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A Technical Analysis of the Common Carrier/User Interconnections Area (1970)

Chapter: Section 6-- Certification Program

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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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Suggested Citation:"Section 6-- Certification Program." National Academy of Sciences. 1970. A Technical Analysis of the Common Carrier/User Interconnections Area. Washington, DC: The National Academies Press. doi: 10.17226/13320.
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SECTION' 6 CERTIFICATION PROGRAM Certification procedures in the interest of safety are customary in areas where safety to personnel and equipment depends critically upon engineering design, installation, maintenance and inspection. The Federal Aviation Agency regulates priyate·flying under such a program. The Federal Communications Commission regulates the operation of radio and television broadcasting stations through the issuing of station and personnel licenses. A certification of satisfactory inspection by an inspector, who is himself certified as competent, is required before an electric power utility will permit the connection of its power lines to a new home, office building or factory. There are other familiar examples in which certification procedures are in daily operation. It is natural to inquire whether similar procedures can be applied to the interconnection of user-owned equipment with the telephone network. The Panel has studied this question and has concluded that: AlTHOUGH EACH TELEPHONE INSTAlLATION IS, TO SOME EXTENT, CUSTOMIZED BECAUSE OF DIFFERENCES IN LOOP AND SWITCH CHARACTERISTICS, NEVERTHELESS, THERE IS SUFFICIENT COMMONAlITY TO AlLOW STANDARDIZATION THE PANEL CONCLUDES THAT THE STATE OF KNOWLEDGE AS TO THE CHARACTERISTICS OF THE TELEPHONE PLANT AND THE DEMONSTRATED CAPABILITY OF REPUTABLE MANUFACTURERS AND USERS WILL AlLOW THE DEVELOPMENT AND CAREFULLY PHASED-IN IMPLEMENTATION OF A CERTIFICATION PROGRAM A successful certification program for telephone interconnection must be made up of three principal functions. These cover the areas of: (a) Standards development (b) Equipment certification (c) Certification of installation and maintenance - 48 -

- 49 - STANDARDS No certification program, whether it be for equipment or for services, will work unless proper standards have been established. In the case of telephone interconnection, standards must be developed to cover certification for installation and maintenance of equipment and facilities, as well as for equipment manufacture, since all of these combine to determine the net effectiveness of the program. The standards, as defined:·forthis.effort, cover those factors relating to protection of the telephone network and topersortnel safety. These limited performance and safety standards would not guarantee the performance that the use of user-owned and maintained equipment would receive. Programs for this area could be developed. However, they are not within the realm of this study, which is limited to the technical issues that have evolved from theCarterphone decision. Since enforcement will require that the standards be referred to in the tariffs, final authority for the entire program should remain with the governmental agency having jurisdiction over the tariffs. Standards Development A standards-development program requires the resources of a qualified standards organization to provide coordination, structural guidance, and staff services to those. writing standards. Such organizations exist within both the private sector and goverrtment. In addition, a standards- development program in this area requires the work of knowledgeable people with sufficient training and experience in the design, manufacture, installa- tion, operation, and maintenance of modern complex communication equipment and systems. Without this depth of practical technical knowledge, the resulting standards will fall short of the requirements for a workable certification program. The technical expertise in this area resides with the carriers, users, and manufacturers, and these must all be involved in this program. In this connection, several organizations representing such expertise are now active in the United States in the preparation of standards for communication equipment, systems, and interfaces. They can contribute knOWledge and experience toward the establishment of the program being considered. AssHming federal government participation in the establishment and conduct of standards-development activity for telephone-interconnection certification programs, this participation should take several forms: (a) Establish the line of authority that gives weight to the enforcement of the standards. Cooperation between .federal and state g~vernments will be most important in this area.

