EXECUTIVE OFFICE OF THE PRESIDENT 

 OFFICE OF MANAGEMENT AND BUDGET 

WASHINGTON, D.C. 20503 

 

January 25, 2007 

The Honorable Daniel K. Inouye 

Chairman 

Committee on Commerce, Science 

 and Transportation 

United States Senate 

Washington, DC 20510-6125 

Dear Mr. Chairman: 

I am pleased to submit the annual report on Federal participation in the development and 

use of voluntary consensus standards during Fiscal Year 2005, in accordance with the Office of 

Management and Budget (OMB) Circular A-119 and as required by Section 12(d) of the 

National Technology Transfer and Advancement Act Amendments of 1996 (NTTAA, P.L. 104-

113). This report was prepared by the National Institute of Standards and Technology (NIST) at 

the Department of Commerce based on input from 26 agencies. NIST and OMB staffs continue 

to work collaboratively with each other and with contributing agencies to improve the 

availability, accuracy, and relevance of this report. 

The NTTAA directs Federal government agencies to achieve greater reliance on 

voluntary consensus standards developed by private sector and decreased reliance on standards 

developed by and for the government. It also directs that Federal agency personnel participate in 

the activities of voluntary consensus standards developing organizations to help ensure that 

standards produced in the private sector are more likely to be appropriate for use by Federal 

agencies. 

 

This report demonstrates that agencies develop a minimal number of new standards and 

perform periodic review of government-unique standards for potential rescission or replacement 

by commercial standards. 

Thank you for your ongoing interest in and support for policies related to Federal use of 

voluntary consensus standards. 

Sincerely, 

 Steven D. Aitken 

 Acting Administrator 

 Office of Information 

 and Regulatory Affairs 

Enclosure 
2 

Identical Letter Sent to: 

The Honorable Vernon J. Ehlers 

The Honorable David Wu 

The Honorable Bart Gordon 

The Honorable Sherwood Boehlert 

The Honorable Ted Stevens 

The Honorable Daniel Inouye 

The Honorable John Ensign 

The Honorable John Kerry 

The Honorable Richard B. Cheney 

The Honorable J. Dennis Hastert 
Ninth Annual Report on Federal Agency Use of 

Voluntary Consensus Standards and Conformity 

Assessment 

December 2006

U.S. DEPARTMENT OF COMMERCE 

Carlos M. Gutierrez, Secretary 

TECHNOLOGY ADMINISTRATION 

Robert C. Cresanti, Under Secretary of Commerce for Technology 

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY 

William A. Jeffrey, Director
Table of Contents 

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

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

3.0 – Federal Agency Use of Standards.......................................................................... 2 

3.1 – Government-Unique Standards Used in Lieu of Voluntary Consensus 

Standards..................................................................................................................... 3 

3.2 – Current Federal Agency Use of Voluntary Consensus Standards (VCSs) ........ 5 

3.3 – Current Agency Reporting on Voluntary Consensus Standards Substituted for 

Government-Unique Standards................................................................................... 6 

4.0 – Federal Participation in Private Sector Standards Activities................................. 6 

4.1 – Participation Data for FY 2005.......................................................................... 6 

4.2 – Strategic Partnerships......................................................................................... 7 

5.0 – Federal Agency Conformity Assessment Activities.............................................. 8 

6.0 – Evaluation of the Effectiveness of OMB Circular A-119.................................... 10 

7.0 – The Interagency Committee on Standards Policy................................................ 11 

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

Appendix A – FY 2005 List of Federal Agencies That Report.................................. A-1 

Appendix B – FY 2005 Federal Agency Use of Standards and Participation in Private 

Sector Standards Bodies ............................................................................................. B-1 

Appendix C –Government-Unique Standards Used in Lieu of Voluntary Consensus 

Standards..................................................................................................................... C-1 

Appendix C.1 – Government-Unique Standards Used in Lieu of Voluntary 

Consensus Standards Incorporated in FY 2005...................................................... C-1 

Appendix C.2 –Instances of Government-Unique Standards Used in lieu of 

Voluntary Consensus Standards Discontinued in FY 2005.................................... C-2 

ii
Summary Report on Federal Agency Use of Private Sector Standards 

And Conformity Assessment Activities for FY 2005 

1.0 – Executive Summary 

The U.S. Department of Commerce’s National Institute of Standards and Technology 

(NIST) prepares this summary report for the Office of Management and Budget (OMB) 

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

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

Circular, this report describes activities related to Federal use of voluntary consensus 

standards (VCSs) by 26 agencies during FY 2005. The report also summarizes voluntary 

agency reporting on coordination of conformity assessment activities. 

