EAC - Voluntary Voting System Guidelines

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