from the front line: Compliance Starts At Home

• 02/09/1999

During the past six months, the number of Y2K surveys crossing my desk has increased exponentially.

Our standard response is a form letter explaining that our AS/400 systems have been Y2K compliant since May, 1997, and that all other servers, PCs, networks, switchboards, elevators, and coke and candy machines are also ready for the new millennium.

The largest numbers of e-commerce documents – 1.2 million per year – we process internally are in the form of EDI purchase orders and invoices. The majority of our 300-plus trading partners were led (read dragged) into EDI and most likely will not upgrade their EDI translator software to be Y2K compliant.

At first glance, one would surmise that this non-compliance would be a cause for concern. But we have taken the position that since we do not have control over what our trading partners do relative to Y2K compliance, we have made internal system modifications, so that no matter what is sent our way, it will be handled as if it were compliant.

The program we put together encompasses several different positions and approaches. Among these decisions were that we would not:

• Respond to detail Y2K surveys, but would provide a form letter explanation of our current status.
• Require any of our trading partners to complete a formal written Y2K survey.
• Add new trading partners during December 1999.
• Perform 3030 to 4010 testing during December 1999.

However, we would:

• Conduct an ongoing telephone survey of all trading partners to determine their Y2K status.
• Notify all trading partners that they should contact us as soon as possible in 1999 when they were 4010 capable, so we could begin individual testing. We did not want to be in a position to be testing with large numbers of partners during the last months of ‘99.
• Create new 4010 overlays to match the existing 3030 formats.

Our position on trying to guarantee Y2K compliance is probably best summarized in the "Readiness" report prepared by the Securities and Exchange Commission in June 1997.

"It is not, and will not, be possible for any single entity or collective enterprise to represent that is has achieved complete Year 2000 compliance and thus guarantee its remediation efforts. The problem is simply too complex for such a claim to have legitimacy. Efforts to solve the Year 2000 problems as best described as ‘risk mitigation.’ Success in the effort will have been achieved if the number and seriousness of any technical failure is minimized, and they are quickly identified and repaired if they do occur."

One last note … I recently reviewed the October 19, 1998 law, referred to as the Y2K "Good Samaritan" Act. It appears as if the federal government has taken some of the teeth out of any lawsuit which would arise out of Y2K-related e-commerce problems. The act seeks to limit the legal liability of persons and organizations for their well-intentioned, but inadvertently incorrect, statements about their Y2K readiness and preparation. So … be well intentioned! If you are currently sending out Y2K surveys, you might want to review the contents of this new law.

It can be found at www.marketpartners.com/TheY2Kact.htm.

Bob Lewis is VP of IT at the FoodService Purchasing Cooperative Inc. (Louisville, Ky.). He can be reached at bob_lewis@fspc.com.