Seventh Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment 

Kevin L. McIntyre

Michael B. Moore

Standards Coordination and Conformity Group

Standards Services Division

Technology Services

NISTIR 7118
NISTIR 7118

Seventh Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment

Kevin L. McIntyre

Michael B. Moore

Standards Coordination and Conformity Group

Standards Services Division

Technology Services

May 2004

U.S. DEPARTMENT OF COMMERCE

Donald L. Evans, Secretary

TECHNOLOGY ADMINISTRATION

Phillip J. Bond, Under Secretary of Commerce for Technology

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY

Hratch G. Semerjian, Acting Director
iii 

Table of Contents 

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

2.0 Overview and Scope................................................................................................................ 2 

3.0 Federal Agency Use of Standards.......................................................................................... 3 

3.1 Government-Unique Standards Used in lieu of Private Sector Standards.................................3 

3.2 Federal Agency Use of Private Sector Standards ......................................................................6 

3.3 Private Sector Standards Substituted for Government-Unique Standards.................................6 

3.4 Summary Observations..............................................................................................................7 

4.0 Federal Participation in Private Sector Bodies.................................................................... 7 

4.1 Federal Agency Participation in Private Sector Standards Development Activities .................7 

4.2 Federal Agency Employees Participating in Private Sector Standards Bodies .........................8 

4.3 Summary Observations..............................................................................................................8 

5.0 Federal Agency Conformity Assessment Activity................................................................ 8 

6.0 Evaluation of the Effectiveness of OMB Circular A-119 .................................................... 9 

7.0 The Interagency Committee on Standards Policy ............................................................. 10 

8.0 Challenges and Opportunities ............................................................................................. 11 

9.0 Conclusion ............................................................................................................................. 11

APPENDICES 

Appendix A: FY 2003 List of Reporting Federal Agencies.................................................. A-1 

Appendix B: FY 2003 Federal Agency Activities Related to Use of Private Sector 

Standards and Conformity Assessment.............................................................................B-1 

Appendix C: Government-Unique Standards Used in lieu of Voluntary Consensus 

Standards in FY 2003 ........................................................................................................C-1

Appendix D: The “Standards.Gov” Website......................................................................... D-1 
1 

Summary Report on Federal Agency Use of Voluntary Consensus Standards 

and Conformity Assessment Activities for FY 2003 

1.0 Executive Summary 

This summary report is provided to the Office of Management and Budget (OMB) by the 

National Institute of Standards and Technology (NIST) in compliance with OMB 

Circular A-119 and Public Law 104-113, the National Technology Transfer and 

Advancement Act (NTTAA). It describes activities related to the use of voluntary 

consensus standards and conformity assessment practices by agencies of the Federal 

government during FY 2003 as required by Paragraph 9 of the Circular. 

This report presents the standards and conformity assessment activities of 25 Federal 

agencies. Reported data show that overall Federal agencies continue to look to the 

private sector to fulfill government needs rather than creating new government-unique 

standards. Since FY 1997, Federal agencies have adopted nearly 2,500 private sector 

standards in support of their regulatory, procurement and policy activities. 

For FY 2003, Federal agencies reported 400 new uses of private sector standards. In 

addition, during the same period agencies substituted 185 private sector standards for 

government-unique standards. This is a clear demonstration of the progress made by 

agencies in complying with the NTTAA and Circular A-119. It indicates that, overall, 

agencies are increasingly looking to the private sector to fulfill government’s needs rather 

than create new government-unique standards. 

Agency reporting on the number of government-unique standards used in lieu of private 

sector standards shows an incremental increase in FY 2003; with only nine new uses 

reported. New uses by agencies of government-unique standards in lieu of private sector 

standards have declined steadily each year since FY 1999. 

Federal agencies reported participation in 433 private sector standards developing 

organizations during FY 2003. This is the largest number recorded since 2001 when 

NIST began collecting this data. The number of agency staff participating in standards 

activities was 3,568, an increase of 11% over the previous reporting period. Even so, 

private sector standards developers assert that there continue to be areas where greater 

Federal agency participation is necessary to ensure government input on important 

standards-related issues. 

For their part, Federal agencies report that maintaining their current levels of 

participation in standards developing organizations is becoming increasingly difficult. 

Competing organizational priorities, dwindling budget resources and anticipation in 

coming years of accelerated staff losses due to retirement and downsizing are just some 

of the reasons for concern in this area among agency Standards Executives. 
2 

Federal agencies continue to make advances in their ability to assess their standardsrelated activities and to make accurate reports of their activities for incorporation into this 

annual report. NIST is focusing its efforts on improving information sharing among 

Federal agencies as well as between the public and private sector, and on developing 

training programs to acquaint agency staff with their responsibilities under the NTTAA. 

2.0 Overview and Scope 

This summary report is provided to the Office of Management and Budget (OMB) by the 

National Institute of Standards and Technology (NIST) in compliance with OMB 

Circular A-119. It describes activities related to the use of voluntary consensus standards 

and conformity assessment practices by agencies of the Federal government during 

FY 2003 as required by Paragraph 9 of the Circular. The account of federal activities 

summarized in this document was compiled from reports submitted to NIST by federal 

agencies also in compliance with Paragraph 9 of the OMB Circular and Section 12 of the 

NTTAA. First signed into law on March 7, 1996, the NTTAA directs federal 

government agencies to achieve greater reliance on voluntary consensus standards 

developed by the private sector and decreased dependence on government-unique 

standards developed by and for the government. It also directs that federal agency 

personnel participate in the activities of voluntary consensus standards developing 

organizations in order to help ensure that standards produced in the private sector are 

more likely to be appropriate for use by federal agencies. These policies had been 

reflected for many years in OMB Circular A-119, and the enactment of the NTTAA 

codified these policies into statute and reinforced them. 

This report presents the standards and conformity assessment activities of twenty-five 

(25) federal agencies as listed in Appendix A. Data for the Department of Homeland 

Security (DHS) is not included in this report, as the Department was not fully formed and 

operational with respect to its standards management operations in time to file a 

submission for FY 2003 for inclusion herein. Consequently, reports from the Federal 

Emergency Management Agency and the National Communications System, both of 

which reported as independent agencies in years past, as well as the US Coast Guard, 

which formerly reported under the Department of Transportation, are not included in this 

report, as those agencies were all subsumed under the newly established DHS during 

FY 2003. 

This summary report represents a shift in reporting methodology from prior submissions 

made by NIST in compliance with the Act and the Circular. In response to comments 

received on the content and structure of past reports, NIST has attempted to prepare a 

shorter, more focused report that is more useful and informative for the reader. 

Supplemental information including individual agency submissions that were published 

in the past as appendices to NIST reports can be obtained online at www.standards.gov or 

by contacting NIST directly. 
3 

3.0 Federal Agency Use of Standards 

According to OMB Circular A-119, federal agencies must use voluntary consensus 

standards, both domestic and international, in their regulatory and procurement activities 

in lieu of government-unique standards. An agency has the discretion to decline to use 

existing voluntary consensus standards if the agency determines that use of such 

standards is inconsistent with applicable law or otherwise impractical. According to 

paragraph 6 a.(1) and (2) of OMB Circular A-119: 

 

"Use" means incorporation of a standard in whole, in part, or by reference for 

procurement purposes, and the inclusion of a standard in whole, in part, or by reference in 

regulation(s). 

 

"Impractical" includes circumstances in which such use would fail to serve the agency's 

program needs; would be infeasible; would be inadequate, ineffectual, inefficient, or 

inconsistent with agency mission; or would impose more burdens, or would be less 

useful, than the use of another standard. 

The Circular also directs agencies to establish a process for ongoing review of their use 

of standards for purposes of updating such use, including substitution of private sector 

standards for government-unique standards wherever possible. 

The stated policies of the OMB Circular are thus intended to reduce to a minimum the 

reliance by agencies on government-unique standards. The Circular also states that its 

policies do not create the basis for discrimination in agency procurement or regulatory 

activities among standards developed in the private sector, whether or not they are 

developed by voluntary consensus standards bodies. Historically, federal agencies have 

in fact used other private sector standards (classified by the Circular as non-consensus 

standards, industry standards, company standards and de facto standards). In reporting 

the full measure of their efforts at minimizing government-unique standards, agencies 

have typically reported to NIST their activities in these areas as well. Consequently, the 

information contained in this report addresses the use of standards and participation in 

standards development activities of organizations described interchangeably either as 

non-government or private sector standards developers. Either of these terms can be 

taken to include voluntary consensus standards as well as the other classifications of 

standards listed above. 

3.1 Government-Unique Standards Used in Lieu of Private Sector Standards

According to paragraph 6 of OMB Circular A-119, the heads of agencies “must transmit 

to OMB through NIST an explanation of the reason(s) for using government-unique 

standards in lieu of voluntary consensus standards.” After careful review of data for 

FY 2003 and past reporting periods, NIST and OMB have taken steps in this report to 

account for inconsistent reporting across the agencies that has in the past presented a less 

than accurate picture of this important metric. To explain briefly, some agencies in past 

years have counted the number of private sector standards not used instead of the 
4 

government-unique standards that were introduced. For example, a single governmentunique standard used in lieu of five private sector standards was often reported as five 

government-unique standards used. For the first time in this report, each governmentunique standard is listed (and counted) only once along with all of the corresponding 

private sector standards not used. Appendix C contains a complete listing of reported 

government-unique standards used in lieu of private sector standards for FY 2003, as well 

as the associated rationales for such use provided by the agencies. Secondly, further 

examination of the government-unique standards reported in this category has revealed 

that some standards were listed previously when no alternative private sector standards 

existed. In the absence of a private sector standard not used, these government-unique 

standards need not be reported and have therefore been removed from the list. Finally, 

while some agencies report use of a government-unique standard in the first year that it is 

used and in each subsequent year until such use is rescinded, other agencies report use of 

a government-unique standard only in the first year of its use. For this report, an effort 

was made to normalize the reported data in a manner consistent with the spirit of the 

NTTAA. 

Table 3.1 illustrates the cumulative use of standards from FY 1997 to present by agency 

as well as the number introduced and withdrawn each year. Appendix C contains a list of 

the 72 government-unique standards and justifications reported between FY 1997 and 

FY 2003 that are still in use. 

Table 3.1 Government-unique Standards Used in Lieu of 

Private Sector Standards FY 1997 – FY 2003

Agency FY 

1997 

FY 

1998 

FY 

1999 

FY 

2000 

FY 

2001 

FY 

2002 

FY 

2003 

DOD * * * * * * * 

HHS 3 3 3 3 3 3 3 

HUD 2 2 2 2 

DOL 1 2 4 

DOT 1 2 2 2 2 3 3 

EPA 4 29 30 40 45 50 

GSA 3 2 2 3 

NASA * * * * * * * 

NARA 1 1 1 1 

CPSC 1 1 1 2 

GPO 4 4 4 4 

New Uses +4 +5 +25 +12 +11 +7 +9

Discontinued -1 

Total in Use 4 9 34 46 56 63 72 

* DOD and NASA report on a categorical basis in accordance with Section 12 

 of OMB Circular A-119. 