- so - , ~ r (b) As a large userot communications facilities and services,it should participate in the committees developing new standards. (c) Establish priorities and schedules to ~sure that an orderly and expeditious i development program proceeds. Development of proper standards will take time. Even with qualified personnel working on their preparation, some standards have required more than a year beforeagre~ent could be achieved. If the program is recognized to be' sufficiently urgent, the time required for development will be shortened. The importance of each standard influences the manner in which necessary qualified personnel are made available and the willingness of affected organizations to work out compromise agre~ents, and this, in turn, determines the time needed to arrive at an approved standard. In the opinion of the Panel such a standardization program can be successfully impl~ented. EQUIPMENT CERTIFICATION In addition to standards, procedures must be established and enforced to ensure that equipment meets those standards. The degree of inspection performed as a part of equipment certification determines the probability that the equipment will meet the standards. An enforced equipment_certification program requires not only an evaluation of equipment samples but evaluation of the manufacturing organization to establish that procedures for quality of component procur~ent, manufacturing, testing, personnel training, and quality control ensure that there is a consistency of production quality. In setting up an enforced certification program, overall organization responsibilities and relationships, therefore, need to be considered. One approach involves separating central manag~ent and administration of the certification and standards program from the day-to-day operation of test and inspection facilities. A central management organization might be continuously responsible to the government agency granting its authority. At the same time, performance of equipment testing and manufacturer inspection could be handled by government facilities or by many competing firms looking for more cost-effective methods of performing their tasks. There are a number of independent test laboratory companies in the United States today.

- 51 - Certification of Installation and Maintenance After a user obtains his certified terminals or other equipment, he must assume responsibility for their operation. As discussed earlier in this report, it is essential that the equipment be installed and connected to the telephone facilities correctly, and it must be maintained in a way which will not cause future harm to the telephone network. A complete certification program must, therefore, cover installation and maintenance, as well as manufacture, of the user-owned equipment. An insta11ation- and maintenance-certification program must include standards for, and inspection of, the equipment connectiont6 each telephone line. In addition, consideration must be given to the qualifications and responsibility of the personnel who do the work. Minimum standard requirements will specify whether a given individual is authorized to carry out installation and maintenance of the equipment and to certify that the work has been properly completed. A certification program for installation and maintenance would require that testing and licensing procedures be specified. In this case, licensing would follow examination under rules developed in the standards program with every license certificate endorsed to indicate its applicability to equipment of one or more classes. The procedure for installing user-owned equipment will require close cooperation with telephone company personnel, since each case will require some degree of customer adjusting or fitting. This cooperative action will need to be recognized in a standard through the establishment of guideline procedures for installation and checkout. In its simplest form, installation and maintenance certification would apply to a protective coupling unit designed to prevent harm to the public telephone network. If the protective features are not in a separate unit, but are incorporated into the user's equipment, then these procedures must apply to pertinent parts of equipment and facilities in the user system connected to the telephone line. Inspection at the time of installation will not certify the installed user equipment indefinitely. Periodic inspection with appropriate documentation by licensed personnel must also be required by the standards for installation and maintenance. Another area requiring careful consideration is the certification of equipment for resale to a second user. After connection and use at one installation and subsequent remova1,it must be serviced and inspected by authorized personnel before it can be sold to a second user.

