Fifteenth Annual Report on Federal Agency Use of Voluntary 

Consensus Standards and Conformity Assessment 

Mary F. Donaldson and Nathalie Rioux

Standards Services Group

Standards Coordination Office

Laboratory Programs

NISTIR 7857
NISTIR 7857

Fifteenth Annual Report on Federal Agency Use of Voluntary 

Consensus Standards and Conformity Assessment

Mary F. Donaldson and Nathalie Rioux

Standards Services Group

Standards Coordination Office

Laboratory Programs

June 2012

U.S. Department of Commerce

John Bryson, Secretary

National Institute of Standards and Technology

Patrick D. Gallagher, Director
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Table of Contents

1.0 Executive Summary.................................................................................................................. 1

2.0 Federal Agency Use of Standards............................................................................................. 2

2.1 Government-Unique Standards Used in Lieu of Voluntary Consensus Standards........ 2

2.2 Federal Agency Use or Substitution of Voluntary Consensus Standards in 

 Lieu of Government-Unique Standards....................................................................... 3

3.0 Federal Participation in Private-Sector Standards Activities.................................................... 3

4.0 Evaluation of the Effectiveness of OMB Circular A-119......................................................... 5

5.0 The Interagency Committee on Standards Policy (ICSP)......................................................... 6

6.0 Summary and Conclusions ....................................................................................................... 6

Appendix A: FY 2011 Federal Agency Information on Participation/Adoption of 

 Voluntary Standards Activities Required by OMB Circular A-119........................... 8

Appendix B: FY 2011 New Government-Unique Standards Used in Lieu of 

 Voluntary Consensus Standards ................................................................................. 9
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1.0 Executive Summary

The U.S. Department of Commerce (DOC) presents this summary report to the Office of Management 

and Budget (OMB) in compliance with OMB Circular A-119 and Public Law 104-113, the National 

Technology Transfer and Advancement Act (NTTAA). As required by Section 9 of the Circular, this 

report, prepared by the National Institute of Standards and Technology (NIST), describes activities 

related to the use of voluntary consensus standards (VCS) by 25 federal agencies during fiscal year (FY) 

2011. These federal agencies, listed in Appendix A, fulfilled the reporting requirements of both the 

OMB Circular A-119 and Section 12 (d) (3) of the NTTAA by providing information on their activities 

related to the use of private-sector standards in regulation, procurement, and conformity assessment.

In keeping with the requirements of the NTTAA, federal agencies indicated incorporating VCS

whenever possible in their regulatory and procurement activities. NIST, through its Standards 

Incorporated by Reference database, independently tracks government use of private-sector standards in 

regulations. As of the date of this report, NIST has identified over 9,486 citations of standards 

incorporated by reference in regulatory documents – more than 80 percent of these were developed by 

the private sector. Available online at http://standards.gov/sibr/query/index.cfm, this interactive 

database illustrates the extensive use of voluntary standards throughout the U.S. Government. 

For FY 2011, two agencies reported issuing four government-unique standards (GUS) in lieu of VCS for 

a total of 52 GUS that are currently being reported as replacing VCS. The two agencies developed these

GUS to provide cost savings and greater protection for constituents, and to simplify compliance. The 

Department of Labor (DOL) incorporated relevant aspects of five VCS into one GUS to reduce the cost 

burden for their regulated community to purchase and comply with the individual VCS. DOL also 

issued a mine safety standard that incorporated recommendations from new research findings that were 

not yet contained in relevant VCS. The Nuclear Regulatory Commission (NRC) revised the Regulatory 

Guide 8.2, “Guide for Administrative Practices in Radiation Monitoring,” removing references to 

outdated VCS that referred to obsolete technical practices and outdated requirements and issued two 

new regulatory guidance standards as part of this revision.

In FY 2011, federal agencies reported 261 new uses of VCS. Both the continued adoption of significant 

numbers of VCS along with the careful consideration and low rate of development of new GUS in lieu 

of VCS demonstrate the NTTAA’s success in encouraging agencies to look first to VCS to meet their 

regulatory, procurement, and conformity assessment needs.

