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Standards and Industry Leading Practices What to Know, What to Do January 13, 2010. Jim Dieter, CPPM CF Sunflower Systems Director of Strategic Programs. FAR 52.245-1.
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Jim Dieter, CPPM CF
Director of Strategic Programs
The National Technology Transfer and Advancement Act of 1995 (Public Law 104-119) and OMB Circular A-119, mandate the use of Voluntary Consensus Standards in lieu of Government-unique standards
Search results are all about us!
No definition, not even on Wiki
We made this up!!!
• “What is an Industry Leading Practice???
– There was and is no Statutory or Regulatory definition of Industry Leading Practice
– There is no “Official” FAR definition of an Industry Leading Practice
• Note – that is correct, even the Government does not define every term it uses in a regulation – as there are some terms that are ASSUMED to have a general meaning. In this presentation we will discover that the term Industry Leading Practice DOES NOT have a universal definition!
– In point of fact, after doing an exhaustive web search of the term it was discovered that the term is used most often as a “BUZZ WORD” in advertising to establish legitimacy for one’s application or product.
– So, since no “official” definition exists it is important to note that we can “BORROW” or appropriate from OTHER applications or bodies of knowledge.”
The government has no idea what this term means
• “Industry leading practices (ILP) are generally accepted processes, including best practices, that have been proven throughout related businesses, to be managerially and economically effective, efficient, and successful at meeting particular objectives of a contractor’s management system, and where specified, in compliance with the required Government Outcomes. The ILP should be based on empirical research, evidence and literature pertaining to that business practice, product or system as a “leading” practice. In order for a process to become an ILP, it should be widely used. Generally, there should be supporting historical data from an accepted source, e.g., trade publications, literature, etc., to support that process as being repeatable, efficient, measurable, and verifiable.”
* Bolding added
“We should not just accept a statement that process “X” is an ILP without SUPPORTING EVIDENCE.”
FAR 52.245-1 presents a choice between two alternatives (VCSs and IPLs)
IPL is not defined anywhere
Therefore the path of least resistance (and most autonomy) is to define ILP in a way that works best for the person offering the definition
Result – the lowest possible threshold
Goal – successful audits
So, a contractor needs to do one or the other or both.
What’s the easiest thing to do?
What you’re already doing!
So, use ILPs rather than VCSs, and you’ve met the FAR requirement.
All you have to do is justify (current) practice as “Industry Leading Practice”!
Business as usual?
Is this a good thing?
How do you sell your management on doing it better when you can get by doing less?
Stay out of trouble or contribute to the success of the organization?
Compliance or excellence?
“A best practice is a technique, method, process, activity, incentive, or reward that is believed to be more effective at delivering a particular outcome than any other technique, method, process, etc. when applied to a particular condition or circumstance.“ (Wikipedia)
“Methods and techniques that have consistently shown results superior than those achieved with other means, and which are used as benchmarks to strive for. There is, however, no practice that is best for everyone or in every situation, and no best practice remains best for very long as people keep on finding better ways of doing things.” (BusinessDictionary.com)
“Term used in place of best practice where it is inordinately difficult to identify or implement the best practice.” (BusinessDictionary.com)
IOW, “Leading Practice” <“Best Practice”