\ A 111 DM 02211^ PUBLICATIONS

NBSIR 79-1703

The Timely Development of

Environmental, Safety, and

Health Standards for Energy

Technologies

Bruce W. Steiner

National Bureau of Standards

Washington, D.C. 20234

January 1979

-QO . U.S. DEPARTMENT OF COMMERCE

100

.1156

79-1703

C.2

NATIONAL BUREAU OF STANDARDS

NBSIR 79-1703

«THE TIMELY DEVELOPMENT OF

ENVIRONMENTAL, SAFETY, AND

HEALTH STANDARDS FOR ENERGY

TECHNOLOGIES

MAY 1 5

rvo*t. Ate - Ct.ro

Bruce W. Steiner

National Bureau of Standards

Washington, D.C. 20234

January 1 979

U S. DEPARTMENT OF COMMERCE, Juanita M. Kreps, Secretary

Jordan J. Baruch, Assistant Secretary for Science and Technology

NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director
..N- • v • ij

'

'

.

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: .V-
The Timely Development of

Environmental, Safety, and Health

Standards for Energy Technologies

Bruce Steiner

January 1979
SUMMARY

Major Changes in Demands on the Management of National

Standards Are Underway

The Department of Energy (DoE) is now being required to provide

systematic assurance, that, when new energy technologies are ready for

commercialization, their introduction is not held up by: 1) the absence

of essential environmental, safety, and health (ES&H) limits standards,

nor 2) an inability to demonstrate compliance with the then existing

standard limits. Pressure to implement such a program at the earliest

possible time is coming from the Congress, the White House, and the

private sector. Simultaneously, the DoE line program divisions are

focusing on performance specifications as aids to the systematic

stimulation and transfer of technology to the private sector.

The previous responses of other Federal agencies to increased

pressures for limits do not provide suitable models for present systems

specifications and measurements needs of the Department of Energy.

Certain nuclear safety standards, for example, have not won the desired

widespread public support in spite of a strong Federal effort to develop

a comprehensive set of specified safety standards. Moreover, in the

present instance, a highly focused effort similar to the Federal

development of more rigid nuclear specifications would not be suited to

the commercialization of the far more diverse non-nuclear technologies.

Similarly, existing environmental limits do not provide an accepted

model. They are widely perceived not to take into account sufficiently

ii
the costs of compliance. Moreover, environmental limits are frequently

imposed too suddenly for the Department of Energy to use them as a basis

for long range environmental planning. The following analysis describes

DoE activities that would enable the voluntary consensus standards

bodies, without substantial change, to respond to the large new demands

for ES&H limits in the effective manner that these bodies have displayed

for commercial specifications.

New Pressures Reflect Switch from Passive to

Active Role for Standards

An effective response to the new pressures for stronger management

of energy systems ES&H specifications begins with the recognition that

the current pressures extend far beyond energy. These pressures have

major agency and company implications that will be described. These

pressures reflect a widespread desire for national consensus practices

to play a new role, one with greatly increased leverage. In the past,

specifications in the United States have been developed as a response to

needs in existing technology driven by commercial incentives, needs

perceived and ranked initially by senior technical managers. Now a new

set of new system specifications for various future technologies is

being called for. Such specifications will stimulate new technology,

guide its development, and optimize transfer within the private sector.

iii
Anticipatory Mode Imposes Certain Basic Research

and Systemic Requirements

The new role for systems specifications requires that many specific

research needs now will have to be anticipated. The execution of this

research will have to be closely coordinated with the voluntary

consensus standards writing bodies. Both of these changes will affect

the research community far beyond the traditional purview of commercial

product specifications.

In order to develop advanced systems specifications in time for the

commercial introduction of technologies, the system of standards will

need to fulfill certain new criteria. First, the system will need to

anticipate technical problems in an orderly comprehensive fashion.

Second, the system will need to establish priorities for the importance

of specific technical problems and related product specifications and

measurements and incorporate requirements for necessary lead time. The

system will need to assign formal responsibility for the essential

functions. Finally, it will need to assure funding and implementation,

and to monitor progress.

At the same time, any specifications development must continue to

fulfill previously established criteria. The system and the resulting

specifications must be compatible with primary agency and private sector

responsibilities. Moreover, specifications development must continue to

accommodate the responsibilities of other Federal and private agencies.