Agencies reported 3,032 personnel participating in a total of 528 standards-developing organizations 

during FY 2011. This high level of federal engagement reflects a sustained commitment of the U.S. 

government to the activities of the private sector led VCS system.

Individual agency reports for FY 2011 reflect the benefits of this engagement, demonstrating that a 

strong federal investment in voluntary standards development helps to provide a sound technical basis 
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for standards, speeds the standards development process, and enables the adoption of VCS to support 

agency missions. Furthermore, federal use of VCS yields economic and social benefits to numerous 

stakeholders including federal agencies, the Nation’s businesses, and the public through reduced injuries 

and deaths, increased transactional efficiencies, reduced administrative burdens, and lower costs of 

products and services. 

2.0 Federal Agency Use of Standards

The OMB Circular requires that federal agencies use VCS in lieu of GUS in their regulatory and 

procurement activities. However, a federal agency is given discretion in deciding whether to use 

existing VCS if the agency determines that the use of such standards would either be inconsistent with 

applicable laws or otherwise impractical. The Circular also directs agencies to establish a process for 

continuously reviewing their use of standards for purposes of updating such use, including substitution 

of private-sector standards for GUS wherever possible. 

2.1 Government-Unique Standards Used in Lieu of Voluntary Consensus Standards

The OMB Circular requires that agencies report their use of standards on either a “categorical” or a 

“transactional” basis. Agencies reporting on a categorical basis are not required to list each instance that 

a GUS is used in lieu of a private-sector standard in procurement actions. Such agencies are required to 

have a system in place ensuring that GUS are developed only when suitable private-sector standards are 

not available for use. Only the Department of Defense (DoD) and the National Aeronautics and Space 

Administration (NASA) report on a categorical basis. In situations where private-sector standards do 

not exist, agencies are not required to report their use of GUS.

Table 2.1 illustrates the cumulative number of reported GUS (total by year and agency) used in lieu of 

Table 2.1 Government-Unique Standards Used in Lieu of Private Sector Standards Statistics

Agency 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

USDA 1 1 1 1 1 1 1

HHS 3 3 3 3 3 3 3 2 2 4 4 1 1 1 1

HUD 2 2 2 2 2 2 2 2 2 2 2 2

DOL 1 2 4 5 5 6 8 8 9 10 12

DOT 1 2 2 2 2 3 3 3 3 3 3 3 3 4 4

EPA 3 28 29 40 45 50 50 50 50 23 23 23 23 23

GSA 3 2 2 3 2 2 3 3 3 3 3 3

NARA 1 1 1 1 1 1 1 1 1 1 1 1

CPSC 1 1 1 2 2 2 2 2 2 2 2 2

GPO 4 4 4 4 4 

ACCESS 1 1 1 1 1 1

NRC 2

New Uses 4 4 25 12 12 7 9 1 1 5 2 1 3 4

Discontinued 1 2 4 27 3 1

Total In Use 4 8 33 45 56 63 72 71 68 73 48 45 46 48 52
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private sector standards since FY 1997, as well as the number of GUS introduced and discontinued in

each fiscal year. During FY 2011, two federal agencies found it necessary to develop their own 

standards instead of using existing private sector standards. Appendix B lists these agencies, their new 

GUS and rationale for why use of the relevant VCS was impractical. For a complete listing of the GUS

used in lieu of VCS and justifications from FY 1997 through FY 2011, visit

http://standards.gov/NTTAA/agency/index.cfm. 

2.2 Federal Agency Use or Substitution of Voluntary Consensus Standards in Lieu of

Government-Unique Standards

In FY 2011, federal agencies frequently found opportunities to use or substitute VCS instead of creating 

or using GUS.

• Federal agencies report adopting 261 VCS, with DoD accounting for 43 percent of the reported 

new uses and NRC, EPA, and HHS accounting for 31 percent.

• Federal agencies reported substituting 316 VCS for GUS, a significant increase from the last few 

years.

1 Nearly all substitutions were within DoD. Figure 2.2 illustrates the substitutions for each 

year since FY 1998.