Agencies were not asked to report in FY 1997 those government-unique standards 

already in place at the onset of the NTTAA and OMB Circular A-119 reporting 

requirements. Consequently, there is no data presently available to indicate how many 

government-unique standards introduced more than seven years ago are still in use that 
5 

could possibly be withdrawn and replaced by more current, relevant and cost-saving 

voluntary consensus standards. Therefore, NIST will encourage agencies to intensify 

their efforts in future years to review government-unique standards uses that are five 

years old or older to determine if suitable voluntary consensus standards are now 

available for substitution. Also, for future reporting periods NIST will call on agencies to 

specifically report ongoing use of previously reported government-unique standards such 

as those listed in Appendix C and to identify additions, deletions, and substitutions of 

government-unique standards that occur during the reporting period as is captured in 

Table 3.1. 

Table 3.1 indicates that agencies continue to develop a minimal number of governmentunique standards each year. Agencies report that these additions are necessary in order to 

fulfill demands of higher performance specifications and measurements as well as to 

accommodate highly specialized technologies. 

OMB Circular A-119 allows federal agencies to report the number of private sector 

standards they have used on either a categorical or transactional basis as outlined in 

Paragraph 11 and Paragraph 12 of the Circular, respectively. In short, under the 

categorical option, agencies that make extensive use of standards in procurement 

activities are not required to list individually all of the government-unique standards they 

used in lieu of private sector standards during the period. Thus, the numbers represented 

in Table 3.1 do not fully encompass all of the government-unique standards used in lieu 

of private sector standards by federal agencies during FY 2003. Only two agencies, the 

Department of Defense (DOD) and the National Aeronautics and Space Administration 

(NASA), opted to report their use of government-unique standards in lieu of private 

sector standards on a categorical basis for FY 2003. However, both DOD and NASA 

have always reported this way for prior reporting periods. Therefore, the data points in 

Table 3.1 consistently represent government-unique standards used in lieu of private 

sector standards for the rest of reporting agencies. 

The practice of using government-unique standards on the part of federal agencies will 

necessarily continue because of the highly specialized applications of technology (i.e., 

military, space travel, national security) in which federal agencies are involved. 

However, the incidence of new uses of government-unique standards has stabilized at a 

very low rate; only nine new standards were used for the first time during this reporting 

period. Agencies that continue to use government standards developed in the past instead 

of available voluntary consensus standards state the need to apply and to adhere to higher 

performance specifications and measurements than are available through commercial 

and/or other consensus standards. Therefore, while the government-unique standards 

listed may appear at face value to be duplicative of available private sector standards, the 

health, environmental and safety benefits of their use balance the costs. Examples 

include the Department of Transportation’s (DOT) Performance-Based Brake Testing 

standards for large trucks and buses, the Environmental Protection Agency’s (EPA) 

Methods for testing air quality, and the Department of Health and Human Services/Food 

and Drug Administration’s (HHS/FDA) Guidelines on Aseptic Processing. 
6 

3.2 Federal Agency Use of Private Sector Standards

This measure provides a general indication 

of the frequency with which government 

agencies used private sector standards 

during the reporting period. In any 

reporting year, the total number of private 

sector standards used by all government 

agencies will vary based largely on current 

operational priorities for that period. As 

with the previous measures, this one can 

be affected by changes in the accuracy 

with which federal agencies are able to 

determine and report their use of standards 

during the reporting period. 

As illustrated by Figure 3.2, the total number of private sector standards in use by federal 

agencies has grown rather steadily since the onset of agency reporting under the NTTAA. 

(The sharp increase indicated in FY 2000 was due largely to a reported increase of more 

than 1500 VCS used by the Department of the Interior. While this irregularity is thought 

to be a reporting error, Interior is unable to confirm a more accurate figure.) 

In FY 2003, changes in standards use varied widely on an agency-by-agency basis; 

however, the positive net change of nearly 400 new uses of private sector standards again 

demonstrates the progress made by federal agencies in complying with the NTTAA and 

Circular A-119. The positive trend seen in the chart indicates overall that, as needs arise 

within federal agencies for new standards, the agencies are increasingly looking to the 

private sector to fulfill government’s needs rather than create new government-unique 

standards. 

3.3 Private Sector Standards Substituted for Government-Unique Standards

Once again, a significant number of 

private sector standards were 

substituted for government-unique 

standards during the reporting period, 

which attests to the fulfillment of 

Section 12 of the NTTAA (P.L. 104-

113). These figures are represented 

graphically in Figure 3.3. As in 

previous years, the Department of 

Defense was responsible for the 

largest number of substitutions. 

Since 1999, DOD has accounted for 

the majority of the private sector 

standards substitutions in any given 

 Figure 3.2 – Private Sector Standards 

Used by Federal Agencies

4380 2803

1883

3383

0

1000

2000

3000

4000

5000

6000

1997 1998 1999 2000 2001 2002 2003

Fiscal Year

3984

4061* 3958*

* Due to lack of available data, amounts for FY 2000 and FY 

2001 contain estimated Private Sector Standards use for 

Department of Interior. 

Standards by Federal Agencies

Substituted for Government-Unique 

 Figure 3.3 - Private Sector Standards 

Standards

0

100

200

300

400

500

600

1997 1998 1999 2000 2001 2002 2003

Fiscal Year

DOD HUD NASA All Other

Substituted for Government-Unique 
7 

year. In FY 2003, DOD substitutions accounted for about 85 percent of the total. The 

standards substituted address a diverse set of technologies including metals and alloys, 

and manufactured parts. 

3.4 Summary Observations

It is important to caution the reader that reliance upon numbers alone for an 

understanding of federal agency standards use can be misleading. For example, an 

increase in the use of government-unique standards used in lieu of private sector 

standards may not signal a negative development if national priorities such as homeland 

security require such use. Likewise, the use of a management system standard such as 

ISO 9000 or ISO 14000 can be a far more significant event and can have a much more 

profound effect on a federal agency’s activities, including its regulated and/or affected 

procurement communities, than use of a specific test method. Yet, the use of each 

standard may be counted only once by a reporting agency. At any rate, while there is 

much more substance to federal use of standards than can be discerned through a cursory 

review of reported figures, the overall trends are clear—federal agencies are increasing 

their reliance upon private sector standards. 

4.0 Federal Participation in Private Sector Bodies 

OMB Circular A-119 states that federal agencies “must consult with voluntary consensus 

standards bodies, both domestic and international, and must participate with such bodies 

in the development of voluntary consensus standards when consultation and participation 

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

budget resources.” The Circular goes on to declare that “agency support provided to a 

voluntary consensus standards activity must be limited to that which clearly furthers 

agency and departmental missions, authorities, priorities, and is consistent with budget 

resources.” 

4.1 Federal Agency Participation in Private Sector Standards Development Activities 

Federal agencies reported participation in 433 private sector standards developing 

organizations during FY 2003. This is the largest number of non-government standards 

developing organizations with federal agency participants recorded since 2001 when 

NIST began collecting this data. This total includes ANSI-accredited voluntary 

consensus standards developers, trade associations and industry consortia. The list also 

contains both domestic and international organizations. In addition to participating at the 

committee level, federal representatives also serve in various other ways within these 

organizations, sometimes serving in leadership roles that include secretariats, office 

holders and board members. Nevertheless, private sector standards developers assert that 

even greater federal agency participation is necessary in order to bring forth government 

input on important standards-related matters. 
8 

4.2 Federal Agency Employees Participating in Private Sector Standards Bodies

In the aggregate, federal agencies once 

again reported higher net numbers of 

participation in standards developing 

activities in FY 2003, another indicator of 

the increased attention being paid by 

agencies to standards activities and use. 

The gains are largely attributable to more 

complete and accurate reporting of 

employee participation on the part of a 

handful of responding agencies. 

4.3 Summary Observations

As stated above, the reported increases in recent years of federal agency involvement in 

private sector standards development activities signifies an overall improved capability 

on the part of federal agencies to gauge and report their activity levels in these areas. 

Some clear benefits of better accounting are that agencies can better manage their 

existing resources, and they are able to more effectively focus their efforts on standards 

that further mission-related priorities. 

Anecdotally, federal agencies assert that maintaining their current levels of participation 

in standards developing organizations is becoming increasingly difficult. Competing 

organizational priorities, dwindling budget resources and anticipation in coming years of 

accelerated losses due to retirement of experienced staff are just some of the reasons for 

concern in this area among agency Standards Executives. It is also true that these factors 

are more prevalent in some agencies than in others, resulting in noticeable variability 

across the agencies with respect to the current status of their individual efforts to 

implement the requirements of the NTTAA and OMB Circular A-119. 

5.0 Federal Agency Conformity Assessment Activity 

Conformity assessment includes all activities concerned with determining directly or 

indirectly that relevant requirements in standards or regulations are fulfilled. Conformity 

assessment includes: sampling and testing; inspection; certification; management 

systems assessment and registration; accreditation of the competence of the 

aforementioned activities and recognition of an accreditation program's capability. The 

NTTAA directs NIST to coordinate government standards activities and conformity 

assessment activities with private sector standards activities and conformity assessment 

activities. In accordance with OMB Circular A-119, NIST issued guidance1

 to federal 

agencies for the purpose of eliminating unnecessary duplication and complexity in the 

development and promulgation of conformity assessment requirements and measures. 

 

1

 15 CFR Part 287, Guidance on Federal Conformity Assessment Activities, Federal Register: August 10, 

2000 (Volume 65, Number 155) 

Figure 4.2 - Number of Federal Agency 

Employees Participating in Private 

 Sector Standards Activities

3298

3568

3229

2723

2723

2662

3265

2000

2500

3000

3500

4000

1997 1998 1999 2000 2001 2002 2003

Fiscal Year
9 

There are several examples of agencies using existing public and private sector 

conformity assessment systems to reduce the duplication of programs and associated 

costs. For instance, NIST cooperates with the National Cooperation for Laboratory 

Accreditation (NACLA) through the NIST/ NACLA Memorandum of Understanding 

which states that "NIST and NACLA will encourage the use by government and the 

private sector of such accreditation bodies by informing them of the NACLA recognition 

process and inviting their participation in that process." In another example, the 

Department of Energy has endorsed the mission and vision of NACLA, part of which 

involves encouraging DOE laboratories and organizations to become users of the 

NACLA accreditation body recognition process and to join NACLA as member 

organizations. Other examples of ongoing public-private cooperation in conformity 

assessment activities include the following: 

 EPA currently recognizes the American Industrial Hygiene Association and the 

American Association for Laboratory Accreditation (A2LA) as accrediting 

organizations for its National Lead Laboratory Accreditation Program (NLLAP). 