The resulting specifications must also be economical. These results will

most readily be achieved through an open consensus process by mutual

cooperation

.

iv
Comparison of Present Standards with Development Functions Now

Required Provides Strategic Tests

Present procedures for the establishment of voluntary consensus

specifications excel at the two national functions that they were

designed to perform, namley: 1) the development of an educated

consensus among interested parties , and 2) nationally recognized

specification writing . These functions are performed with economy

consistent with the achievement of real consensus. The new role for

specifications, however, requires a process with an expanded set of

functions. Four functions are now essential on a national scale; six

more are needed in each Federal agency or company with a major interest

in anticipated standards for any given technology. Performance of all

ten functions is necessary if the standards development process is to

meet the goals established by the Department of Energy.

The first of the four national functions is clearly 1) the

voluntary consensus standards writing process . This is the keystone of

the present system and must be preserved. The institutional functions

described below are designed to facilitate the development and use of

voluntary standards by both public and private institutions. 2) Federal

specification development is a second national function well established

in the technological sector. Current trends toward utilization of the

voluntary consensus standards system by the Federal specification

process can strengthen the execution of both of these functions. To

these well established national activities need now be linked

v
additional functions. 3) Information on the existence of standards and

those under development will be increasingly important in avoiding

duplication and confusion. 4) Establishment of interinstitutional

collaboration is also crucial in order to provide for collaborative

standards development under special circumstances.

In addition to these four national functions, six institutional

functions now are essential for anticipatory systems standards

development. These six are needed by each closely affected Federal

agency and major company. Three of these six functions provide

essential internal institutional coordination, and the remaining three

provide essential support. 1) The first of the six, management of

institutional standards development must be designed to assure the

effective implementation of the other five institutional functions. 2)

The second, establishment of institutional priorities is critically

important. 3) The third, a mechanism for institution-wide technical

decision , is also critical for assurance of the fulfillment of

institutional goals, such as environmental, safety, and health

preservation, consistent with economical and technical considerations.

4) The fourth function is technical support for " limit " standards , those

standards that limit technical system performance. 4) Closely

associated with this, but distinct from it, is the fifth function,

technical support for " compliance measurements " standards, those

measurements that provide for evidence of compliance with "limit"

standards. 6) Finally, effective execution of all of the above

functions will require the sixth function, standards development

tracking within each affected institution.

vi
Needed Functions Require Agency Strategy with Mixture of

Internal and External Elements

Several specific strategic agency options may be considered for the

development of the newly required functions: 1) complete agency

responsibility for standards centralized in one part of each agency; 2)

total decentralized delegation of standards responsibility to technical

divisions; 3) total delegation of standards responsibility to another

agency; 4) a mixture of the preceding elements. The first approach

would not provide for adequate technology division participation nor for

effective participation in nationwide voluntary standards writing

bodies, essential to nationally recognized documentation. The second,

totally decentralized course would not provide for an institutional,

"cross cutting" Departmental approach, which is also essential. The

third approach lacks all of these essential elements: technology

division and ES&H participation as well as the national forum presented

by consensus bodies. Only the fourth option provides mechanisms for all

required functions through participation by all essential parties. A

plan establishing these mechanisms in their simplest form has already

been submitted to DoE. This plan calls for just such a mixture of

responsibility. The next step is to achieve a DoE-wide consensus on:

1) long term systems specifications development goals, and 2) short term

specifications development objectives.