3.0 Federal Participation in Private-Sector Standards Activities

OMB Circular A-119 states that federal agencies “must consult with VCS bodies, both domestic and 

international, and must participate with such bodies in the development of VCS when consultation and 

 1 GUS being substituted include the universe of GUS, i.e., those in use prior to the implementation of NTTAA reporting, 

those that are not “in lieu of VCS”, and those that are in lieu of VCS. Since NIST began collecting data, there have been 

3,579 reported substitutions of VCS for GUS across agencies. While we do not know the entire universe of GUS, we know 

from published sources that DoD—the largest user of such standards— lists over 21,000 GUS, counting military, federal, and 

NATO specifications, and more than 8,600 private-sector standards. DoD adopted 7,400 private-sector standards before 

1997.
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participation is in the public interest and is compatible with their missions, authorities, priorities, and

budget resources.” The Circular declares that “agency support provided to a VCS activity must be 

limited to that which clearly furthers agency and departmental missions, authorities, priorities, and is 

consistent with budget resources.” 

In FY 2011, agencies reported participation in 528 private-sector standards bodies compared to 517 in 

FY 2010 (see Figure 3a). The list of organizations includes VCS developers accredited by the American 

National Standards Institute (ANSI), other (non-ANSI-accredited) standards developers, industry and 

trade associations, international standards organizations, and consortia.

Federal agencies are also required by OMB to report the number of their employees who participate in 

private-sector standards body activities. This number includes not only those who serve on technical 

standards development committees, subcommittees, or workgroups, but also those who serve on boards 

and other leadership positions. 

In FY 2011, federal agencies reported that 3,032 employees participated in private-sector standards body 

activities, an increase from the previous year. Participation continues to remain above the annual 

average of 2,806 for reporting agencies. Of those reporting on staff participation, Department of Health 

and Human Services (HHS) has the largest number of staff participating in VCS standards body 

activities (856) followed by the Department of Energy (498) and DOC (458). Figure 3b illustrates total 
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federal employee participation in private-sector standards body activities reported since FY 1998. Data 

detailing FY 2011 participation for each agency is provided in Appendix A. A complete listing of the 

standards-developing organizations in which federal agencies participated can be viewed in the extended 

appendices to this report, located at http://standards.gov/NTTAA/agency/index.cfm.

2663 2723 2723

3229

3568

3208

3954 4075

2243

2277

2183

2768

3118

2772 2848 2969

3374

2935

3316

2837

3032

1000

1500

2000

2500

3000

3500

4000

4500

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Number of Employees

Fiscal Year

Figure 3 b — Federal Employee Participation in Private-Sector Standards Body 

Activities* 

* The upper series includes DoD data; 2006 is the last year that DoD reported staff participation in standards body activities. 

The lower series excludes these data.

4.0 Evaluation of the Effectiveness of OMB Circular A-119

During FY 2011, the majority of reporting agencies either had no comment on the effectiveness of OMB 

Circular A-119 or indicated that they found the Circular effective in helping them manage their 

standards development programs. Presented below are a few individual agency comments and their 

recommended changes to the Circular.2

Department of Homeland Security (DHS) - OMB Circular A-119, last revised in 1998, remains in need 

of updating to reflect the federal government initiatives in interoperability and information sharing. 

Recommend that revision address the inclusion of public and private sector participants more directly in 

the evolution of relevant government standards and conventions rather than relying on existing 

voluntary standards, particularly those relating to data standardization and information exchanges, for 

information sharing purposes.

 2 It is within OMB’s purview to consider and respond to these comments as appropriate.
6

Department of Interior (DOI) –Since its issuance, Circular A-119 has worked in a straightforward 

manner to encourage the use of VCS. Some believe that there is an order of preference for VCS (for 

example, international VCS are to be preferred to domestic VCS). NIST and OMB are encouraged to 

adjudicate issues concerning interpretation of OMB Circular A-119.