As reported by agencies, the cumulative number of VCSs in use in their regulatory 

activities in FY 2005 stood at 6,229, a 37% increase from FY 2004. New uses in FY 

2005 totaled 1,670, of which 243 were substitutions for government-unique standards. 

The significant reported increase in use of VCSs in FY 2005 is primarily the result of 

continued improvements in the reporting process implemented by DHS, which reported 

987 new uses. During the year, four government-unique standards were discontinued 

and one new one implemented. Since the enactment of the NTTAA there has been a 

fundamental shift in how the Federal government develops and deploys standards. Since 

the inception of this report, agencies have adopted and continue to use only a small 

number of government-unique standards in lieu of voluntary consensus standards. (See 

Table B-1). The Act has successfully encouraged agencies to first look to voluntary 

consensus standards to meet their needs rather than to develop government-unique 

standards. 

The Department of Defense (DoD) continues to lead the Federal government in the use of 

VCSs. Data reported each year since 1997 do not include all nongovernmental standards 

currently in use by DoD, which launched its efforts to minimize use of governmentunique standards prior to the enactment of the NTTAA. DoD’s inventory of private 

sector standards stood at 9,083 at the close of FY 2005. 

The Federal government is a key player in the U.S. private sector voluntary standards 

system. The 3,954 agency representatives who participated in a total of 409 standards 

developing organizations in FY 2005 were instrumental in ensuring agency compliance 

with the NTTAA and the OMB Circular. Even more importantly, government 

participation means that government users understand both the intent and the content of 

specific standards. While the number of standards bodies with Federal agency 

participation continued to decline in FY 2005, the number of agency staff participating in 

standards activities reached an all-time high. 

Reports for FY 2005 show that agencies now recognize or list a wide range of national 

and international private sector consensus standards as a component of agency guidance 

or recommendations in key areas. They also make "beyond-regulation" use of voluntary 

consensus bodies and of conformity assessment programs operated by the private sector. 

1
Some Federal agencies leverage their partnerships with the private sector in both the 

standards and conformity assessment realms to address national policy and technology 

needs. Partnership vehicles include standards panels and joint development of standards 

strategies and roadmaps in areas ranging from homeland security to health information. 

 

2.0 – Overview and Scope 

This report fulfills the reporting requirements of Section 12 of the NTTAA and of OMB 

Circular A-119. It describes Federal agency activities related to the use of private sector 

standards in regulation, procurement and conformity assessment during FY 2005. In 

close consultation with OMB, NIST formulates this report based on inputs submitted to 

NIST by Federal agencies in fulfillment of the requirements of OMB Circular A-119. 

Section 12 of the Act, enacted on March 7, 1996, directs Federal government agencies to 

achieve two main goals. First, the Federal government must achieve greater reliance on 

voluntary consensus standards developed by the private sector. Second, the Federal 

government must decrease its dependence on government-unique standards developed by 

and for the Federal government. The NTTAA also directs Federal agency personnel to 

participate in the activities of voluntary consensus standards developing organizations 

(SDOs) so that the SDOs remain familiar with the Federal government’s position on 

standards and consider that position in their final standards documents. This provision is 

intended to help ensure that standards produced in the private sector will be more 

appropriate, and cost effective, for use by Federal agencies. While these policies have 

been a part of the Circular for many years, the enactment of the NTTAA served to codify 

these policies into statute, thereby reinforcing them. 

3.0 – Federal Agency Use of Standards 

The OMB Circular requires that Federal agencies use voluntary consensus standards in 

lieu of government-unique standards in their regulatory and procurement activities. 

However, a Federal agency is given the discretion to decide not to use existing voluntary 

consensus standards if the agency determines that use of such standards would either be 

inconsistent with applicable laws or otherwise impractical. 

 

According to Section 6 of the OMB Circular: 

"Use" means the 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. 

2
The Circular also directs agencies to establish a process for a continuing review of their 

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

sector standards for government-unique standards wherever possible. 

NIST, through the Interagency Committee on Standards Policy (ICSP), coordinates the 

efforts of Federal agencies to report their use of standards in a clear and consistent 

manner and to eliminate confusing interpretations of the term “use” as well as in what has 

to be reported by Federal agencies. The ICSP established a work group in FY 2005 to: 

(1) review the reporting procedures for determining the number of private sector 

standards used by Federal agencies; and (2) establish guidelines as to what agencies 

should report. The group works with OMB as part of the continuing effort to increase the 

accuracy and consistency of agency data. The guidance produced by the new work group 

should help agencies present a more accurate report of the total number of the standards 

they use and of agency participation in standards activities. 