vn
TABLE OF CONTENTS

Chapter Page

SUMMARY ii

TABLE OF CONTENTS viii

I. CHANGE IN DEMANDS PLACED ON THE MANAGEMENT OF STANDARDS 1

A. Environmental, Safety, and Health Standards 1

B. Technology Specifications 2

C. The Specifications Desired 2

D. Previous Institutional Response 4

II. SWITCH FROM PASSIVE TO ACTIVE ROLE FOR STANDARDS 4

III. IMPLICATIONS FOR RESEARCH AND THE DEVELOPMENT OF STANDARDS... 5

A. Basic and Applied Research 5

B. New Standards Requirements 6

C. Continuing System Requirements 7

viii
IV. CHARACTER OF PRESENT STANDARDS DEVELOPMENT 8

A. Voluntary Standard 8

B. Federal Regulations & Specifications 9

C. Funding & Priorities 10

D. Technical Support 11

E. Fulfillment of New Requirements 12

V. FUNCTIONS NOW REQUIRED. 13

A. National 13

1. Consensus Generation 13

2. Specification Writing 13

3. Standard Information 14

4. Interinstitutional Collaboration 14

B. Departmental 15

1. Management of Standards Development 15

2. Priority Establishment 16

3. Technical Decision 17

4. Technical Support for Limit Standards 17

5. Technical Support for Compliance Measurements Standards.. 18

6. System Tracking. . 20

VI. AGENCY STRATEGIES FOR THE PROVISION OF ESSENTIAL

FUNCTIONS 21

A. Provision of National Functions 21

B. Provision of Agency Functions 22

lx
1. Coordination 22

2. Support 22

C. Summary 23

VII. CONCLUSIONS 23

VIII. REFERENCES

*

X
1

I. CHANGE IN DEMANDS PLACED ON THE MANAGEMENT OF STANDARDS

A. Environmental , Safety , and Health Standards

The Department of Energy is being required to provide assurance

that new energy technologies will meet national limits established by

the time these technologies are introduced commercially. In the area of

the environment safety, and health, pressure to do so is coming from

Congress (1), from the White House (2), and directly from nongovernmental groups (3) . The source of this concern was the absence of

systematic planning for the benign operation of energy technologies,

both present and future. The new Department is under strong pressure

not to depend exclusively on Federal regulatory agencies for systems

specifications planning.

The Department of Energy Division of Operational and Environmental

Safety (OES) therefore has commissioned a plan for the development of

all critically important environmental, safety, and health (ES&H)

standards (limits and specifications). This plan is to outline

procedures to assure that, when new technologies are ready for

commercialization: 1) all necessary ES&H standard limits will be in

place in the private sector; and 2) the means for demonstrating

compliance with these standard limits will be available also in the

private sector.
2

B . Technology Specifications

In the area of improved technical performance, standard specifications are also receiving attention from DoE technical divisions as

vehicles for stimulating technical innovation and for the transfer of

technology to the private sector. For example, new technology codes and

standard specifications are being developed for solar heating and

cooling, conservation, fossil energy, and photovoltaic energy. Why have

this interest and activity in standard specifications suddenly expanded,

and what range of responses would be effective? The considerations in

the evolution of the DoE plan apply also to other institutions, public

and private, faced with the growing implications of standards.

C. The Specifications Desired

The codes and standard specifications most generally desired may be

viewed as nationally accepted practice (4). Interest in them is based

primarily on the fact that they are widely "accepted". This recognition

is derived either: 1) from the consensus achieved in voluntary

standards writing bodies or 2) from the act of establishment of

governmental regulations and specifications (5).

The growing desire for both types of standard specifications,

voluntary and governmental, is based on several distinct ramifications

of the acceptance process. Of primary importance to the general public

and to industry is the formally recognized standing of such
3

specifications. Moreover, standard specifications are perceived by the

public to provide stable performance guidelines, although this varies

greatly with the particular standards. For the technical manager,

standard specifications offer nationally recognized levels of acceptable

performance and hence reduce the liaibility for technical performance

equal to or within the agreed limits. Standard specifications thus

represent an advance agreement on what constitutes acceptable

performance. The basic importance of a properly functioning set of

standard specification limits however, both for the public and for the

manager, is twofold. Both the development and the ultimate performance

of the system covered by specifications are frequently more predictable

than for a comparable system developed in the absence of national

participation. Moreover, difficulty in the establishment of standard

specifications may serve advance notice of deep-seated difficulty in the

development or operation of a particular system. The standard

specification development process itself thus can serve as a technical

early warning system.

The most prominent difficulties in the development of standard

specifications also are related to the procedure for gaining their

acceptance. The process of acceptance necessarily involves all

concerned individuals and institutions. Such a process is intrinsically

a complex and lengthy one. The complexity and length imply, moreover,

that the process can be an expensive one. This is true particularly, as

we shall see, where one purpose of the standard specification is to

stimulate the development of a given technology that lacks a proven

basis of experience.
4

D. Previous Institutional Response

Before undertaking the development of a totally new ES&H standard

specifications plan, we reviewed as potential models previous

institutional response to systematic requirements for specifications.

The nuclear system could conceivably furnish one such model. However,

nuclear limits have been prepared primarily to embody and promulgate

homogeneous, Federallydeveloped technology. The current DoE mission, by

contrast, is to stimulate the private sector development of

heterogeneous technology ("energy options") and to support them with

viable private sector standard specifications.

The development of environmental control limits also was not viewed

as a suitable model. Industry has displayed widespread concern that the

resulting limits are severely uneconomic. In any event, they are being

imposed with insufficient advance notification to serve as a basis for

long range planning by others. (6,7)

II. SWITCH FROM PASSIVE TO ACTIVE ROLE FOR STANDARDS

The traditional voluntary standards writing system has been

developed to respond to technical problems arising in industry and

commerce (8). The widespread use of the system has resulted from its
5

responsiveness to acknowledged industrial and commercial concerns. When

problems arose, the system has not acted until it achieved a consensus.