Environmental Protection Agency (EPA) –This reporting mechanism has not proven to be a significant 

asset in trying to encourage strategic consideration of the voluntary standards and conformity 

assessment tools available here in the US and world-wide a reconsideration of the reporting might be 

helpful in providing the Administration, Congress, and the public with a better sense of the value of the 

standards system and how collaboration between the government and the system is to the benefit of all.

Treasury and the Office of Financial Research - To the extent NIST determines creation of data 

interoperability in other industry sectors as a government-wide goal, that such purpose may be built into 

A-119. 

The full text of agency comments may be found in the Addendum to the Fifteenth Annual Report on 

Federal Agency Use of Voluntary Consensus Standards and Conformity Assessment, soon to be 

available online at http://standards.gov/NTTAA/agency/index.cfm.

5.0 The Interagency Committee on Standards Policy (ICSP)

During FY 2011, 54 individuals served on the ICSP, including agency Standards Executives, their 

alternates, NIST support staff, and a representative from OMB. The ICSP met twice jointly with the 

ANSI’s Government Member Forum, and once alone in FY 2011. Information concerning the ICSP, 

including membership, charter, and meeting minutes, may be found online at 

http://standards.gov/icsp/query/index.cfm.

6.0 Summary and Conclusions

As of FY 2011, 15 years since the start of the NTTAA reporting requirement, federal agencies report 

that they currently are using only 52 GUS in lieu of existing VCS. This small inventory reflects a real 

and continuing reliance on VCS. The NTTAA has successfully encouraged agencies to look first to 

VCS and to engage with the private sector standards system for solutions to government needs, rather 

than to develop GUS unnecessarily.

Guided by the NTTAA and OMB A-119, NIST continues to assist federal agencies and their 

stakeholders with standards and conformity assessment information, program support, guidance, and 

policy concerns. NIST hosts http://standards.gov, offering ongoing practical guidance, tools such as the 

searchable Standards Incorporated by Reference database, and information needed by agencies to 

implement the NTTAA successfully as well as a means to report standards activities as required by the 

NTTAA and OMB Circular A-119. In addition, NIST is working with agency standards executives and 

OMB to integrate standards participation and use more directly into the missions, decision-making 
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processes, operating procedures, and strategic goals of federal agencies. This report fulfills the annual 

reporting requirements of both the NTTAA and OMB Circular.
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Appendix A: FY 2011 Federal Agency Information on 

Participation/Adoption of Voluntary Standards Activities Required by 

OMB Circular A-119

Agency GUS in 

lieu of 

VCS 

VCS 

substituted 

for GUS

New VCS

used this 

year 

Employee 

participation 

in VCS bodies 

VCS bodies 

with agency 

participation 

Department of Agriculture 1 0 11 91 48

Department of Commerce 0 0 0 458 123

Department of Defense * 313 113 n/a 122

Department of Energy 0 0 10 498 92

Department of Education 0 0 0 24 4

Department of Health and Human Services 1 0 22 856 201

Department of Homeland Security 0 0 10 284 46

Department of Housing and Urban 

Development 2 0 0 9 5

Department of Interior 0 2 0 166 85

Department of Justice 0 0 0 1 0

Department of Labor 12 0 2 60 22

Department of State 0 0 0 9 1

Department of Transportation 4 0 8 131 50

Department of the Treasury 0 0 2 1 13

Environmental Protection Agency 23 0 26 80 14

General Services Administration 3 0 8 18 16

National Archives and Records 

Administration 1 0 13 14 9

National Aeronautics and Space 

Administration * 0 0 71 12

Consumer Product Safety Commission 2 1 3 29 9

Federal Communications Commission 0 0 0 28 13

Federal Energy Regulatory Commission 0 0 0 0 0

Federal Trade Commission 0 0 0 0 0

Nuclear Regulatory Commission 2 0 33 189 15

Government Printing Office 0 0 0 7 4

Access Board 1 0 0 8 7

Totals 52 316 261 3032 **

* Agencies reporting on a categorical basis per OMB Circular A-119, Section 12.