In FY 2005, NIST also conducted its first intra-government training session to clarify 

agency responsibilities for reporting standards usage under the NTTAA. Approximately 

20 representatives of various Federal agencies attended the NTTAA training session. 

The training included a round-table discussion of issues and problems in reporting agency 

use of standards. One major issue identified during the FY 2005 session was related to 

the turnover in agency staff. New staff members who are assigned reporting 

responsibilities are often unaware of the NTTAA, the Circular, and their agency’s duties 

and responsibilities under both. This lack of awareness has sometimes led to 

inconsistent, incomplete, or delayed reporting. NIST plans to continue its training efforts 

for newer ICSP representatives so that the requirements of the NTTAA and the Circular 

are carried out effectively. 

3.1 – Government-Unique Standards Used in Lieu of Voluntary 

Consensus Standards 

A major goal of the NTTAA is to reduce the need for Federal government use of 

government-unique standards. Hence, Section 6 of the Circular requires that Federal 

agencies report such use and explain the reason(s) why their agencies must use 

government-unique standards in lieu of private sector standards. However, reporting of 

such use is limited to only those situations where an applicable private sector standard 

exists. If there is no applicable private sector standard available to address the agency’s 

needs, then the use of a government-unique standard is not required to be reported. In the 

past, some agencies have reported the use of government-unique standards in cases where 

no applicable private sector standard was available. NIST continues to work with the 

agencies to clarify that no reporting is required in these cases. 

Section 12 of the Circular allows Federal agencies to report their use of private sector 

standards on either a “categorical” or a “transactional” basis. Those agencies that report 

on a “categorical” basis are not required to list each instance that a government-unique 

standard is used in lieu of a private sector standard in procurement actions. Agencies that 

routinely reference private sector or government-unique standards in their numerous 

3
procurement actions can report such usage on a “categorical” basis if they meet other 

requirements outlined in the Circular. For example, the agency must maintain a 

centralized standards management system that identifies how the agency uses both 

government-unique and private sector standards. The agency must also maintain records 

on the groups or categories in which the agency uses government-unique standards in lieu 

of private sector standards. Such agencies are also required to have a system in place to 

ensure that government-unique standards are developed only when suitable private sector 

standards are not available for use. At present, only DoD and the National Aeronautics 

and Space Administration (NASA) consistently report on a “categorical” basis. In those 

cases when government-unique standards are required because private-sector standards 

do not exist, use of the government-unique standard is not subject to reporting. 

Regulatory agencies must report their standards use on a “transactional” basis because 

they use far fewer standards in their rulemaking processes than do agencies, such as DoD, 

that engage in extensive procurement activities. This means that these agencies must 

report every time that a standard is used, typically by reference in a regulation. 

Table 3.1 illustrates the use of government-unique standards (that is, the total number 

used, by agency and the U.S. Government as a whole, by year) in lieu of voluntary 

consensus standards since FY 1997, as well as the number of government-unique 

standards introduced and discontinued in each fiscal year. For FY 2005, the Department 

of Agriculture (USDA) reported the new use of a government-unique standard. The 

Government Printing Office (GPO) identified four instances where the use of 

government-unique standards was previously reported even though no applicable VCS 

existed. The four are recorded as discontinued. The Department of Interior and GPO 

reported new government-unique standards in FY 2005; however, they are not in lieu of 

voluntary consensus standards and therefore not included in the report. 

Table 3.1 – Government-unique Standards Used in Lieu of Voluntary 

Consensus Standards 

Agency 1997 1998 1999 2000 2001 2002 2003 2004 2005 

USDA 1

HHS 3 3 3 3 3 3 3 2 2

HUD 2 2 2 2 2 2

DOL 1 2 4 5 5

DOT 1 2 2 2 2 3 3 3 3

EPA 3 28 29 40 45 50 50 50

GSA 3 2 2 3 2 2

NARA 1 1 1 1 1 1

CPSC 1 1 1 2 2 2

GPO 4 4 4 4 4 0

Total in use 4 8 33 45 56 63 72 71 68

New Uses +4 +4 +25 +12 +12 +7 +9 +1 +1

Discontinued -1 -2 -4

These changes yield a net total of 68 government-unique standards reported as being used 

in lieu of voluntary consensus standards during FY 2005. 