This consensus has contributed greatly to the probability of compliance.

The recent pressures for systematic standard specifications

management reflect the evolution of the following challenging roles for

such activity. Standard specifications are now being called for, not

only to ameliorate specific recognized problems, but also to stimulate

technical innovation for new technologies and to control the course of

technical innovation and performance for, e.g., the protection of the

environment. In these cases, anticipation of technical performance is a

prerequisite. This anticipation is a new requirement. It represents an

expansion of the standards writing system from one based previously on

well-established experience to one that must increasingly attempt to

anticipate problems and provide the necessary experience. Such a system

will exercise far greater leverage on technical development than that of

traditional standard specifications. Any procedure designed to support

this new role successfully must display a substantially expanded set of

characteristics. We now turn to these new requirements which must be

met if standard specifications are to be in place when needed.

III. IMPLICATIONS FOR RESEARCH AND THE DEVELOPMENT 6F STANDARD

A. Basic and Applied Research

The new anticipatory role for standards implies the need both for

standards-related research (9) and for its coordination. An evolving
6

standards system will require much closer interaction between it and the

research stages of the technology with which it is associated than has

previously been necessary. Joint priorities for research and standards

will be called for in Federal agencies, as has already happened in the

private sector (3).

B. New Standards Requirements

Identification of the critical characteristics of new standards

development will provide a basis for evaluating the suitability of

current practice and any proposals to meet the new needs:

o Standards development must first of all be anticipatory .

It must embody mechanisms to anticipate the need for

standards before this need becomes critical.

o The development must be comprehensive . That is, it

must provide assurance that needs for important standards

will not be overlooked.

o The development must incorporate priorities . In the past

this aspect has been handled primarily outside of the

voluntary standards writing system.
7

o The development must allow for an adequate amount of lead

time. The normal standard development process depends upon

the existence of data that form the basis of agreement. Where

the specifications are anticipated, the research leading to

these basic data will also need to be anticipated in a timely

fashion.

o The preceding characteristics require the assignment of

specific responsibility for various operational activities

necessary in the development of a standard (Chapter V).

o This above responsibility will necessarily extend ultimately to

funding and implementation of general technical support for

the development of specific standard.

o Finally, progress in the development of standard will need

to be monitored by the primary agency if technology

commercialization schedules are to be met.

C. Continuing System Requirements

In addition to the characteristics just enumerated, the strengths

of present standard development will have to be maintained:
8

o Close collaboration with the program organizations must be

maintained. They will continue to be a focus for major

responsibility for new standard.

o At the same time, the resulting standard specifications will

need to be compatible with responsible public concern and with

appropriate standards of the agencies charged with public

environmental, health, and safety responsibilities. Ultimately

standard specifications will not be viewed as adequate if they

are not socially accepted.

o Finally, the standard specifications will not be successful if

they are not economical to implement , a criterion that will be

achieved if the development process continues to include

strong industrial participation.

IV. CHARACTER OF PRESENT STANDARDS DEVELOPMENT

A. Voluntary Standard

Most voluntary standards writing organizations are composed of

technically homogeneous committees that consist of concerned individuals

and institutional representatives. These committees examine the need

for given national standards practices, develop a strategy for their
9

attainment, and work together until a consensus is achieved on their

content. Additional review and consent is usually furnished by others in

the committee's parent organization. Finally, the approved document is

registered with the American National Standards Institute.

This process derives its strength through the development of a

consensus among concerned parties. In addition to the tradition of use

of the consensus process in the development of standard practices and

procedures in this country, there are very strong technical reasons for

the development of a consensus. Since a standard specification or

measurement is generally designed to have a broad impact, the full

breadth of its impact should be taken into consideration in its

development. Consideration by all affected parties is assured by an

effective consensus process. It is thus desirable that this system be

strengthened.

B. Federal Regulations & Specifications

I With the recent growth of governmental activity, especially in

dealing with ES&H issues another path to standards has been used

increasingly in recent years: direct governmentally established limits.

These standards rest not upon consensus but upon legislated

responsibility. Public views are frequently incorporated through the

publication of an "Advanced Notice of Proposed Rule Making" in the

Federal Register with the accompanying request for comment. But the
10

ultimate responsibility for, and standing of, such a standard rest on

governmental authority. The trend now for Federal agencies is to

participate in the writing of voluntary consensus standards and toward

the parallel development of Federal regulations, and specifications and

voluntary specifications. That is, Federal regulatory bodies are now

attempting to assist the development of voluntary national standard

practices instead of issuing differing Federal regulations and

specifications. This evolution in recent years, is contributing to the

establishment of scientific data as the basis for national standard

specifications

.