 A2LA and NIST’s National Voluntary Laboratory Accreditation Program 

(NVLAP) are approved accreditation bodies under the U.S. Federal 

Communications Commission (FCC) program that requires manufacturers and 

suppliers of personal computers and computer peripherals who intend to use a 

"Declaration of Conformity" on their products to have the products tested by an 

accredited Electromagnetic Compatibility (EMC) laboratory. 

Federal agencies continue to participate in a variety of conformity assessment activities 

that are either conducted by private sector organizations or are government-run activities 

that encourage private sector participation. A number of federal agencies are working 

jointly with other agencies and non-governmental organizations in the development of 

conformity assessment policies and guidelines. 

6.0 Evaluation of the Effectiveness of OMB Circular A-119 

OMB Circular A-119 provides an opportunity for federal agencies to offer commentary 

on the effectiveness of the Circular. The remarks offered by federal agencies for 

FY 2003 were mostly positive. Some examples of those comments are paraphrased 

below: 

 The Consumer Product Safety Commission stated that during FY 2003, the 

Commission's efforts to enhance voluntary safety standards development were 

complemented by the overall federal policy set forth in the Circular.

 The Department of Defense affirmed that the A-119 policy mandating that 

government agencies review their respective voluntary consensus standards 

programs at least once a year is an excellent means of determining if agencies are 

relying on government-unique standards to a greater extent than is necessary.

 The National Aeronautics and Space Administration stated that the Circular 

continues to provide stimulus for NASA's efforts to “enhance the use of 

Voluntary Consensus Standards, challenge the need for NASA-unique Technical 
10 

Standards requirements, and improve its Technical Standards System.” As a 

result, NASA has increased its participation with Voluntary Consensus Standards 

bodies in standards activities by 10 percent from FY 2002.”

On the other hand, some agencies voiced a desire for more precise instructions on how to 

report their use of standards. These and other issues surrounding federal agencies’ ability 

to effectively comply with the Circular will be addressed by the Interagency Committee 

on Standards Policy (ICSP) during FY 2004. 

7.0 The Interagency Committee on Standards Policy 

As set out in Section 13 of OMB Circular A-119, the Interagency Committee on 

Standards Policy (ICSP) is directed to advise the Secretary of Commerce and other 

Executive Branch agencies in standards policy matters. The Committee reports to the 

Secretary of Commerce through the Director of NIST. The ICSP seeks to promote 

effective and consistent standards policies in furtherance of U.S. domestic and foreign 

goals and to foster cooperative participation by the Federal government and U.S. industry 

and other private organizations in standards activities, including the related activities of 

product testing, quality system registration, certification, and accreditation. 

Chaired by NIST, the committee had as many as 45 members during FY 2003, including 

agency Standards Executives and their alternates, NIST support staff and representation 

from OMB. Six agencies had vacant Standards Executive positions. In May 2003, the 

ICSP, through the Secretary of Commerce, made requests of five federal agency heads to 

appoint Standards Executives to fill existing vacancies on the ICSP and to achieve 

representation for the newly formed Department of Homeland Security. The ICSP Chair 

plans to request through the Secretary one additional appointment to represent the newly 

formed Access Board, formerly the Architectural and Transportation Barrier Compliance 

Board, an independent Federal Board originally created by Congress in 1973. The use of 

government-unique and private sector standards as well as conformity assessment 

activities will very likely figure in the programs of both the DHS and the Access Board; 

therefore, membership on and coordination with the ICSP should prove advantageous for 

both organizations and for the ICSP as a whole. 

The ICSP met three times in FY 2003 at various locations in the Washington 

Metropolitan Area. The following examples are but a handful of the various topics 

discussed by the committee at those meetings: 

 The importance of standards in support of homeland security objectives, and the 

addition of representation from the newly formed Department of Homeland 

Security; 

 Collaboration with the private sector through the Homeland Security Standards 

Panel established by the American National Standards Institute (ANSI); 

 Ramifications for federal agencies stemming from the SBCCI, Inc. v. Veeck case; 

 Private sector concerns regarding use by multiple federal agencies of the 

Leadership in Energy and Environmental Design (LEED) Green Building Rating 
11 

System for environmentally sustainable buildings; 

 Various discussions among committee members regarding improved methods of 

selecting standards for use, improved management of standards activities, and 

streamlined annual activity reporting. 

8.0 Challenges and Opportunities 

In order to comply successfully with the Act and the Circular, federal agencies must work 

externally to increase their use of private sector standards and to increase their 

participation in private sector standards development activities. At the same time, federal 

agencies must improve internally their ability to assess their activities and to make 

accurate reports of their activities for incorporation into the NTTAA Annual Reports. 

Clearly, federal agencies are making advances in both of these areas. 

At the same time, federal agencies continue to deal constructively with significant 

challenges to their efforts to fully implement the requirements of the NTTAA. 

Diminishing assets and competing organizational priorities have caused agencies to make 

difficult decisions regarding resource allocations as they try to maintain support for 

standards-related activities at levels necessary to carry out their missions. In addition, 

agencies regularly experience personnel turnover at all organizational levels due to 

reorganizations, accelerating retirements among senior level career personnel, and normal 

attrition. These changes make it very difficult for federal agencies to retain high-level 

managers who appreciate the importance of standards and who visibly support standardsrelated activities. Likewise, federal agencies struggle to retain knowledge of standards 

policies, responsibilities and practices at the staff level. 

In an effort to address at least some of these challenges, NIST is developing training 

programs with the goal of acquainting federal agency leaders, managers and staff with 

their roles and responsibilities under the NTTAA as well as the benefits to government of 

NTTAA implementation. Under this initiative, practical guidance will also be offered in 

effective methods of managing and reporting standards activities. NIST also intends to 

create a handbook that contains useful and concise information for federal employees 

who make decisions regarding use of standards. 

In a further effort to improve information sharing among federal agencies as well as 

between government and the private sector, NIST has created an Internet portal located at 

www.standards.gov. A major goal of this portal is to provide a one-stop, e-government 

location for information related to the use of voluntary consensus standards in 

government. It can also serve as a forum for providing ongoing, practical guidance to 

agencies on standards-related matters. Appendix D is provided to introduce readers to 

the store of information that is available at this site. NIST welcomes any suggestions on 

content and format improvements that might improve the usability of this portal. 

9.0 Conclusion 

This year’s report is evidence that agencies are committed to carrying out Section 12 of 
12 

the NTTAA, which was enacted to encourage the Federal government to rely on private 

sector, voluntary consensus standards wherever possible. There is ample evidence to 

suggest that the Federal government as a whole is improving incrementally from year-toyear both in its use of private sector standards and in the level of its participation in 

private sector standards development activities. From FY 1997-FY 2003, the 

government has used nearly 2,000 private sector standards in place of government-unique 

standards. Furthermore, federal agencies are developing very few government-unique 

standards, and federal agencies overall are getting better at reporting the full extent of 

their standards-related activities in an accurate and timely manner. Private sector 

stakeholders continue to seek additional participation to meet their needs for government 

input in important standards development activities. 

For additional information, individual agency report submissions may be obtained online 

at www.standards.gov or by contacting the Standards Coordination and Conformity 

Group within Technology Services at NIST. 

APPENDICES 
A-1

Appendix A: FY 2003 List of Reporting Federal Agencies 

Note: This report presents the standards and conformity assessment activities of twentyfive (25) federal agencies as listed below. Data for the Department of Homeland 

Security (DHS) is not included in this report, as the Department was not fully formed and 

operational with respect to its standards management operations in time to file a 

submission for FY 2003. Consequently, reports from the Federal Emergency 

Management Agency and the National Communications System, both of which reported 

as independent agencies in years past, as well as the US Coast Guard, which formerly 

reported under the Department of Transportation, are not included in this report, as those 

agencies were all subsumed under the newly established DHS during FY 2003. 

Agency Acronym

Department of Agriculture USDA 

Department of Commerce DOC 

Department of Defense DOD 

Department of Energy DOE 

Department of Education ED 

Department of Health and Human Services HHS 

Department of Housing and Urban Development HUD 

Department of the Interior DOI 

Department of Justice DOJ 

Department of Labor DOL 

Department of State DOS 

Department of Transportation DOT 

Department of the Treasury TRES 

Department of Veterans Affairs VA 

Environmental Protection Agency EPA 

Agency for International Development USAID 

General Services Administration GSA 

National Archives and Records Administration NARA 

National Aeronautics and Space Administration NASA 

National Science Foundation NSF 

Consumer Product Safety Commission CPSC 

Federal Communications Commission FCC 

Federal Trade Commission FTC 

Nuclear Regulatory Commission NRC 

Government Printing Office GPO 
B-1

Appendix B: Federal Agency Activities Related to Use of Private Sector 

Standards and Conformity Assessment 

I II III IV V VI VII VIII 

Agency Governmentunique 

standards in 

use in lieu of 

voluntary 

consensus 

standards 

Voluntary 

consensus 

standards 

substituted 

for 

governmentunique 

standards in 

FY 2003 

Voluntary 

consensus 

standards 

in use in 

FY 2003 

Employee 

participation 

in voluntary 

consensus 

standards 

bodies in 

FY 2003 

Change 

from 

previous 

year 

Voluntary 

consensus 

standards 

bodies with 

agency 

participation 

in FY 2003 

Change 

from 

previous 

year 

USDA 0 0 163 106 24 42 -9 

DOC 0 0 0 415 -24 118 -47 

DOD * 156 8803 450 -11 55 0 

DOE 0 0 1187 674 -7 85 28 

ED 0 0 17 2 0 1 0 

HHS 3 11 663 623 108 165 126 

HUD 2 1 300 10 0 5 0 

DOI 0 0 242 645 345 25 6 

DOJ 0 0 1 5 0 1 -1 

DOL 4 0 117 61 1 16 1 

DOS 0 0 0 0 0 0 0 

DOT 3 0 323 167 -9 30 -24 

TRES 0 0 99 3 -63 3 -5 

VA 0 0 0 4 -10 17 -3 

EPA 50 0 109 44 2 21 -1 

USAID 0 0 0 0 0 0 0 

GSA 3 0 391 25 -19 26 2 

NARA 1 16 52 13 0 10 -2 

NASA * 1 266 144 13 33 -3 

NSF 0 0 0 3 3 7 7 

CPSC 2 0 0 31 2 7 -1 

FCC 0 0 0 5 0 7 0 

FTC 0 0 0 0 0 0 0 

NRC 0 0 117 136 -8 15 0 

GPO 4 0 126 2 2 4 4 

Totals 72 185 4380 3568 349 

* Agencies reporting on a category basis per OMB Circular A-119, Section 12.
C-1

Appendix C: Government-Unique Standards Used in lieu of Voluntary 

Consensus Standards in FY 2003 

Note: Government-unique standards denoted by (*) indicate instances of use reported for the first time in FY 2003. 

