporated in a more timely manner. (The process for dropping the accreditation is listed in the Addendum). 3. Focus on areas where AAMVA has subject matter expertise (Driver and Vehicle areas) and not include other areas (Accident/Crash and Roadway areas). The areas being considered for removal would be covered by other standards (ANSI-D16 and MMUCC). The following sections address questions and concerns about the proposals. 4 USERS OF D20 D20 has to support the needs of its users. AAMVA will verify the changes being proposed satisfy the needs of the users. AAMVA is asking users of D20 if there are any objections to the proposal. AAMVA will use its notifications to inform its membership through the following means: The Week in Review newsletter The AAMVA web page D20 distribution lists 2 AAMVA ANSI D Status

3 The Association of Transportation Safety Information Professionals (ATSIP) will also notify its membership of the proposal and ask if there are any objections. These proposals can only be enacted if there are no objections from current D20 users. 5 DOT REQUIREMENTS The need for the D20 Data Element Dictionary for Traffics Records Systems was created by the U.S. Federal Highway Safety Act of 1966, which required states receiving federal highway safety funds to develop better systems for collecting and processing data to be used in operating safety programs. Traffic records in this context refer to records related to motor vehicle registration, driver licensing, highway design and operations, accidents, financial responsibility, motor vehicle inspection, commercial vehicle reciprocity, traffic law enforcement, emergency medical services, etc. Under AAMVA s leadership, several hundred persons from more than eighty public and private organizations participated on a D20 Parent Committee to compile the dictionary. With funding and computer services provided by the National Highway Transportation Safey Administration (NHTSA) and the Federal Highway Administration (FHWA), the D20 Parent Committee in 1979 issued the first edition of the dictionary as American National Standard (ANSI) D The Act and the rules still stand, but currently the model inventory of roadway elements is supported by other means. The Traffic Record Coordinating Committee (comprised of the Federal Motor Carrier Saftey Administration [FMCSA], NHTSA and FHWA) has confirmed that the U.S. Department of Transportation (DOT) no longer has a requirement for ANSI D20. Instead, they now use ANSI D16 terminology definitions and the Model Minimum Uniform Crash Criteria Guideline (MMUCC) element definitions. 6 LEGAL REFERENCES TO D20 There do not appear to be any explicit legal references to ANSI-D20. So ANSI-D20 does not need to be maintained to support any rules. At one point, D20 was explicitly referenced in a Federal Regulation (FR) 23 CFR used to reference ANSI-D , but it has since been changed to violations exchange code and avoids specifying a specific document. There was a question about the possibility of jurisdictions having legal references to ANSI-D20. Direct searches through Westlaw for ANSI D20, ANSI-D20, (ANSI) D20, and (ANSI)-D20 found no results in the following databases: Westlaw Combined Bill and Regulation Tracking State & Federal Summaries, Status, & Full Text Westlaw Combined Bill and Regulation Tracking State and Federal Summaries and Status Westlaw Federal Bill and Regulation Tracking US Bill Tracking Westlaw Federal Statutes and Regulations USCA (U.S. Code Annotated) Westlaw Federal Statutes and Regulations U.S. Public Laws Westlaw Federal Statutes and Regulations CFR (Code of Federal Regulations) Westlaw State Bill Tracking ALL STATES Westlaw State Regulation Tracking ALL STATES Westlaw State Statutes Statutes - ALL STATES AAMVA ANSI D Status 3

4 Westlaw State Regulations State Administrative Codes ALL STATES 7 OTHER REFERENCES TO D20 D20 is referenced in other standards and best practices. They include the following: AAMVA Best Practices i.e., the DL/ID Card Standards references element code values The National Information Exchange Model (NIEM), which contains an ANSI-D20 name space If D20 is no longer an ANSI standard, these artifacts will have to stop using the ANSI name. Requests will be submitted and the name will be dropped in future releases. 4 AAMVA ANSI D Status

5 8 ADDENDUM OF REFERENCES The following are rules and regulations that are associated with D ANSI D20 WITHDRAWAL PROCESS ANSI D20 is governed by the ANSI-D20 procedures, they make provision for dropping the ANSI accreditation: Proposals to revise, reaffirm, or withdraw approval of D20 shall be transmitted to ANSI using the BSR-8 form, or its equivalent, for listing in Standards Action in order to provide an opportunity for public comment. The comment period shall be a minimum of 45 calendar days (or 60 days if the document is not available electronically) if the full text of the revision(s) can be published in Standards Action. (Proposals for new standards shall use the same protocol). The BSR-8 form, (which is available online at must be submitted by AAMVA to ANSI. 8.2 HIGHWAY SAFETY ACT The following is an excerpt from the Federal Regulation 23 U.S. Code 402. Within section 402, subsection (b)(1)(f) states: (F) provide satisfactory assurances that the State will implement activities in support of national highway safety goals to reduce motor vehicle related fatalities that also reflect the primary data-related crash factors within a State as identified by the State highway safety planning process, including (v) ensuring that the State will coordinate its highway safety plan, data collection, and information systems with the State strategic highway safety plan (as defined in section 148(a)) The referenced section 148 (a) says: (a) Definitions. In this section, the following definitions apply: (5) Model inventory of roadway elements. The term model inventory of roadway elements means the listing and standardized coding by the Federal Highway Administration of roadway and traffic data elements critical to safety management, analysis, and decision making. (9) Safety data. (A) In general. The term safety data means crash, roadway, and traffic data on a public road. (B) Inclusion. The term safety data includes, in the case of a railway-highway grade AAMVA ANSI D Status 5

6 crossing, the characteristics of highway and train traffic, licensing, and vehicle data. (f) Data Improvement. (1) Definition of data improvement activities. In this subsection, the following definitions apply: (A) In general. The term data improvement activities means a project or activity to further the capacity of a State to make more informed and effective safety infrastructure investment decisions. (B) Inclusions. The term data improvement activities includes a project or activity (i) to create, update, or enhance a highway basemap of all public roads in a State; (ii) to collect safety data, including data identified as part of the model inventory for roadway elements, for creation of or use on a highway basemap of all public roads in a State; (iii) to store and maintain safety data in an electronic manner; (iv) to develop analytical processes for safety data elements; (v) to acquire and implement roadway safety analysis tools; and (vi) to support the collection, maintenance, and sharing of safety data on all public roads and related systems associated with the analytical usage of that data. (2) Model inventory of roadway elements. The Secretary shall (A) establish a subset of the model inventory of roadway elements that are useful for the inventory of roadway safety; and (B) ensure that States adopt and use the subset to improve data collection. 6 AAMVA ANSI D Status