C. Funding & Priorities

A chief characteristic of the current development of voluntary

consensus standards is a broad base. Many participants are involved

in roles subsidiary to other responsibilities. Authority is not focused

on a single institution, although general coordination is provided by

organizations such as the American National Standards Institute and the

American Society for Testing and Materials. Participants are funded by

their own participating institutions. This decentralized support

constitutes a major strength of the present system. It provides for the

establishment of priorities informally through the breadth and depth of

the interest in the development of particular specifications. Standards

documents are not developed if they are not strongly desired by those

contributing to their generation.
11

However, it is possible that standards may not be promulgated on

occasion even though they may be of high priority, if a consensus cannot

be reached on their content. Conversely, in special cases where the

Federal Government has recognized the strong need for the accelerated

development of standard, it has supported a concerted effort. This has

occurred for example in the development of nuclear technology. The cost

of developing nuclear materials specifications, like the technology

itself, was born largely by the Federal Government (10).

The requirement for strong support before the development of a

standard specification or measurement is undertaken is vital to the

voluntary standards writing process as it exists. However, if funding

of data as the basis for environmental, safety, and health limits is not

available from the private sector, it is clear that procedures for the

establishment of priorities and for funding will have to receive

immediate attention by the responsible agency.

D. Technical Support

The actual development of a standard specification or measurement

procedure, either through the voluntary standards process or as a

Government regulation/specification, has depended on the accumulation of

scientific data through reliable procedures. Specifications have usually

not been contemplated until a basis of reliable data has been laid. In

the traditional operation of the standards development system, that is,
12

a standard typically codifies existing technical practice. Major

additional technical support, therefore, has not been necessary since

the critical information typically exists. Now, however, if standards

are to be generated in anticipation of technology, or parallel with its

development, the necessary research will have to be anticipated and

undertaken deliberately in order to obtain basic data. Such new

activity will require the establishment of new institutional mechanisms,

as agencies with the obligation to develop or control technology are

beginning to conclude.

E. Fulfillment of New Requirements

A comparison of the characteristics of present standards

development with the new and continuing requirements shows the

importance of continued strength in the voluntary consensus standards

and Federal standards processes. They are a key link with the private

sector and the ultimate standard specification implementation. To these

cornerstones must now be added additional functions so that the entire

development will have all characteristics now required.
13

V. FUNCTIONS NOW REQUIRED

A. National

1. Consensus Generation

The effectiveness of all standards is closely correlated with the

degree of participation and consensus among those most affected. The

voluntary standards groups have achieved this important mutual

accommodation with great dedication for many years. They will continue

to provide key elements in the standards development process. Indeed,

any successful plan for agency-wide or company-wide standards

development will depend heavily on close cooperation with existing

voluntary standards groups.

2. Specification Writing

The development of Federal specifications is undergoing change as

the recognition of the importance of mutual accommodation increases.

This contribution to specification writing is thus being amplified. The

process nevertheless is being performed with considerable skill.

Dramatic change in the mechanisms for the preparation of specifications

is not foreseen.
14

3. Standard Information

The development of new standards must take into account existing

voluntary standards and governmental regulations that are already in use

as well as those that are being developed by other agencies. The length

of time required for the development and field use of a standard makes

the latter category particularly important during the current period of

rapidly increasing standards development. An information system that

provides information on such activity will avoid substantial duplication

of effort. Since the total price tag of a single typical standard falls

between $200,000 and $20,000,000, substantial savings can be made with

such information. At least as important as the monetary saving, is the

clear desirability of coordination of specific standards interests by

various agencies so that the utility of a single new standard will be as

broad as possible.

4. Interinstitutional Collaboration

Rarely if ever can the functions of a given agency or company be

executed in the absence of consideration of the responsibilities of

other agencies. Particularly in the field of environment, safety, and

health, the views of several agencies must be taken into account. The

establishment of priorities by one agency will be carried out most

effectively and with least question if other agencies, public and

private, have the opportunity to comment on priorities while they are

being formulated.
15

A second role for interagency coordination, in addition to the

establishment of priorities, is the cooperative modification of

regulations and specifications already promulgated by other agenices.

Where information that has come to light since the development of

another agency's regulation or specification indicates that

reconsideration is in order, a new standard development effort may

clearly be more successful if undertaken jointly by both agencies.

