US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Section CommentsGeneral CommentsGlossary Comments
 
Name :   Stanley A. Klein
Organization :   N/A
Post Date :   9/30/2005

Section Comments
Section :  3.4.3
Page no. :  3-22
Line no.:  
Comment :  RELIABILITY
Mean time between failures (MTBF)
Section 3.4.3 of the VVSG specifies a “Mean Time Between Failures” of 163 hours. This
provision first appeared in the 1990 FEC standard and was carried into the 2002 update of that
standard. Based on the usual “constant hazard rate” reliability model with time between failures
distributed according to the Exponential Distribution, this specification corresponds to a failure
rate of 1/163 per hour of operation. During a 15hour
election day, this means the allowable
probability of voting machine malfunction on election day under the VVSG is 9.2%.
This provision clearly attempts to minimize the cost of reliability testing but does so by trading
away election integrity. The concept of “Parallel Testing” discussed in section 3.3 of Volume II,
in which the reliability testing is performed on the equipment while it is also being tested for
functionality, suggests how the MTBF specification was determined. Reliability testing requires
sufficient test time to obtain statistically valid results. Rather than determine a proper reliability
standard for voting machines and testing to that standard, the draft VVSG and the FEC standards
appear to be based on capping the reliability testing at the duration of the other testing and
setting the reliability standard at what can be accommodated under the cap. There is no other
way such an otherwise incompetently low MTBF requirement can be explained.
Attach file :  comments-to-EAC-on-VVSG-draft.pdf