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

1 HHS FDA Guidelines on 

Aseptic Processing (1987) 

ISO 13408-1 – Aseptic 

Processing of Health 

Care Products, Part 1, 

General Requirements 

FDA/CBER is not using the ISO standard 

because the applicability of these requirements is 

limited to only portions of aseptically 

manufactured biologics and does not include 

filtration, freeze-drying, sterilization in place, 

cleaning in place, or barrier-isolator technology. 

There are also significant issues related to 

aseptically produced bulk drug substance that 

are not included in the document 

ASTM Standard E1115 

– Test Method for 

Evaluation of Surgical 

Hand Scrub 

Formulations 

Sensitivity and bias of the ASTM Standard has 

not been established. 

ASTM Standard 

E1173-93 – Standard 

Test Method of an 

Evaluation of 

Preoperative, 

Precatheterization, or 

Preinjection Skin 

Preparations 

Sensitivity and bias of the ASTM Standard has 

not been established. 

2 HHS FR Notice dated June 17, 

1994 Tentative Final 

Monograph for Health 

Care Antiseptic Drug 

Products; Proposed Rule 

ASTM Standard 

E1174-00 – Standard 

Test Method for the 

Evaluation of the 

Effectiveness of Health 

Care Personnel or 

Consumer Handwash 

Formulations 

Sensitivity and bias of the ASTM Standard has 

not been established. 

3 HHS National Standard Format 

(NSF) 

ANSI X12 837 The NSF is used widely across the health care 

payment industry and has become a defacto 

national standard. However, the Centers for 

Medicare and Medicaid Services (CMS) have 

directed their contractors to discontinue use of 

the NSF standard and replace it with ANSI X12 

837. 

4 HUD 24 CFR 200.935 --

Administrator 

qualifications and 

procedures for HUD 

building products 

certification programs. 

ANSI A119.1 N – 

Recreation Vehicles 

HUD Building-Product Standards & 

Certification Programs. HUD was required by 

legislation to “establish federal construction and 

safety standards for manufactured homes and to 

authorize manufactured home safety research 

and development.” Recently, HUD retained a 
C-2

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

private consensus body (NFPA) to update and 

modernize the Manufactured Home Standards. 

At the conclusion of the development process, 

NFPA will submit the revised standard to HUD 

for regulatory adoption. 

5 HUD 24 CFR 3280 – 

Manufactured Home 

Construction and Safety 

Standards 

ANSI A119.1, 

Recreation Vehicles, 

and NFPA 501C, 

Standard on 

Recreational Vehicles. 

HUD-Unique Manufactured Home Construction 

& Safety Standards. HUD was required by 

legislation to “establish federal construction and 

safety standards for manufactured homes and to 

authorize manufactured home safety research 

and development.” Recently, HUD retained a 

private consensus body (NFPA) to update and 

modernize the Manufactured Home Standards. 

At the conclusion of the development process, 

NFPA will submit the revised standard to HUD 

for regulatory adoption. 

6 DOL Electric Motor-Drive 

Equipment rule 

IEEE Standard 242-

1986 Recommended 

Practice for Protection 

and Coordination of 

Industrial and 

Commercial Power 

Systems (IEEE Buff 

Book) 

NFPA 70 - National 

Electrical Code® 

The MSHA rule is a design-specific standard. 

The NFPA and IEEE standards were used as a 

source for the rule; however, the exact 

requirements of the rule were tailored to apply 

specifically to electric circuits and equipment 

used in the coal mining industry. 

7* DOL Exit Routes, Emergency 

Action Plans, and Fire 

Prevention Plans, 29 CFR 

1910, Subpart E

Life Safety Code, 

NFPA 101-2000 

The OSHA standard addresses only workplace 

conditions whereas the NFPA Life Safety Code 

goes beyond workplaces. However, in the final 

rule OSHA stated that it had evaluated the 

NFPA Standard 101, Life Safety Code, (NFPA 

101-2000) and concluded that it provided 

comparable safety to the Exit Route Standards. 

Therefore, the Agency stated that any employer 

who complied with the NFPA 101-2000 instead 

of the OSHA Standard for Exit Routes would be 

in compliance. 

8* DOL Sanitary Toilets in Coal 

Mines, 30 CFR 71, 

Subpart E 

Non-Sewered Waste 

Disposal Systems--

Minimum 

Requirements, ANSI 

Z4.3-1987 

The ANSI standard was not incorporated by 

reference because certain design criteria allowed 

in the ANSI standard, if implemented in an 

underground coal mine, could present health or 

safety hazards. For instance, combustion or 

incinerating toilets could introduce an ignition 

source which would create a fire hazard. For 

certain other design criteria found in the ANSI 

standard, sewage could seep into the 

groundwater, or overflow caused by rain or runoff could contaminate portions of the mine. 

9 DOL Steel Erection Standards ANSI A10.13, Steel 

Erection; ASME/ANSI 

Many consensus standards were relied upon for 

various provisions in the final rule, but there was 
C-3

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

B30 series Cranes 

standards 

no one consensus standard available that covered 

all of the topics covered by OSHA's final rule. 

10 DOT Brake Performance, 49 

CFR 393.52, – FMCSA’s 

Performance-Based Brake 

Testers (PBBTs) 

requirement. 

SAE J667 – Brake Test 

Code Inertia 

Dynamometer 

(cancelled February, 

2002) 

SAE J1854 – Brake 

Force Distribution 

Performance Guide – 

Trucks and Buses 

FMCSA used government-unique standards in 

lieu of voluntary consensus standards when it 

implemented its final rule to allow inspectors to 

use performance-based brake testers (PBBTs) to 

check the brakes on large trucks and buses for 

compliance with federal safety standards and to 

issue citations when these vehicles fail (67 FR 

51770, August 9, 2002). The FMCSA evaluated 

several PBBTs during a round robin test series to 

assess their functional performance and potential 

use in law enforcement. The standard, a specific 

configuration of brake forces and wheel loads on 

a heavy-duty vehicle, was used to evaluate the 

candidate PBBTs and their operating protocols. 

The agency’s rationale for use of the 

government-unique standards was to verify that 

these measurements and new technology could 

be used by law enforcement as an alternative to 

stopping distance tests or on-road deceleration 

tests. PBBTs are expected to save time and their 

use could increase the number of commercial 

motor vehicles that can be inspected in a given 

time. Only PBBTs that meet specifications 

developed by the FMCSA can be used to 

determine compliance with the Federal Motor 

Carrier Safety Regulations. The final rule 

represents a culmination of agency research that 

began in the early 1990s. 

11 DOT 63 FR 17976; April 13, 

1998 - Product Safety 

Signs and Labels 

ANSI Z535.4 - ANSI 

Requirements for Color 

Coded Header 

Messages for the 

Different Levels of 

Hazard 

Since agency labeling decisions are highly 

dependent on the facts regarding the specific 

hazard being addressed, NHTSA anticipates 

making case-by-case determinations of the 

extent to which it should follow voluntary 

standards versus information from focus groups 

and other sources. NHTSA will rely on its own 

expertise and judgment in making 

determinations under the NTTAA and the 

statutory provisions regarding vehicle safety 

standards. 

12 DOT Air Bag Warning Label 

(1997) 

ANSI 

ISO 

The Air Bag Warning Label uses yellow as the 

background color, instead of orange, in 

accordance with an ANSI standard, and uses a 

graphic developed by Chrysler Corporation to 

depict the hazards of being too close to an air 

bag, instead of the graphic recommended by the 

ISO. These decisions were based on focus group 

testing sponsored by the agency which strongly 

indicated that these unique requirements would 

be far more effective with respect to safety than 
C-4

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

the industry standards. 

13 EPA 40 CFR 89 – Control of 

Emissions from New and 

In-Use Non-Road 

Compression Ignition 

Engines 

ISO 8178 – 

Reciprocating Internal 

Combustions Engines, 

Exhaust Emission 

Measurement 

Procedures would be impractical because they 

rely too heavily on reference testing conditions. 

Agency decides instead to continue to rely on 

procedures outlined in 40 CFR Part 90. 

14 EPA 40 CFR 90 – Control of 

Emission from Non-Road 

Spark Ignition Engines at 

or below 19KV 

ISO 8178 – 

Reciprocating Internal 

Combustions Engines, 

Exhaust Emission 

Measurement 

Procedures would be impractical because they 

rely too heavily on reference testing conditions. 

Agency decides instead to continue to rely on 

procedures outlined in 40 CFR Part 90. 

15 EPA 40 CFR 92 – Control of 

Air Pollution from 

Locomotives and 

Locomotive Engines 

ISO 8178 – 

Reciprocating Internal 

Combustions Engines, 

Exhaust Emission 

Measurement 

Procedures would be impractical because they 

rely too heavily on reference testing conditions. 

Agency decides instead to continue to rely on 

procedures outlined in 40 CFR Part 90. 

ASTM D3154-00, 

Standard Method for 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers (e.g., 

magnehelic gauges) are used, their calibration 

must be checked after each test series; and (3) 

the frequency and validity range for calibration 

of the temperature sensors. 2. They are too 

general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory 

requirements. 

16 EPA EPA Method 1 – Traverse 

Points, Stationary Sources 

ASTM D3154-91 

(1995), "Standard 

Method for Average 

Velocity in a Duct 

(Pitot Tube Method)" 

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements. 

ASTM 3796-90 (1998), 

"Standard Practice for 

Calibration of Type S 

Pitot Tubes" 

The standard lacked sufficient quality control 

specifications to ensure meeting the regulatory 

levels required in the rule; the standard also 

includes detection limits not consistent with the 

rule. Rule: "National Emission Standards for 

Hazardous Air Pollutants; Engine Test 

Cells/Stands" 

17 EPA EPA Method 2 – Velocity 

and S-type Pitot 

ASTM D3464-96 

(2001), Standard Test 

Method Average 

Velocity in a Duct 

Using a Thermal 

Anemometer 

Applicability specifications are not clearly 

defined, e.g., range of gas composition, 

temperature limits. Also, the lack of supporting 

quality assurance data for the calibration 

procedures and specifications, and certain 

variability issues that are not adequately 

addressed by the standard limit EPA's ability to 

make a definitive comparison of the method in 

these areas. 
C-5

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

ISO 10780:1994, 

Stationary Source 

Emissions-- 

Measurement of 

Velocity and Volume 

Flowrate of Gas 

Streams in Ducts 

The standard recommends the use of an 

L-shaped pitot, which historically has not been 

recommended by EPA. The EPA specifies the 

S-type design, which has large openings that are 

less likely to plug up with dust. 

ASTM D3154-00, 

Standard Method for 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers (e.g., 

magnehelic gauges) are used, their calibration 

must be checked after each test series; and (3) 

the frequency and validity range for calibration 

of the temperature sensors. 2. They are too 

general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory 

requirements. 