B. Departmental

1. Management of Standards Development

The development of standards is necessarily a lengthy process

because of the large amount of convincing data that must be obtained.

It may take as long as twenty years (8). The development now required

differs in two important respects from traditional standards

development. First, it must anticipate the need for specifications and

all that that implies. Second, it must develop standard specifications

and measurements in a routine fashion at a substantially accelerated

rate . Both of these differences require that: 1) strong, technically

credible leadership be exercised by the agency or company with a strong

interest; i.e., it must have strong standards management, and 2) this

leadership be exercised through the institutionalization of other
16

critical functions. Each of these functions can be performed

effectively only by those with appropriate expertise and responsibility.

It is, therefore, necessary that responsibility for each function be

delegated to a distinct internal or external organization, and perhaps

to two or three separate institutions. Although such designation of

organizations may seem to some a large step to take, the result can be a

relatively simple structure that indeed can be managed in an effective

manner. Moreover, an explicit allocation of responsibility will permit

the entire comprehensive standards development effort to be coordinated

by a small but expert central staff.

2. Priority Establishment

Because of the length of time and the expense involved in the

standards development process, on the one hand, and the consequences of

failing to develop adequate standards, on the other hand, the

establishment of priorities is critical. There are really two separate

levels of priorities that must be established and executed. The first

is the establishment of the most critical issues to be addressed. In

the areas of environment, safety, and health, this step involves

specific hazards identification and priority establishment. The next

level is the selection of those specifications that should be developed

first and the assignment of priorities to each for development. The

establishment of suitable priorities at both levels requires agency-wide

participation in order to assure both comprehensiveness and adequate

consideration of programmatic factors.
17

3. Technical Decision

Certain technical decisions on standards that must be made by the

agency or company, although basically technical in nature, will be

controversial because of conflicting or insufficient information. One

example is the decision in a given instance whether or not to develop a

voluntary consensus standard specification, a Federal specification, or

both. Another is the review of field tests and evaluations and the

related decisions whether or not information in hand provides an

adequate basis to proceed with standards development.

The simplest reliable approach to the evaluation of compliance

involves a comparable, but technically and administratively distinct,

technical decision on the adequacy of the compliance data obtained. The

differences between this and the standards development decisions are

sufficiently great that two distinct activities are called for, one for

technical decisions related to standards development and a second for

technical decisions related to evidence of compliance.

4. Technical Support for Limit Standards

There are two basic kinds of standards that are needed in most

standards systems: 1) "limit" standards, which define acceptable limits

to system performance and design, and 2) compliance measurement

standards, which define the methods for demonstration of compliance with

"limit" standards. The development of "limit" standards requires
18

knowledge of system performance under given conditions and of the effect

on people of possible changes in the environment. This knowledge

requires at a minimum certain technical ability, technical background,

and familiarity with recent developments in specific fields. Where

technology is pushing the state of the art, laboratory work will also be

required

.

Two formal kinds of technical services will be required now to

support the development of new standards. The first is independent

technical consultation during the process of decision making. Such

consultation will be especially important where the inherently lengthy

process must be shortened substantially. The second service is the

development of technical information to support specific standards. The

former type of service will be technically broad and continuing, while

the latter is a series of separate efforts, each highly focused in

technology and in time, a "batch" process. Sources of funding of these

two types of services will differ in a manner corresponding to those

differences. That is, the general function would naturally be supported

on an agency-wide basis, while the focused efforts would be more closely

coupled to specific technologies.

5. Technical Support for Compliance Measurements Standards

The Compliance Measurement Standard Technical Support function

considered here is similar conceptually to Limit Standard Technical

Support described in the preceding section. Both require major
19

continuing laboratory support with a wide range of expertise. Both must

have a broad, basic component and a more highly focused component

addressing a series of specific standards.

There are two important distinctions between these support

functions, however. In the first place, the technical expertise

required is quite different. While Limit Standards Technical Support

requires biologists and structural engineers, Compliance Measurement

Standard Technical Support requires measurement experts, those who know,

or can readily evaluate, the state of the art of measurements and who

are able to apply recent developments in measurement science to

identified needs.

The second major distinction is the far more political nature of

limit standards. In environmental, safety, and health areas, for

example, if an agency desires to avoid playing a purely responsive role

with other agencies in the establishment of limits, the agency must have

independent technical resources to develop independent data. The

distinction between the two types of resources, internal and other

agency, must be preserved in the generation of a technical basis for its

"limits" and for "compliance measurement". But the danger of agency

loss of technical independence is more severe in the "limit" case than

in the "compliance measurement" case.