** Total not calculated to avoid duplicate counting due to participation in a standards body by 

more than one federal agency.
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Appendix B: FY 2011 New Government-Unique Standards Used in Lieu 

of Voluntary Consensus Standards

Agency Department of Labor (DOL)

Government 

Standard

29 CFR 1915 Subpart F – General Working Conditions in Shipyard Employment 

(Incorporated: 2011) [Incorporated: 2011]

Voluntary Standards • ANSI/IESNA RP–7–01, Recommended Practice for Lighting Industrial Facilities 

• ANSI/ISEA Z308.1–2009, Minimum Requirements for Workplace First Aid Kits and 

Supplies 

• ANSI Z358.1–2009, Emergency Eyewash and Shower Equipment 

• ANSI Z4.1–1995 and Z4.3–1995, Sanitation 

• ANSI/ASME B56.1–1993, Safety Standard for Low Lift and High Lift Trucks

Rationale Several voluntary consensus standards (VCS) were relied upon for the various 

provisions in the final rule, however, no single VCS is available to cover all the 

workplace hazards that are addressed by OSHA in this final rule. The Agency believes 

that it is less burdensome for the regulated community to use the one OSHA standard 

rather than require the purchase and use of numerous individual consensus standards it 

used to write the rule.

Government 

Standard

30 CFR Part 75 – Safety Standards for Underground Coal Mines (Section 75.403 –

Maintenance of Incombustible Rock Dust) – [Incorporated: 2011] [Incorporated: 2011]

Voluntary Standards • ASTM C110-09 – Standard Test Methods for Physical Testing of Quicklime, 

Hydrated Lime, and Limestone 

• ASTM C737-08 – Standard Specification for Limestone Dusting of Coal Mines

Rationale MSHA issued a final rule in June 2011 that finalized an Emergency Temporary 

Standard (ETS) on Maintenance of Incombustible Content of Rock Dust in 

Underground Bituminous Coal Mines. The basis of the ETS and final rule was a 

recommendation of the National Institute for Occupational Safety and Health 

contained in their Report of Investigations 9679 published in 2010. The ASTM 

consensus standards do not include the NIOSH recommendations or address the 

specific hazard covered in the MSHA ETS and final rule.

Agency Nuclear Regulatory Commission (NRC)

Government 

Standard

NRC NUREG-1556, “Consolidated Guidance about Materials Licenses” 

[Incorporated: 2011]

Voluntary Standards (ANSI) N 13.2-1969, “Guide for Administrative Practices in Radiation Monitoring”

Rationale (ANSI) N 13.2-1969, “Guide for Administrative Practices in Radiation Monitoring,” 

had been endorsed in Regulatory Guide 8.2, with the same title, issued in February, 

1973. The standard has not been revised since its inception, and it now refers to 

obsolete technical practices and outdated requirements. Therefore, Revision 1 of RG 

8.2, published in May, 2011, removed endorsement of ANSI N 13.2-1969. Guidance 

is now provided through two referenced NRC reports, which could be considered 

Government-unique standards: NUREG-1556, “Consolidated Guidance about 

Materials Licenses,” and NUREG-1736, “Consolidated Guidance: 10 CFR Part 20—

Standards for Protection against Radiation.”

Government NRC NUREG-1736, “Consolidated Guidance: 10 CFR Part 20—Standards for 
10

Standard Protection against Radiation” [Incorporated: 2011]

Voluntary Standards (ANSI) N 13.2-1969, “Guide for Administrative Practices in Radiation Monitoring”

Rationale (ANSI) N 13.2-1969, “Guide for Administrative Practices in Radiation Monitoring,” 

had been endorsed in Regulatory Guide 8.2, with the same title, issued in February, 

1973. The standard has not been revised since its inception, and it now refers to 

obsolete technical practices and outdated requirements. Therefore, Revision 1 of RG 

8.2, published in May, 2011, removed endorsement of ANSI N 13.2-1969. Guidance 

is now provided through two referenced NRC reports, which could be considered 

Government-unique standards: NUREG-1556, “Consolidated Guidance about 

Materials Licenses,” and NUREG-1736, “Consolidated Guidance: 10 CFR Part 20—

Standards for Protection against Radiation.”