 

ASTM D3154-91 

(1995), “Standard 

Method for Average 

Velocity in a Duct 

(Pitot Tube Method)” 

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements. 

18 EPA EPA Method 2C – 

Velocity and Flow Rate, 

Standard Pitot 

ASTM D3154-00, 

Standard Method for 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers (e.g., 

magnehelic gauges) are used, their calibration 

must be checked after each test series; and (3) 

the frequency and validity range for calibration 

of the temperature sensors. 2. They are too 

general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory 

requirements. 

ASME C00031 or PTC 

19-10-1981--part 10, 

"Flue and Exhaust Gas 

Analyses" 

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements. 

19 EPA EPA Method 3 – 

Molecular Weight Carbon 

Dioxide, Oxygen 

ASTM D3154-00, 

Standard Method for 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers (e.g., 
C-6

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

 magnehelic gauges) are used, their calibration 

must be checked after each test series; and (3) 

the frequency and validity range for calibration 

of the temperature sensors. 2. They are too 

general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory 

requirements. 

ASTM D5835-95, 

Standard Practice for 

Sampling Stationary 

Source Emissions for 

Automated 

Determination of Gas 

Concentration 

1. They lack in detail and quality 

assurance/quality control requirements. 

Specifically, these two standards do not include 

the following: (1) Sensitivity of the method; 

(2) acceptable levels of analyzer calibration 

error; (3) acceptable levels of sampling system 

bias; (4) zero drift and calibration drift limits, 

time span, and required testing frequency; (5) a 

method to test the interference response of the 

analyzer; (6) procedures to determine the 

minimum sampling time per run and minimum 

measurement time; and (7) specifications for 

data recorders, in terms of resolution (all types) 

and recording intervals (digital and analog 

recorders, only). 2. Is too general, too broad, or 

not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

CAN/CSA Z223.2-

M86(1986), Method for 

the Continuous 

Measurement of 

Oxygen, Carbon 

Dioxide, Carbon 

Monoxide, Sulphur 

Dioxide, and Oxides of 

Nitrogen in Enclosed 

Combustion Flue Gas 

Stream 

1. It does not include quantitative specifications 

for measurement system performance, most 

notably the calibration procedures and 

instrument performance characteristics. The 

instrument performance characteristics that are 

provided are nonmandatory and also do not 

provide the same level of quality assurance as 

the EPA methods. For example, the zero and 

span/calibration drift is only checked weekly, 

whereas the EPA methods requires drift checks 

after each run. 2. Is too general, too broad, or 

not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

20 EPA EPA Method 3A – 

Carbon Dioxide and 

Oxygen Concentrations, 

IAP 

ISO 10396:1993, 

Stationary Source 

Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

1. They lack in detail and quality 

assurance/quality control requirements. 

Specifically, these two standards do not include 

the following: (1) Sensitivity of the method; 

(2) acceptable levels of analyzer calibration 

error; (3) acceptable levels of sampling system 

bias; (4) zero drift and calibration drift limits, 

time span, and required testing frequency; (5) a 

method to test the interference response of the 

analyzer; (6) procedures to determine the 

minimum sampling time per run and minimum 

measurement time; and (7) specifications for 
C-7

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

data recorders, in terms of resolution (all types) 

and recording intervals (digital and analog 

recorders, only). 2. Is too general, too broad, or 

not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

 

ISO 12039:2001, 

Stationary Source 

Emissions-- 

Determination of 

Carbon Monoxide, 

Carbon Dioxide, and 

Oxygen--Automated 

Methods 

This ISO standard is similar to EPA Method 3A, 

but is missing some key features. In terms of 

sampling, the hardware required by ISO 

12039:2001 does not include a 3-way calibration 

valve assembly or equivalent to block the sample 

gas flow while calibration gases are introduced. 

In its calibration procedures, ISO 12039:2001 

only specifies a two-point calibration while EPA 

Method 3A specifies a three-point calibration. 

Also, ISO 12039:2001 does not specify 

performance criteria for calibration error, 

calibration drift, or sampling system bias tests as 

in the EPA method, although checks of these 

quality control features are required by the ISO 

standard. 

ASTM D3154-00, 

Standard Method for 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers (e.g., 

magnehelic gauges) are used, their calibration 

must be checked after each test series; and (3) 

the frequency and validity range for calibration 

of the temperature sensors. 2. They are too 

general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory 

requirements. 

21 EPA Method 3B – Oxygen, 

Carbon Dioxide, Carbon 

Monoxide, Emission Rate 

Correction Factor 

ASTM D3154-91 

(1995), "Standard 

Method for Average 

Velocity in a Duct 

(Pitot Tube Method)" 

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements. 

ASTM E337-84 

(1996), "Standard Test 

Method for Measuring 

Humidity with a 

Psychrometer (the 

Measurement of Wetand Dry-Bulb 

Temperatures)" 

They are too general, too broad, or not 

sufficiently detailed to assure compliance with 

EPA regulatory requirements. 

22 EPA EPA Method 4 – Moisture 

Content in Stack Gases 

ASTM D3154-00, 

Standard Method for 

1. The standard appears to lack in quality 

control and quality assurance requirements. It 
C-8

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Average Velocity in a 

Duct (Pitot Tube 

Method) 

does not include the following: (1) Proof that 

openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges 

other than inclined manometers 

 (e.g., magnehelic gauges) are used, their 

calibration must be checked after each test 

series; and (3) the frequency and validity range 

for calibration of the temperature sensors. 

2. They are too general, too broad, or not 

sufficiently detailed to assure compliance with 

EPA regulatory requirements. 

 

ASTM D3154-91 

(1995), "Standard 

Method for Average 

Velocity in a Duct 

(Pitot Tube Method)" 

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements. 

ASME PTC-38-80 R85 

or C00049, 

"Determination of the 

Concentration of 

Particulate Matter in 

Gas Streams" 

It lacks sufficient quality assurance and quality 

control requirements necessary for EPA 

compliance assurance requirements. 

ASTM 

D3685/D3685M-98, 

“Test Methods for 

Sampling and 

Determination of 

Particulate Matter in 

Stack Gases.” 

It lacks sufficient quality assurance and quality 

control requirements necessary for EPA 

compliance assurance requirements. 

23 EPA EPA Method 5 – 

Particulate Matter, 

Stationary Sources 

ISO 9096:1992, 

"Determination of 

Concentration and 

Mass Flow Rate of 

Particulate Matter in 

Gas Carrying Ducts-- 

Manual Gravimetric 

Method" 

It lacks sufficient quality assurance and quality 

control requirements necessary for EPA 

compliance assurance requirements. 

24 EPA EPA Method 5i – Low 

Level Particulate Matter, 

Stationary Sources 

ASTM D6331-98 This standard does not have paired trains as 

specified in method 5 and does not include some 

quality control procedures specified in the EPA 

method and which are appropriate to use in this 

rule. 

ASME C00031 or PTC 

19-10-1981 - Part 10 

Flue and Exhaust Gas 

Analyses 

Too broad to be useful in regulatory sense. 

Covers Methods 3, 6, 7, and 15 with variants. 

25 EPA EPA Method 6 – Sulphur 

Dioxide Emissions 

ISO 7934:1998 - 

Stationary Source 

Emissions - 

This standard is only applicable to sources with 

30 mg/m3 SO2 or more. In addition, this 

method does not separate SO3 from SO2 as does 
C-9

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Determination of the 

Mass Concentration of 

Sulfur Dioxide - 

Hydrogen 

Peroxide/Barium 

Perchlorate/ Thorin 

Method 

EPA Method 6; therefore, this method is not 

valid if more than a negligible amount of SO3 is 

present. Also, does not address ammonia 

interferences. 

 

ISO 11632:1998 - 

Stationary Source 

Emissions - 

Determination of the 

Mass Concentration of 

Sulfur Dioxide - Ion 

Chromatography 

ISO 11632:1998 - Stationary Source Emissions - 

Determination of the Mass Concentration of 

Sulfur Dioxide - Ion Chromatography 

(NIST HAS A CALL IN TO EPA 

REGARDING THIS BOX) 

ISO 10396:1993 - 

Stationary Source 

Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

Duplicates Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to 

ASTM D5835. 

ASTM D5835-95 - 

Standard Practice for 

Sampling Stationary 

Source Emissions for 

Automated 

Determination of Gas 

Concentration. 

Similar to Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396. 

26 EPA EPA Method 6c – Sulphur 

Dioxide Emissions, 

Stationary by IAP 

CAN/CSA Z223.2-

M86 - (1986) Method 

for the Continuous 

Measurement of 

Oxygen, Carbon 

Doixide, Carbon 

Monoxide, Sulphur 

Dioxide, and Oxides of 

Nitrogen in Enclosed 

Combustion Flue Gas 

Streams 

Too general. This standard lacks in detail and 

quality assurance/quality control requirements. 

Appendices with valid quality control 

information are not a required 

27 EPA EPA Method 7 – Nitrogen 

Oxide Emissions, 

Stationary Sources 

ASME C00031 or PTC 

19-10-1981 - Part 10 

Flue and Exhaust Gas 

Analyses 

Too broad to be useful in regulatory sense. 

Covers Methods 3, 6, 7, and 15 with variants. 

ISO 10396:1993 - 

Stationary Source 

Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

Duplicates Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to 

ASTM D5835. 

28 EPA EPA Method 7e – 

Nitrogen Oxide, 

Instrumental 

ASTM D5835-95 - Similar to Methods 3a, 6c, 7e, 10, ALT 004 and 
C-10

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Standard Practice for 

Sampling Stationary 

Source Emissions for 

Automated 

Determination of Gas 

Concentration. 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396. 

 

CAN/CSA Z223.2-

M86 - (1986) Method 

for the Continuous 

Measurement of 

Oxygen, Carbon 

Doixide, Carbon 

Monoxide, Sulphur 

Dioxide, and Oxides of 

Nitrogen in Enclosed 

Combustion Flue Gas 

Streams 

Too general. This standard lacks in detail and 

quality assurance/quality control requirements. 

Appendices with valid quality control 

information are not a required part of this 

method. 

ASTM D3162 (1994) 

Standard Test Method 

for Carbon Monoxide 

in the Atmosphere 

(Continuous 

Measurement by Nondispersive Infrared 

Spectrometry) 

This ASTM standard, which is stated to be 

applicable in the range of 0.5-100 ppm CO, does 

not cover the range of EPA Method 10 (20-1,000 

ppm CO) at the upper end (but states that it has a 

lower limit of sensitivity). Also, ASTM D3162 

does not provide a procedure to remove carbon 

dioxide interference. Therefore, this ASTM 

standard is not appropriate for combustion 

source conditions. In terms of non-dispersive 

infrared instrument performance specifications, 

ASTM D3162 has much higher maximum 

allowable rise and fall times (5 minutes) than 

EPA Method 10 (which has 30 seconds). 