On the other hand, if the agency's own data are to be viewed as

independent of "technology" bias, the distinction must also be preserved

between ES&H programs and technology development programs. Credibility

of ES&H standards will depend on the validity of the data presented.
20

One additional technical service is required to support both

"Limit" standards development and "Compliance Measurement" standards

development: statistics. The general statistics that are needed to

support research and development are well established in concept. The

statistics needed for regulatory compliance, by contrast, have not been

developed in a generally accepted manner and will require special

attention if the sampling procedures used for compliance are not to be

open to serious question. (11) Once this development has been performed

in a satisfactory manner, it will not have to be repeated.

6. System Tracking

Two mechanical activities will be required to support institutional

standards development. The first is the establishment of an institutional

memory, so that information required to establish priorities, which may

be cumulative, can be collected and evaluated in an effective manner.

The second is the tracking of the progress of each standard through the

stages of intra-agency development.

The impact of a given potential standard, e.g., for a specific

chemical emission, may not be sufficient to justify the cost of development. However, after the same issue has been identified in a number of

areas as important, the strength of the total justification will increase

to the point that standards development should be undertaken. Therefore,

a system will be needed to accumulate this justification and to trigger

the standards development at the appropriate stage.
21

Once the development process has started, it will then be important

to track the development through each of the approximately 350 stages

involved for an anticipated standard from start to finish. Such tracking

will also assist the judgments required to determine which stages can be

bypassed without sacrifice of the integrity of resulting standards.

VI. AGENCY STRATEGIES FOR THE PROVISION OF ESSENTIAL FUNCTIONS

A. Provision of National Functions

Two of the four necessary national functions are already being

provided: consensus generation and specification writing. During the

development of individual standards, an agency focus for these functions

will be required, and a specific focus must necessarily be created for

each standard. This focus will consist largely of technology division

activity. Systematic assurance that broader agency concerns are also

being incorporated can be provided through the energy standards management function if it is appropriately structured.

The other two national functions, standards document information

and institutional interaction, are not now being generally provided in a

manner that will meet agency and company needs. Agencies will,

therefore, need to strengthen existing external institutions or to
22

create new ones. In both cases, there is no need to provide for the

execution of these functions internally. However, without agency

support, the functions will not be provided in suitable form.

B. Provision of Agency Functions

1. Coordination

The three agency standards coordination functions, management of

standards development, priority establishment, and technical decision,

are not now usually provided in a systematic way. These are

intrinsically internal cross-cut functions and cannot be contracted out.

New agency institutions will be called for or existing ones must be

charged with the responsibility to provide for each function in a

systematic way if agencies are to meet the new pressures on them for the

timely development of standard specifications.

2. Support

Provision of the three support functions, technical support for

limit standards, technical support for compliance measurement standards,

and system tracking can in principle be provided either internally or on

contract. In each case technical expertise is an essential requirement.
23

Technical support for limit standards will require primarily biologists

and structural engineers. Technical support for compliance measurement

standards will require physical measurement scientists and engineers.

Systems tracking will require management systems specialists and

probably computer systems engineers.

C . Summary

It is clear that the four essential national functions are broader

than any single mission agency. However, they will require strong

agency support if they are to be executed effectively. Three of the six

agency functions provide intra-agency coordination and must be

established internally to each strongly affected agency. The remaining

three agency functions provide broad support to the entire agency

participation in standards development. While they can be located

either internally or externally depending on the relative availability

of personnel and funding, as well as agency preferences, they must be

funded by each agency with the necessity to arrive at independent

conclusions

VII. CONCLUSIONS

The growing desire to anticipate needs for technological standard

specifications and measurements represents a transformation from a
24

passive role to an active role for such standards. The implementation

of an active role by an agency requires new agency approaches. These

approaches will need to take full advantage of existing voluntary

standards and specification writing organizations. To support them,

eight other functions are essential; two national and six departmental.

The two national functions would appropriately be established outside of

an agency but with agency support. Three of the six agency functions

need necessarily to be established within the agency. The remaining

three are support functions that can be provided either internally or

externally. A specific plan for provision of all functions has already

been prepared (12).
25

ACKNOWLEDGEMENT

A number of DoE and NBS colleagues have contributed actively and

extensively to development of the ideas in this report. In the Department

of Energy, the assistance of George Dix and Robert Poe was essential to

the general form and detailed presentation of the planning. At the

National Bureau of Standards, the guidance and encouragement of Howard

Sorrows and Wayne Cassatt were essential to the entire effort.