52 - ~ Maintenance requirements will include both routine and emergency service of the user's equipment.c The correct type of routine or preventive maintenance can protect the. network by preventing trouble before it starts. After trouble has been obserVed or suspected~ optimum methods for fault isolation will help greatly in reducing the time needed to correct the trouble and to return the system· to satisfactory operation. Responsibility and duties of those on each side of the common carrier~user interface must be spelled out in sufficient detail. A maintenance organization, in order to secure certification, should carry the necessary stock of replacement units, spare parts, and other material needed for service of the equipment. Training programs for service personnel should also be implemented in a way that meets or exceeds minimum standard requirements, PHASE-IN PROGRAM In the Applicable Experience Section (Section 8) of this report, we point out that there has been considerable successful experience of U.S. carrier interconnection of large-scale organizations -- such as "right- of-way" companies. However, this experience is limited in scale relative to the overall telephone plant, and detailed data on the degree and specifics of this interconnection was not gathered. The past experience has been with large and technically capable organizations. There is no such equivalent experience with the larger-volume/smaller-user type of customer on a direct interconnection basis. As a matter of fact, since this whole area is so new, there is no large-scale experience of interconnection using the carrier-supplied connecting arrangements. As discussed earlier in this report, those elements are also new, relatively untried, and already some deficiencies are evident. All this leads to the caution that if a program for direct interconnection by the customer via a certification program is to be carried out, it should be done carefully and in a way planned to minimize risk to the success of the program. This program must be set up to gather data to provide feedback to the standards organization for further development of the program. Therefore, the Panel feels that, as a first step of implementation, configurations involving smaller numbers of installations (such as PBX) should be certified. A ready technical base of servicemen exists, which could be certified. The equipment manufacturers and users are already familiar with telephone practices. This application would not represent a significant volume impac~ so that if errors are made and lessons are learned they can be remedied. Following this, the next most widespread area can develop (probably data terminals), and then proceed to the remainder of the field. It must be emphasized that the development of the certification program for both equipment and personnel must proceed apace. A number of installations, primarily the "right-of-way" companies,

- 53 - are presently directly interconnected with the carrier system. Over a period of time, these existing interconnections should be certified or access arrangements used. The Panel has not investigated a schedule for this, but it could be considered as an element in the overall certification program. SELF-CERTIFICATION If a user-manufacturer sets up his own program for equipment certification and verifies that he, in fact,meets all the stated require- ments of a producer of specific products, and that the finished product has been installed and inspected according to published standards, the resulting program would be called self-certification. Limited self-certification has proved to be satisfactory in several areas. The FCC requires that manufacturers of radio transmitting equipment mark all such products in a way that certifies that particular standards are met. Although the units are not tested by a third party, provision is made for monitoring in case of interference and inspection when required. In a similar way, the U.S. Coast Guard requires that standards be met in the manufacture of equipment and accessories for small craft used in specified areas. Again, the manufacturers' own certification is sufficient. However, annual inspection of small craft equipment is required. An enforced certification program formally separates the responsibility for inspection from the manufacturing, distributing, and using organizations that have a direct financial involvement in the outcome. In the case of direct electrical interconnection where intractable harm can be done, it is the considered opinion of the Panel that this risk cannot be avoided by self-certification. This is particularly so in the case where a large group of small users with little technical knowledge might buy lower-quality equipments (new or used) and cause serious harm to the rest of the using community. Faults in equipment quality, installation, maintenanc~and operating procedures will have a high likelihood of occurrence in the absence of the controls of an enforced certification program. Responsibility It was pointed out that the allocation of responsibility for protection of personnel, equipment,and service is important to the success of a certification program. At present the carriers are responsible for the safety of their personnel, equipmen4and the services they provide, and the regulatory agencies (both federal and state) exert authority over these carriers.

- 54 - The,widespread interconnection of user-owned terminals and systems, without isolating protective interface'devices (which assign responsibility to the carrieis), would cause'the dispersal of responsibility for service to include, in addition to', the canr Iers , one or mOl?e, of .the. following: (a) Users who own their own equipment (b) "Manufacturers who assure that standards are met ~;,i ,Those who prepare standards (c) Those who test or certify products (d) The source of certifying authority (e) Those who certify the competence of individuals (f) or organizations for installation and maintenance Inspectors (g) Commission (directly, in contrast to present (h) 'back-up responsibility) for system design' The Panel also believes that any significant dispersal of responsi- bility for service and cost would ultimately jeopardize the performance of ,the telephone network. The Panel also believes that this can be prevented by so structuring a program of standards and certification that the final authority for each segment of the program rests with the federal regulatory commission having jurisdiction ovel? the carriers. Installation and maintenance work will usually be performed at the request or direction of the user. The user therefore should be required to acknowledge his responsibility for abiding by rules he understands. The Panel believes that the vast majority of users will accept such responsi- bility if care is taken to be cel?tain that each one is aware of the rules and limitations. Users who wish to interconnect directly with the network should be required, in the process of applying for such privilege, to affirm their acceptance and undel?standing of the provisions of the tariffs governing such interconnection. If the evidence of such awareness is pro- vided in the form of an application fOl? service, then the carriers and the commissions will have the necessary tools and authol?ity to deal with problems on a case-by-case basis. The question of jUl?isdiction among the several commissions, federal and state, must be consi,dered, Equipment manufacturers cannot deal with a multiplici,ty of standal?ds, and centralized authority is thus essential. Minimum standards for thecerti,fi,cation of serVicemen will be a ,parallel effort with 'the setting of standards for equipment, and the same uniformity !-.