29 EPA EPA Method 10 – Carbon 

Monoxide, NDIR 

CAN/CSA Z223.21-

M1978, Method for the 

Measurement of 

Carbon Monoxide: 3—

Method of Analysis by 

Non-Dispersive 

Infrared Spectrometry. 

1. It is lacking in the following areas: (1) 

Sampling procedures; (2) procedures to correct 

for the carbon dioxide concentration; 

(3) instructions to correct the gas volume if CO2 

traps are used; (4) specifications to certify the 

calibration gases are within 2 percent of the 

target concentration; (5) mandatory instrument 

performance characteristics (e.g., rise time, fall 

time, zero drift, span drift, and precision); 

(6) quantitative specification of the span value 

maximum as compared to the measured value: 

The standard specifies that the instruments 

should be compatible with the concentration of 

gases to be measured, whereas EPA Method 10 

specifies that the instrument span value should 

be no more than 1.5 times the source 

performance standard. 2. Is too general, too 

broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

30 EPA EPA Method 10A – CAN/CSA Z223.21- 1. It is lacking in the following areas: (1) 
C-11

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Carbon Monoxide for 

Certifying CEMS 

M1978, Method for the 

Measurement of 

Carbon Monoxide: 3—

Method of Analysis by 

Non-Dispersive 

Infrared Spectrometry. 

Sampling procedures; (2) procedures to correct 

for the carbon dioxide concentration; 

(3) instructions to correct the gas volume if CO2 

traps are used; (4) specifications to certify the 

calibration gases are within 2 percent of the 

target concentration; (5) mandatory instrument 

performance characteristics (e.g., rise time, fall 

time, zero drift, span drift, and precision); 

(6) quantitative specification of the span value 

maximum as compared to the measured value: 

The standard specifies that the instruments 

should be compatible with the concentration of 

gases to be measured, whereas EPA Method 10 

specifies that the instrument span value should 

be no more than 1.5 times the source 

performance standard. 2. Is too general, too 

broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

ASTM D4358-94 

(1999), "Standard Test 

Method for Lead and 

Chromium in Air 

Particulate Filter 

Samples of Lead 

Chromate Type 

Pigment Dusts by 

Atomic Absorption 

Spectroscopy" 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and, therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29. 

31 EPA EPA Method 12 – 

Inorganic Lead, 

Stationary Sources 

ASTM E1741-95 

(1995), "Standard 

Practice for Preparation 

of Airborne Particulate 

Lead Samples 

Collected During 

Abatement and 

Construction Activities 

for Subsequent 

Analysis by Atomic 

Spectrometry" 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and, therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 
C-12

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

which cannot be considered equivalent to EPA 

Method 29. 

 

ASTM E1979-98 

(1998), "Standard 

Practice for Ultrasonic 

Extraction of Paint, 

Dust, Soil, and Air 

Samples for 

Subsequent 

Determination of Lead" 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and, therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29. 

ASME C00031 or PTC 

19-10-1981 - Part 10 

Flue and Exhaust Gas 

Analyses 

Too broad to be useful in regulatory sense. 

Covers Methods 3, 6, 7, and 15 with variants. 

32 EPA EPA Method 15 – 

Hydrogen Sulfide/Carbon 

Disulfide/Carbon Sulfide 

ASTM D4323-84 

(1997) - Standard Test 

Method for Hydrogen 

Sulfide in the 

Atmosphere by Rate of 

Change of Reflectance 

ASTM D4323 only applies to concentrations of 

H2S from 1 ppb to 3 ppm without dilution. 

Many QC items are missing, such as calibration 

drift and sample line losses. The calibration 

curve is determined with only one point. 

ASTM D3685/3685M95 – Standard Test 

Method for Sampling 

and Determination of 

Particulate Matter in 

Stack Gases 

EPA looked at this standard for both Pulp and 

Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. 

Contains sampling options beyond which would 

be considered acceptable for Method 5. 

 

33 EPA EPA Method 17 – 

Particulate Matter (PM), 

In Stack Filtration 

ASME C00049 EPA looked at this standard for both Pulp and 

Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. Too 

flexible in allowing for more train configurations 

than is appropriate for purposes of this rule. 

34 EPA EPA Method 18 – 

VOC/GC 

ASTM D6060-96 (in 

review 2000) - Practice 

for Sampling of 

Process Vents with a 

Portable Gas 

Chromatography 

This standard lacks key quality control and 

assurance that is required for EPA Method 18. 

For example: lacks acceptance criteria for 

calibration, details on using other collection 

media (e.g. solid sorbents), and reporting/ 

documentation requirements. 

35

* 

EPA EPA Method 21 – 

Volatile Organic 

Compound (VOC) Leaks 

ASTM E1211-97 - 

Standard Practice for 

Leak Detection and 

Location Using 

Surface-Mounted 

This standard will detect leaks but not “classify” 

the leak as VOC, as in EPA Method 21. In 

addition, in order to detect the VOC 

concentration of a known VOC leak, the 

acoustic signal would need to be calibrated 
C-13

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Acoustic Emission 

Sensors 

against a primary instrument. Background noise 

interference in some source situations could also 

make this standard difficult to use effectively. 

36 EPA EPA Method 23 – Dioxin 

and Furan (PCDD and 

PCDF) 

European Committee 

for Standardization 

(CEN) EN 1948-3 

(1997), "Determination 

of the Mass 

Concentration of 

PCDD'S/PCDF'S--Part 

3: Identification and 

Quantification" 

Upper and lower detection limits do not support 

regulatory levels specified in Rule # 68 FR 

5144-01, 2003 (WL 201268) "Federal Plan 

Requirements for Small Municipal Waste 

Combustion Units Constructed On or Before 

August 30, 1999." 

ISO 11890-1 (2000) 

part 1, "Paints and 

Varnishes--

Determination of 

Volatile Organic 

Compound (VOC) 

Content-Difference 

Method" 

Measured nonvolatile matter content can vary 

with experimental factors such as temperature, 

length of heating period, size of weighing dish, 

and size of sample. The standard ISO 11890-1 

allows for different dish weights and sample 

sizes than the one size (58 millimeters in 

diameter and sample size of 0.5 gram) of EPA 

Method 24. The standard ISO 11890-1 also 

allows for different oven temperatures and 

heating times depending on the type of coating, 

whereas EPA Method 24 requires 60 minutes 

heating at 110 degrees Celcius at all times. 

Because the EPA Method 24 test conditions and 

procedures "define" volatile matter, ISO 11890-1 

is unacceptable as an alternative because of its 

different test conditions. 

37 EPA EPA Method 24 – Surface 

Coatings, Volatile Matter 

Content 

ISO 11890-2 (2000) 

part 2, "Paints and 

Varnishes--

Determination of 

Volatile Organic 

Compound (VOC) 

Content-Gas 

Chromatographic 

Method" 

ISO 11890-2 only measures the VOC added to 

the coating and would not measure any VOC 

generated from the curing of the coating. The 

EPA Method 24 does measure "cure" VOC, 

which can be significant in some cases, and, 

therefore, ISO 11890-2 is not an acceptable 

alternative to this EPA method. 

EN 12619:1999 

Stationary Source 

Emissions--

Determination of the 

Mass Concentration of 

Total Gaseous Organic 

Carbon at Low 

Concentrations in Flue 

Gases--Continuous 

Flame Ionization 

Detector Method 

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher. 

38 EPA EPA Method 25 – 

Gaseous Nonmethane 

Organic Emissions 

ISO 14965:2000(E) Air 

Quality--Determination 

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 
C-14

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

 of Total Nonmethane 

Organic Compounds--

Cryogenic 

Preconcentration and 

Direct Flame Ionization 

Method 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher. 

EN 12619:1999 

Stationary Source 

Emissions--

Determination of the 

Mass Concentration of 

Total Gaseous Organic 

Carbon at Low 

Concentrations in Flue 

Gases--Continuous 

Flame Ionization 

Detector Method 

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher. 

39 EPA EPA Method 25A – 

Gaseous Organic 

Concentration, Flame 

Ionization 

ISO 14965:2000(E) Air 

Quality--Determination 

of Total Nonmethane 

Organic Compounds--

Cryogenic 

Preconcentration and 

Direct Flame Ionization 

Method 

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher. 

40 EPA EPA Method 26 – 

Hydrogen Chloride, 

Halides, Halogens 

Emissions 

EN 1911-1,2,3 (1998), 

"Stationary Source 

Emissions-- Manual 

Method of 

Determination of HCl--

Part 1: Sampling of 

Gases Ratified 

European Text--Part 2: 

Gaseous Compounds 

Absorption Ratified 

European Text-- Part 3: 

Adsorption Solutions 

Analysis and 

Calculation Ratified 

European Text" 

Part 3 of this standard cannot be considered 

equivalent to EPA Method 26 or 26A because 

the sample absorbing solution (water) would be 

expected to capture both HCl and Cl2 gas, if 

present, without the ability to distinguish 

between the two. The EPA Methods 26 and 26A 

use an acidified absorbing solution to first 

separate HCl and Cl2 gas so that they can be 

selectively absorbed, analyzed, and reported 

separately. In addition, in EN 1911 the 

absorption efficiency for Cl2 gas would be 

expected to vary as the pH of the water changed 

during sampling. 

41 EPA EPA Method 26A – 

Hydrogen Halide and 

Halogen, Isokinetic 

EN 1911-1,2,3 (1998), 

"Stationary Source 

Emissions-- Manual 

Method of 

Determination of HCl--

Part 1: Sampling of 

Gases Ratified 

European Text--Part 2: 

Gaseous Compounds 

Absorption Ratified 

European Text-- Part 3: 

Part 3 of this standard cannot be considered 

equivalent to EPA Method 26 or 26A because 

the sample absorbing solution (water) would be 

expected to capture both HCl and Cl2 gas, if 

present, without the ability to distinguish 

between the two. The EPA Methods 26 and 26A 

use an acidified absorbing solution to first 

separate HCl and Cl2 gas so that they can be 

selectively absorbed, analyzed, and reported 

separately. In addition, in EN 1911 the 

absorption efficiency for Cl2 gas would be 
C-15

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Adsorption Solutions 

Analysis and 

Calculation Ratified 

European Text" 

expected to vary as the pH of the water changed 

during sampling. 

ASME Power Test 

Codes, "Supplement on 

Instruments and 

Apparatus, part 5, 

Measurement of 

Quantity of Materials, 

Chapter 1, Weighing 

Scales" 

It does not specify the number of initial 

calibration weights to be used nor a specific 

pretest weight procedure. 

42 EPA EPA Method 28 (Section 

10.1) – Wood Heaters, 

Certificate and Auditing 

ASTM E319-85 

(Reapproved 1997), 

"Standard Practice for 

the Evaluation of 

Single-Pan Mechanical 

Balances" 

This standard is not a complete weighing 

procedure because it does not include a pretest 

procedure. 