Extensive conversations with John Wachtman, Jr., Elio Passaglia, James

Leiss, and Jack Snell also played an important role at critical

junctures in the thinking. The author, however, is entirely responsible

for any deficiencies in the logic or conclusions that may be formed.
26

VIII. REFERENCES

(1) 95th Congress, U. S. House of Representatives, Committee on

Science and Technology, Subcommittee on the Environment and the

Atmosphere Hearing No. 7, March 1, 1977, p. 5.

(2) 0£. Cit . p. 211.

(3) 0£. Cit. p. 1147.

(4) In some areas, notably in building, the word "standard" refers

to a voluntary standard, a standard without official standing, while the

word "code" refers to a standard that has official standing. In the

present document the word, standard, is used generally for all codes and

standards for performance or design practice.

(5) A third form of acceptance is a de facto acceptance, such as

that provided by the dominance of one company in a market. An example

is the IBM computer card format. This type of acceptance is necessarily

not a major factor for anticipated standards.

(6) Jordan Baruch, testimony before joint U.S. Senate and House of

Representatives Science Subcommittee hearings, 14 February 1978.
27

(7) N. Bruce Hannay, ibid.

(8) Samuel Etris, ASTM, private communication.

(9) James Gruhl, Review of Methods for Assessing the Carcinogenic

Hazards from Coal Using Energy Technologies, MIT Report EZ 76015, NTIS

No. PB 270 682 (1976).

(10) John Crawford, Sr.

,

DoE, private communication.

(11) Joan Rosenblatt, NBS, private communication.

(12) U.S. NBS Energy Standards Planning and Coordination Task

Force: Plan for the Development of Environmental Safety and Health

Standards, September 1977. Report to the ERDA Division of Operational

and Environmental Safety.
NBS-114A (REV. 9-78)

BIBLIOGRAPHIC

U.S. DEPT. OF COMM.

DATA

"1

SHEET

1. PUBLICATION OR REPORT NO.

NBSIR 79-1703

Jto* 3. fi&cfptertf s Aco$$slo?t No.

4. TITLE AND SUBTITLE

The Timely Development of Environmental, Safety, and Health

Standards for Energy Technologies

5. Publication Date January 1979

7. AUTHOR(S)

Bruce W. Steiner

9. PERFORMING ORGANIZATION NAME AND ADDRESS Project/Tasfc/Work

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, DC 20234

8. Performing Organ. Report No. NBSIR 79-1703

11. Contract/Grant No.

12. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, state, ZIP)

National Bureau of Standards

Department of Commerce

Washington, D.C. 20234

13. Type of Report & Period Covered Gen 1 Conclusions Follow:

Preparation of DOE Repori

15. SUPPLEMENTARY NOTES

| | Document describes a computer program; SF-185, FIPS Software Summary, is attached.

1$. ABSTRACT (A 200-word or leas tactual summary of most significant information . If document includes a significant bibliography or

literature survey, mention it here.) The Division of Operational and Environmental Safety (OES) was established in the

spring of 1977 as a division of the former Energy Research and Development

Administration. As one of its first tasks, OES commissioned the National Bureau

of Standards to develop a comprehensive plan for the development of non-nuclear

energy-related environmental, safety, and health standards for the Department of

Energy. The objective was to provide assurance that the expolitation of new energy

technologies by the private sector would not be hindered by the absence in the

private sector of (1) all necessary environmental, safety, and health standards;

or (2) the ability to comply with them. A detailed plan was submitted to the

Division in September 1977.

During the preparation of that report it became clear that the effort commissioned

by the OES was representative of a broad transformation with great significance

for the standards development process in the United States. The present report

consists of a paper describing that transformation in the role of standards its

significance, and the broad implications.

17. KEY WORDS (six to twelve entries; alphabetical order; capitalize only the first letter of the first key word unlees a proper name;

separated by semicolons)

Energy Standards, Environmental Standards; Safety and Health Standards*

Standards Development

18. AVAILABILITY Unlimited

| | For Official Distribution. Do Not Release to NTIS

j Order From Sup. of Doc., U.S. Government Printing Office, Washington, DC

20402, SD Stock No. SN003-003-

| | Order From National Technical Information Service (NTIS), Springfield, VA, 22161 ___

19. SECURITY CLASS

(THIS REPORT)

UNCLASSIFIED

20. SECURITY CLASS

(THIS PAGE)

UNCLASSIFIED

21. NO. OF

PRINTED PAGES

38

22. Price

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