- 55 __ is needed. Nationwide service considerations would seem to require that practices be uniform, or nearly so, and certainly, certified equip- ment will be shipped from state-to-state. To retain the greatest practi- cable degree of centralized responsibility, the Panel recommends, therefore, that all standards and certifying organizations cooperating in the program derive their authority from the same federal regulatory agency having jurisdiction over the services of the common carrier. The tariffs would contain the provisions governing interconnections. COSTS The Panel has been requested to consider the technical aspects of interconnection with the telephone network, and of making recommendations on the basis of those considerations. At this time there is no available cost-data base for analysis. Nevertheless, every technical conclusion is associated with costs, and some general comments in this area would be worthwhile. Many of the presentations made to this Panel have included protestations that this or that solution entailed an unnecessary cost burden. Consideration of anyone cost by itself is easily transformed into a debate about who should bear the cost, or of how costs should be distributed among users and suppliers of telephone service. Such a debate is beyond the scope of the assignment given to this Panel. What matters is that all costs that result from interconnection be recognized, and that they be held to a level that is reasonable in relation to the benefits expected to follow. While the directly connected user will have expenses for equipment purchase, installation and maintenance, the carriers will also have costs associated with direct connection. These will be primarily associated with changed maintenance and installation procedures and administrative tasks. The apparent waste involved in requiring the use of protective interface devices in all cases, may be offset more or less by the reduction or elimination of other costs that are less visible, but just as real. The overall standardization-certification program will also entail costs. In this connection, a figure of $1,000 has been suggested for test and evaluation of the production run for one manufacturer's small product. Final figures will depend upon volume as well as details of the equipment configuration. It should be noted that the whole subject of rates has been outside the scope of this Panel's consideration. Nevertheless, rates are basic to this entire issue, as they will determine the degree of interest among users in any interconnection method beyond that presently authorized by the tariffs. Since there is as yet no experience with

- 56 - direct interconnection, no conclusions in the area of rates are possible. CONCLUSIONS (a) The establishment of standards and the enforced certification of user-supplied equipment and personnel fom an acceptable way of ensuring network protection. (b) Authority for a nationwide certification program should reside With a federal regulatory~ency responsible for the tariffs. (c) A carefully planned and timed step-by-step effort is necessary to ensure the successful implementation of a certification program. (d) Self-certification by manufacturers or users will not ensure an acceptable degree of protection,

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A Technical Analysis of the Common Carrier/User Interconnections Area assesses the technical factors affecting the common carrier/user interconnection area of public communications. This book develops technical and background information that might be useful to common carriers, users, and equipment manufacturers in reaching and implementing solutions to immediate problems. This includes a technical evaluation of various contending points fo view regarding the common carrier/user interaction area, the various problems to which these views relate, and the various technical and policy alternatives for responding to these problems in the near future.

A Technical Analysis of the Common Carrier/User Interconnections Area addresses questions of the propriety of the telephone company-provided network control signaling requirements and various alternatives to the provision thereof by the telephone company; the necessity and characteristics of telephone company-provided connecting arrangements and various alternatives to the provision thereof by the telephone company; and basic standards and specifications for interconnection and the appropriate method to administer them.

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