CAN/CSA Z223.26-

M1987, "Measurement 

of Total Mercury in Air 

Cold Vapour Atomic 

Absorption 

Spectrophotometeric 

Method" 

It lacks sufficient quality assurance and quality 

control requirements necessary for EPA 

compliance assurance requirements. 

ASTM D4358-94 

(1999), "Standard Test 

Method for Lead and 

Chromium in Air 

Particulate Filter 

Samples of Lead 

Chromate Type 

Pigment Dusts by 

Atomic Absorption 

Spectroscopy" 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29. 

43 EPA EPA Method 29 – Metals 

Emissions from 

Stationary Sources 

ASTM E1741-95 

(1995), "Standard 

Practice for Preparation 

of Airborne Particulate 

Lead Samples 

Collected During 

Abatement and 

Construction Activities 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 
C-16

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

for Subsequent 

Analysis by Atomic 

Spectrometry" 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29. 

 

ASTM E1979-98 

(1998), "Standard 

Practice for Ultrasonic 

Extraction of Paint, 

Dust, Soil, and Air 

Samples for 

Subsequent 

Determination of Lead" 

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA 

Method 29 and therefore, they cannot be used 

for the preparation, digestion, and analysis of 

Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29. 

44 EPA EPA Method 101 – 

Mercury Emissions, 

Chlor-Alkali Plants (Air) 

ASTM D6216-98 - 

Standard Practice for 

Opacity Monitor 

Manufacturers to 

Certify Conformance 

with Design and 

Performance 

Specifications. 

The EPA is incorporating ASTM D6216 

(manufacturers certification) by reference into 

EPA Performance Specification 1, Sect. 5 & 6 in 

another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1. 

45 EPA EPA Method 101a – 

Mercury Emissions – 

Sewer/Sludge Incinerator 

ASTM D6216-98 - 

Standard Practice for 

Opacity Monitor 

Manufacturers to 

Certify Conformance 

with Design and 

Performance 

Specifications. 

The EPA is incorporating ASTM D6216 

(manufacturers certification) by reference into 

EPA Performance Specification 1, Sect. 5 & 6 in 

another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1. 

46 EPA EPA Method 180.1 – 

Turbidity, Nephelometric 

ISO 7027 – Water 

Quality - Determination 

of Turbidity 

EPA has no data upon which to evaluate whether 

the separate 90 degrees scattered or transmitted 

light measurement evaluations according to the 

ISO 7027 method would produce results that are 

equivalent to results produced by the other 

methods. 

47

* 

EPA EPA Method 306 – 

Chromium Emissions, 

Electroplating and 

Anodizing 

ASTM D4358-94 

(1999) - Standard Test 

Method for Lead and 

Chromium in Air 

This MACT standard (Petroleum Refineries) 

only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 

not Method 12 and 306: Method 29 requires the 
C-17

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

 Particulate Filter 

Samples of Lead 

Chromate Type 

Pigment Dusts by 

Atomic Absorption 

Spectroscopy 

use of hydrofluoric acid (HF) in its process of 

digestion of the sample. ASTM D4358-94 

(1999) does not require the use of HF; therefore, 

it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. 

Additionally, Method 29 requires the use of a 

glass fiber filter, whereas the subject ASTM 

standard requires cellulose filters and other 

probable non-glass fiber media, and this further 

negates their use as Method 29 equivalent 

methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979). 

48

* 

EPA EPA Method 306a – 

Chromium Emissions, 

Electroplating—Mason 

Jar 

ASTM D4358-94 

(1999) - Standard Test 

Method for Lead and 

Chromium in Air 

Particulate Filter 

Samples of Lead 

Chromate Type 

Pigment Dusts by 

Atomic Absorption 

Spectroscopy 

This MACT standard (Petroleum Refineries) 

only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 

not Method 12 and 306: Method 29 requires the 

use of hydrofluoric acid (HF) in its process of 

digestion of the sample. ASTM D4358-94 

(1999) does not require the use of HF; therefore, 

it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. 

Additionally, Method 29 requires the use of a 

glass fiber filter, whereas the subject ASTM 

standard requires cellulose filters and other 

probable non-glass fiber media, and this further 

negates their use as Method 29 equivalent 

methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979). 

49 EPA EPA Method 320 – Vapor 

Phase Organic and 

Inorganic Emissions, 

FTIR 

ASTM D6348-98, 

"Determination of 

Gaseous Compounds 

by Extractive Direct 

Interface Fourier 

Transform (FTIR) 

Spectroscopy" 

Suggested revisions to ASTM D6348-98 were 

sent to ASTM by the EPA that, would allow the 

EPA to accept ASTM D6348-98 as an 

acceptable alternative. The ASTM 

Subcommittee D22-03 is currently undertaking a 

revision of ASTM D6348- 98. Because of this, 

we are not citing this standard as a acceptable 

alternative for EPA Method 320 in the final rule 

today. However, upon successful ASTM 

balloting and demonstration of technical 

equivalency with the EPA FTIR methods, the 

revised ASTM standard could be incorporated 

by reference for EPA regulatory applicability. 

In the interim, facilities have the option to 

request ASTM D6348-98 as an alternative test 

method under 40 CFR 63.7(f) and 63.8(f) on a 

case-by-case basis. 

50 EPA EPA Method 515.1 – 

Chlorinated Acids in 

Water by GC/ECD 

Standard Methods 

6640B 

Standard Methods 6640B for acid herbicides 

was tentatively deemed impractical for EPA’s 

needs because its sample preparation and quality 

control procedures were not similar enough to 

EPA Method 515.1 to ensure that there would 

not be underreporting of acid herbicide 
C-18

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

contamination. EPA plans to offer to work with 

the Standard Methods committee to resolve this 

issue prior to the next publication. 

ASTM D5317-98 -- 

Standard Test Method 

For Determination of 

Chlorinated Organic 

Acid Compounds in 

Water by Gas 

Chromatography With 

an Electron Capture 

Detector 

ASTM D5317-98 specifies acceptance windows 

for the initial demonstration of proficiency for 

laboratory fortified blank samples that are as 

small as 0 percent to as large as 223 percent 

recovery for picloram, with tighter criteria for 

other regulated contaminants. Therefore, this 

method permits unacceptably large control 

limits, which include 0 percent recovery. 

51 EPA EPA Method 515.4 – 

Chlorinated Acids in DW 

by LL Fast CG/ECD 

Standard Method 6640 

B for the chlorinated 

acids Standard Method 

6640 B for the 

chlorinated acids 

The use of this voluntary consensus standard 

would have been impractical due to significant 

shortcomings in the sample preparation and 

quality control sections of the method 

instructions. Section 1b of Method SM 6640 B 

states that the alkaline wash detailed in section 

4b2 is optional. The hydrolysis that occurs 

during this step is essential to the analysis of the 

esters of many of the analytes. Therefore, this 

step is necessary and cannot be optional. In 

addition, the method specifies that the quality 

control limits for laboratory-fortified blanks are 

to be based upon plus or minus three times the 

standard deviation of the mean recovery of the 

analytes, as determined in each laboratory. 

Therefore, this method permits unacceptably 

large control limits, which may include 0 percent 

recovery. 

52 EPA EPA Method 531.2–NMethylcarbamoylozimes/

ates, Aqueous In/HPLC 

Standard Method 6610, 

20th Edition 

Standard Method 6610, 20th Edition has recently 

been approved for compliance monitoring. 

Standard Method 6610, 20th Supplemental 

Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The 

preservatives in all of the other approved EPA 

and Standard Methods procedures for these 

analytes are weak acids that adjust the pH to a 

specific value based upon the pKa of the 

preservative. The use of HCL would require 

accurate determinations of the pH of the sample 

in the field and could be subject to considerable 

error and possible changes in pH upon storage. 

Although not specifically observed for oxamyl 

or carbofuran during the development of similar 

methods, structurally similar pesticides have 

been shown to degrade over time when kept at 

pH 3. Therefore, approval of this method is 

impractical because it specifies the use of a 

strong acid (HCL) when positive control of the 

pH is critical. 
C-19

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Standard Method 6610, 

20th Supplemental 

Edition 

Standard Method 6610, 20th Edition has recently 

been approved for compliance monitoring. 

Standard Method 6610, 20th Supplemental 

Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The 

preservatives in all of the other approved EPA 

and Standard Methods procedures for these 

analytes are weak acids that adjust the pH to a 

specific value based upon the pKa of the 

preservative. The use of HCL would require 

accurate determinations of the pH of the sample 

in the field and could be subject to considerable 

error and possible changes in pH upon storage. 

Although not specifically observed for oxamyl 

or carbofuran during the development of similar 

methods, structurally similar pesticides have 

been shown to degrade over time when kept at 

pH 3. Therefore, approval of this method is 

impractical because it specifies the use of a 

strong acid (HCL) when positive control of the 

pH is critical. 

53 EPA EPA Method 1650 – 

Organic Halides, 

Absorbable (AOX) 

ISO, DIN, SCAN, and 

Standard Methods (SM 

5320) – No Titles 

Found 

EPA decided to use EPA Method 1650. This 

Method was developed by drawing on various 

procedures contained in the methods of 

voluntary consensus standards bodies and other 

standards developers, such as ISO, DIN, SCAN, 

and Standard Methods (SM 5320). However, 

none of these more narrowly focused voluntary 

consensus standards contained the standardized 

quality control and quality control compliance 

criteria that EPA requires for data verification 

and validation in its water programs. Therefore, 

EPA found none of these VCS standing alone to 

meet EPA’s needs. 

ISO 10396:1993 - 

Stationary Source 

Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

Duplicates Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to 

ASTM D5835. 

 

54

* 

EPA EPA Method 

ALT 004 

ASTM D5835-95 - 

Standard Practice for 

Sampling Stationary 

Source Emissions for 

Automated 

Determination of Gas 

Concentration. 

Similar to Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396. 

55

* 

EPA EPA Method 

CTM 022 

ISO 10396:1993 - 

Stationary Source 

Duplicates Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 
C-20

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Emissions: Sampling 

for the Automated 

Determination of Gas 

Concentrations 

 

plus quality control requirements. Similar to 

ASTM D5835. 

 

ASTM D5835-95 - 

Standard Practice for 

Sampling Stationary 

Source Emissions for 

Automated 

Determination of Gas 

Concentration. 

Similar to Methods 3a, 6c, 7e, 10, ALT 004 and 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396. 

