US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Ian S. Piper
Organization :   Diebold Election Systems, Inc.
Post Date :   9/29/2005

Section Comments
Section :  2.5.1
Page no. :  2-60
Line no.:  
Comment :  This requirement in item (b) states that "The system shall provide the means for providing an internal test that verifies that the prescribed closing procedure has been followed, and that the device status is normal", but it can only be based on procedures involving the equipment function.  There are jurisdictional procedures for auditing the paper ballots issued against the paper ballots supplied, locking up the polling place, etc. which are outside the scope of the equipment function.  The language used in the wording of this requirement can be interpreted to mean every step of the closing process has to be somehow tested by the equipment, even though the equipment is not even used in portions of that process.  

In most cases, a system does not allow the equipment to proceed to the next step unless a certain function is performed.  This relates directly to Requirement 2.2.1.(b) which indicates that the system operate only in the intended order of its function.  If a certain state of the equipment can only be reached by proceeding through the steps of the process, why would it be necessary to conduct an internal test to verify that it has been done, when you could only have gotten to that state by performing the ordered steps?  There would also be usability concerns in having Pollworkers move out of the standard task order and into a diagnostic mode to perform an internal test.

Proposed change:  Replace the requirement with "If the system allows the bypassing of steps in the equipment's prescribed closing procedure, provide an internal test that verifies that those steps of the prescribed closing procedure have been followed, and that the device status is normal."