Members of the communications industry are encouraged to share the results of their efforts. While the sharing of information can greatly expedite response time, it also raises some legal questions concerning liability. Some of these questions may be directed to the Antitrust Division of the US Department of Justice which has already authorized the sharing of some Year 2000 information.
This document is designed to set forth general suggestions for the communications industry on how to approach and address this situation systematically. These suggestions are general, not definitive. Individuals should take these suggestions and flexibly apply them to their own unique situations, seeking counsel from experts, from their peers, and from the many other sites referenced in this document.
Step One: Inventory
- Inventory your communications system. Attempt to keep a broad vision in order to anticipate each component which could influence the ability of your system to work. It may helpful to break your system down as follows:
- Communications: systems or components that directly affect communications transmission or reception (e.g., computer switches, routers, amplifiers) including equipment directly integrated into your system such as personal computers.
- Support: operations support and administrative systems (e.g., maintenance, billing, parts ordering).
- Auxiliary: systems or components such as payroll, human resources, security and alarm control systems, and air conditioning.
- Also consider your suppliers, business partners, and utilities. While making your inventory, be sure to collect the part numbers of your equipment; different versions of the same component can experience difference levels of problems. The part number can help specify whether yours is the model which will or will not experience difficulties.
Step Two: Assessment
- Define the problem. Select or draft a standard for the operational goal of your company.
- Determine the nature and the extent of the problem.
- Consult with manufacturers. Many manufacturers now have web sites providing detailed information for the equipment that they produce. Linked below is a partial list of communications equipment manufacturers with links to their Y2K pages where possible.
- Determine the nature of the risk. Distinguish those components and systems that pose the risk of critical failure and those that pose the risk of merely annoying failure. Be sensitive that some failures will be critical to your network and other failures, while only being annoying to your network, could be a critical loss to users (i.e., loss of services to the disabled, impeding their access to public safety).
- Identify the anticipated date of problems for each component. For some systems, the problem can experienced in advance of the year 2000 due to the calculation of such data as expiration dates. Other systems may experience problems well after January 1, 2000.
Step Three: Remediation
- Remediation may include any method of addressing the Y2K date conversion problem, including repair, replacement, retirement, or avoidance.
- Develop a plan to respond to the problem, with a strict time line for when each phase must be completed (be sure to afford sufficient time for testing and for unexpected events).
- The remaining time for remediation is a significant factor. Your plan may need to incorporate a priority of action, responding to critical systems first and dealing with lessor risks later. If not every problem can be fixed in time, alternative plans for how to survive the date conversion may need to be considered. Be aware that as we approach January 1, 2000, the resources available to respond will be in ever greater demand and possibly shorter supply.
- Consider the necessity of synchronized solutions. Generally communications equipment exist as a part of networks or larger systems. Fixes implemented in one component or system must successfully work with other connected components or systems. Efforts between business partners, competitors, peers, and consumers may need to be coordinated. For example, a remediation based on one set of assumptions may not be compatible with a remediation based on another set of assumptions. In addition, certain remediation must be conducted in certain chronological order. Anticipate that some actions may have to be taken in response to certain problems before other actions are taken.
- Deploy your plan.
Step Four: Unit Testing
- Testing is done in two steps. Unit testing occurs when individual components in isolation are tested. Integrated testing occurs when components are carefully reintroduced into their systems in order to ensure compatibility.
- Testing is vital to the implementation of a Y2K strategy. Experts suggest devoting 50 percent of your overall effort to testing. Testing permits you to uncover overlooked areas of difficulty. One auto company which felt confident about its level of compliance tested one of its plants only to discover that the factory doors would not unlock. Testing should be considered for all equipment, including equipment that is thought to be problem free, especially where that equipment is considered critical.
- Be aware that a fix implemented in one part of a system can have ramifications throughout the rest of the system. According to Bellcore, a new defect is introduced into software code with every 4.5 fixes. In addition, in the best of situations, 5 percent of defects are not discovered until after testing has been completed and the code has been made operational. Be prepared to test for and respond to the effect that fixes will have on systems.
- If testing cannot be completed on all systems, an order or priority should be developed with the most critical systems being tested first.
- Testing should be done with care to ensure that the testing itself results in no harm to the system or individuals.
Step Five: Integration & System Testing
- Once remediated and tested, equipment must carefully be integrated back into a system. You should take care to ensure that equipment that works in isolation also works when plugged back in. If the format of data has changed for a piece of equipment, than any other piece of equipment with which it works must be able to understand that new format.
- Integration also involves "synchronized implementation." This means that where two systems work together and exchange data, a change in data format in one system must occur at the same time as a change in a data format in the other. This may mean working with the companies with whom you interconnect to ensure that upgrades are conducted at the same time and will be compatible.
- Once your preparations are complete, be sure to maintain a "clean" environment. Do not integrate any untested component, hardware, or software into your system.
Contingency Plans
Contingency planning is critical to preparing for the year 2000. Your equipment might not accept the Y2K date change quite as anticipated. A failure may result from something overlooked or not within your control. Have a contingency plan in place so that your staff can efficiently, flexibly, and quickly respond to unexpected events before they become critical. For example, some companies are planning to operate at full staff during the initial period of the Y2K date change in order to be able to respond to problems, requesting that employees take New Years Eve leave at an alternative time. Know what actions FCC rules require in the event of service interruption (i.e., contacting the appropriate authorities such as the FAA or the Coast Guard ).It goes without saying that the communications industry will play a vital role in other people's contingency planning. The ability to utilize telecommunications to coordinate responses and provide information will be critical. The communications industry should be prepared to respond with the greatest of speed to any difficulties in order to ensure that all other members of our communities can also timely respond to the problems which they experience.
Disclaimer: These suggestions are general, not definitive. Individuals should take these suggestions and flexibly apply them to their own unique situations, seeking counsel from experts and from their peers.
Last Updated: January 8, 1999
http://www.fcc.gov/year2000/y2kguide.html