56 EPA EPA Method GG ASTM D3031-81 – 

Method of Test for 

Total Sulfur in Natural 

Gas (Hyrogenation), 

Withdrawn 

This method has been deleted from the final rule 

because it was discontinued by the ASTM in 

1990 with no replacement. If the total sulfur 

content of the fuel being fired in the turbine is 

less than 0.4 weight percent, we are adding a 

provision that the following methods may be 

used to measure the sulfur content of the fuel: 

ASTM D4084-82 or 94, D5504-01, D6228-98, 

or the Gas Processors Association Method 2377-

86. This provision is consistent with the 

provision in 40 CFR 60.13(j)(1) allowing 

alternatives to reference method tests to 

determine relative accuracy of CEMS for 

sources with emission rates demonstrated to be 

less than 50 percent of the applicable standard. 

57 EPA EPA Performance 

Specification 1 

ASTM D6216-98 – 

Standard Procedure for 

Opacity Monitor 

Manufacturers to 

Certify Conformance 

with Design and 

Performance 

Specifications. 

The standard does not address all the 

requirements specified in PS-1. 

58 EPA EPA Performance 

Specification 2 (nitrogen 

oxide portion only), PF, 

Performance 

Specifications 1-7 

ISO 10849:1996, 

"Determination of the 

Mass Concentration of 

Nitrogen Oxides--

Performance 

Characteristics of 

Automated Measuring 

Systems" 

Test methods options are not specific enough to 

meet the required regulatory levels specified 

in Rule # 68 FR 5144-01, 2003 (WL 201268) 

"Federal Plan Requirements for Small Municipal 

Waste Combustion Units Constructed On or 

Before August 30, 1999." 

 EPA Performance 

Specification 2 (sulfur 

dioxide portion only), PF, 

Performance 

Specifications 1-7 

ISO 7935:1992, 

"Stationary Source 

Emissions--

Determination of the 

Mass Concentration of 

Sulfur Dioxide--

Performance 

Characteristics of 

Test method options in the standard are not 

specific or rigorous enough to meet the 

regulatory levels specified in Rule # 68 FR 

5144-01, 2003 (WL 201268) "Federal Plan 

Requirements for Small Municipal Waste 

Combustion Units Constructed On or Before 

August 30, 1999." 
C-21

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Automated Measuring 

Methods" 

59 EPA EPA Performance 

Specifications 11 - 

Particulate Matter 

Continuous Monitoring 

System 

ISO 10155:1995 - 

Stationary Source 

Emissions Automated 

Monitoring of Mass 

Concentration of 

Particles – Performance 

Characteristics, Test 

Methods, and 

Specifications 

This international standard is only applicable on 

a site-specific basis by direct correlation with the 

manual method ISO 9096 (which does not 

produce particulate matter measurements like 

EPA Method 5). This appears to be a particulate 

matter (PM) CEMS performance specification 

similar to EPA Performance Specification (PS) 

11, but does not contain detailed RATA 

procedures. In addition, EPA does not have a 

final performance specification to compare this 

to. 

60 EPA GLI Method 2 ISO 7027 – Water 

Quality - Determination 

of Turbidity 

EPA has no data upon which to evaluate whether 

the separate 90 degrees scattered or transmitted 

light measurement evaluations according to the 

ISO 7027 method would produce results that are 

equivalent to results produced by the other 

methods. 

61 EPA Standard Method 2130B ISO 7027 – Water 

Quality - Determination 

of Turbidity 

EPA has no data upon which to evaluate whether 

the separate 90 degrees scattered or transmitted 

light measurement evaluations according to the 

ISO 7027 method would produce results that are 

equivalent to results produced by the other 

methods. 

ASTM C1111-98 

(1998) - Standard Test 

Method for 

Determining Elements 

in Waste Streams by 

Inductively Coupled 

Plasma-Atomic 

Emission 

Spectrometers 

This standard lacks details for instrument 

operation QA/QC, such as optimizing plasma 

operating conditions; upper limit of linear 

dynamic range; spectral interference correction; 

and calibration procedures, which include initial 

and continuous calibration verifications. Also 

lacks internal standard and method of standard 

addition options for samples with interferences. 

62 EPA SW846-6010b 

ASTM D6349-99 

(1999) - Standard Test 

Method for 

Determining Major and 

Minor Elements in 

Coal, Coke, and Solid 

Residues from 

Combustion of Coal 

and Coke by 

Inductively Coupled 

Plasma-Atomic 

Emission 

Spectrometers 

This standard lacks details for instrument 

operation QA/QC, such as optimizing plasma 

operating conditions, upper limit of linear 

dynamic range, spectral interference correction, 

and calibration procedures, that include initial 

and continuous calibration verifications. Also 

lacks details for standard preparation, and 

internal standard and method of standard 

addition options for samples with interferences. 

63 GSA Federal Specification AA-1925 – Shield, 

Expansion (Nail Anchors) 

ASTM E488 – 

Standard Test Methods 

for Strength of 

Anchors in Concrete 

and Masonry Elements 

This government-unique standard is prepared & 

maintained by the Defense Logistics Agency 

(DLA). Both the GSA & DLA contract for 

products that reference A-A-1925. In order to 

maintain product continuity in the federal 
C-22

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

marketplace, we must cite the standard as the 

DLA. 

64

* 

GSA Federal Specification 

KKK-A-1822E – Federal 

Specification for 

Ambulances 

ASTM F2020 – 

Standard Practice for 

Design, Construction, 

and Procurement of 

Emergency Medical 

Services Ambulances 

The ASTM “Standard Practice for Design, 

Construction, and Procurement of Emergency 

Medical Services (EMSS) Ambulances” (ASTM 

F2020) is not practical for use, and therefore 

GSA uses the Federal Specification for 

Ambulances (KKK-A-1822E). GSA has 

determined the ASTM document is not practical 

for use for the following reasons: 1) GSA has 

determined that ASTM F2020 contains specific 

practices that are technically and economically 

impractical to use for the acquisition of 

commercial based vehicles because the 

document is financially burdensome and 

technically ineffective. Specifically at issue is 

the ASTM Standard Specification for Medical 

Oxygen Delivery Systems for EMS Ground 

Vehicles, F1949-99 which is inclusive to ASTM 

F2020. 2) GSA has determined that ASTM 

F2020 is impractical because it is defined as a 

“standard practice” which is ambiguous and an 

ineffective substitution for specifications or 

requirements for use in GSA contract 

documents. ASTM F1949-99, a Standard 

Specification for Medical Oxygen Delivery 

Systems for EMS Ground Vehicles is included 

in ASTM F2020. ASTM F1949-99 is defined as 

a “standard specification”. 3) GSA has 

determined that ASTM F2020 is impractical 

because ASTM International does not provide 

interpretations and written guidance to their 

publications which is inadequate and less useful. 

ASTM members may only offer personal 

opinions. ASTM offers no mechanism to 

support timely resolution of conflicts between 

contractor and procurement organizations on 

technical subject matter. GSA provides 

interpretations, clarifications and engineering 

determinations when required. This is one of the 

most important concerns presented by the 

Ambulance Manufacturers Division (AMD). 4) 

The AMD has determined through consensus 

that it is impractical to replace the Federal 

Specification for Ambulances, KKK-A-1822E 

with the ASTM Standard Practice, F2020. GSA 

initiated a survey to collect public responses 

from a wide range of constituent users of the 

Federal Ambulance Specification. The National 

Association of Emergency Medical Technicians 

(NAEMT), the International Association of Fire 

Chiefs (IAFC), the National Association of State 
C-23

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

EMS Directors (NASEMSD) and the National 

Association of EMS Physicians universally 

accept and support the continued use of the 

Federal Specification. The AMD and 

constituent users have determined that it is 

impractical to replace the Federal Specification 

for Ambulances, KKK-A-1822E with the ASTM 

Standard Practice, F2020 because rule 

promulgation is burdensome and costly. Staff 

and administration resources would need to be 

diverted in each state EMS office to implement 

the change in statutes, public health codes, rules 

and regulations. 5) GSA has determined that 

ASTM F2020 is impractical because it is 

burdensome to GSA procurement efforts. While 

the current ASTM document recites many of the 

requirements from the Federal Specification, a 

future ASTM document would likely have 

diverging requirements unacceptable to the 

Government. This was verified by a member of 

the ASTM F2020 subcommittee at the 

September 4, 2003 meeting of the Federal 

Interagency Committee on Emergency Medical 

Services. 

65 GSA MIL-G-9954 – Glass 

Beads for Cleaning and 

Peening 

SAE/AMS 2431 – 

Peening Media, 

General Requirements 

This government-unique standard contains 

specific size & performance required for Air 

Force critical applications that are not present in 

the voluntary standards. 

66 NARA NARA Data Standard Encoded Archival 

Description (EAD) 

Archives, Personal 

Papers, and 

Manuscripts (APPM) 

General International 

Standard Archival 

Description (ISAD(G)) 

International Standard 

Archival Authority 

Record for Corporate 

Bodies, Persons, and 

Families 

(ISAAR(CPF)) 

Machine Readable 

Cataloguing (MARC) 

These standards do not meet the precise needs of 

our agency. However, we continue to bring our 

individual data elements guidance closer into 

line with these voluntary standards. 

67

* 

CPSC FR/Vol. 68, No. 

75/Friday, April 18, 2003, 

pp. 19142-19147, "MetalCored Candlewicks 

Voices of Safety 

International (VOSI) 

standard on lead in 

candle wicks 

The U.S. Consumer Product Safety Commission 

found that "the VOSI standard is technically 

unsound, and thus would not result in the 

elimination or adequate reduction of the risk, 
C-24

 Agency Government-Unique 

Standard 

Voluntary 

Consensus 

Standard 

Rationale Provided by Agency 

Containing Lead and 

Candles With Such 

Wicks" 

and that substantial compliance with it is 

unlikely." See FR/Vol. 68, No. 75/Friday, April 

18, 2003, pp. 19145-19146, paragraph H2, 

"Voluntary Standards" for further information on 

this finding. 

68 CPSC CPSC CFR Parts 1213, 

1500, and 1513 

ASTM F1427-96 

Bunk Beds 

The CPSC rule goes beyond the provisions of 

the ASTM voluntary standard to provide 

increased protection to children from the risk of 

death and serious injury from entrapment. 

69 GPO FED-STD 209 ISO 14644-1 & ISO 

14644-2 

Quality Assurance. Second ISO standard not 

issued until end of FY 2000. Being phased out. 

70 GPO MIL-STD 105 ANSI/ASQC Z1.4 Quality Assurance. Cited in small number of 

contracts due to editing errors. These are being 

corrected and phased out. 

71 GPO MIL-STD 1189 ANSI/AIM X5-2 & 

ANSI X3.182 

Quality Assurance. Cited in small number of 

contracts due to editing errors. These are being 

corrected and phased out. 

72 GPO MIL-STD 498 IEEE/EIA 12207.0, 

IEEE/EIA 12207.1, & 

IEEE/EIA 12207.2 

Quality Assurance. Cited in small number of 

contracts due to editing errors. These are being 

corrected and phased out. 
D-1

Appendix D: The “Standards.Gov” Website