4
A complete listing of the government-unique standards used in lieu of voluntary 

consensus standards from FY 1997 through FY 2005 is available in Appendix C of this 

report. The list includes the justification(s) for not using each listed voluntary consensus 

standard. It should be noted that agency justifications tend to focus on the need for more 

detailed requirements, higher performance specifications and measurements, and/or the 

need to accommodate highly specialized technologies not yet adequately addressed by 

voluntary consensus standards. 

3.2 – Current Federal Agency Use of Voluntary Consensus Standards 

(VCSs) 

Federal agencies annually report the total number of VCSs they used during the previous 

fiscal year. For FY 2005, agencies reported a total of 1,670 new uses of VCSs, with a 

cumulative total number of uses of VCSs reported since 1997 of 6,229. The significant 

increase in FY 2005 is primarily the result of the improved reporting process 

implemented by DHS, which reported 987 new uses. Table 3.2 illustrates the upward 

trend in the total number of VCSs in use by Federal agencies. 

Table 3.2 -- Voluntary Consensus Standards Used by 

Federal Agencies

6229

4559 4380 3749 3984

5453*

3383

2803

1883

0

1000

2000

3000

4000

5000

6000

7000

1997 1998 1999 2000 2001 2002 2003 2004 2005

Years

* The increase of VCS usage during FY 2000 was due largely to a reported increase 

of more than 1500 VCSs used by the Department of Interior. This irregularity is attributable 

to erroneous interpretations of the term “use” by DOI as described in Section 3.0 of this 

report. These 1500 VCSs were withdrawn from the inventory for subsequent reporting years. 

It should be noted that, since these data include only those standards used since the 1997 

onset of agency reporting, the data do not include all non-governmental standards 

currently in use by DoD, which initiated efforts to minimize use of government-unique 

standards prior to enactment of the NTTAA. DoD continues to be the leader in the 

adoption of private sector standards reporting a total inventory of 9,083 private sector 

standards for FY 2005. 

5
3.3 – Current Agency Reporting on Voluntary Consensus Standards 

Substituted for Government-Unique Standards 

Federal agencies also report annually on the number of voluntary consensus standards 

they have substituted for government-unique standards during the year. Table 3.3 

illustrates the cumulative total number of substitutions each year since FY 1997. In FY 

2005, Federal agencies substituted 243 voluntary consensus standards for governmentunique standards. After an intense initial effort to substitute many standards, the trend 

within the Federal government to make such substitutions is still increasing although at a 

slower pace. 

Table 3.3 – Cumulative Total of Voluntary Consensus 

Standards Used in Lieu of Government-Unique Standards. 

2270 1923 2027

1647 1738 1542

1006

459

150

0

500

1000

1500

2000

2500

1997 1998 1999 2000 2001 2002 2003 2004 2005

Years

4.0 – Federal Participation in Private Sector Standards Activities 

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 – Participation Data for FY 2005

In FY 2005, agencies reported participation in 409 private sector standards bodies, 

compared to 431 in FY 2004. The list of organizations includes American National 

Standards Institute (ANSI)-accredited voluntary consensus standards developers, industry 

and trade associations, and international organizations. 

6
Federal agencies are also required by OMB to report the number of Federal employees 

, 

In 

 complete listing of the standards developing organizations in which Federal agencies 

ovided in 

.2 – Strategic Partnerships 

day, standards are playing a valuable role in tackling some of the important issues 

or example, the development of appropriate standards for addressing health informatics, 

In support of the President’s Health Information Technology Agenda, the Office of the 

). 

The General Services Administration’s E-Authentication Initiative will provide a trusted 

Successful implementation of E-Authentication will produce numerous benefits for the 

who participate in private sector standards bodies. This includes not only those who 

serve on technical standards development committees, subcommittees, or workgroups

but also those who participate in management activities, annual meetings, or seminars. 

FY 2005, agencies reported that 3,954 employees participated in private sector standards 

body activities. This was an increase of 736 participants from FY 2004. 

A

participated can be viewed in the extended appendices to this report located at 

http://standards.gov. Data detailing FY 2005 participation for each agency is pr

Appendix B. 

4

To

facing the country today. To best address these standards needs, the government and 

private sector are forming strategic partnerships to develop standards that will reduce 

costs, improve quality, and provide greater value to all stakeholders. 

F

computer security, and homeland security will provide for common and uniform 

requirements to help ensure effective and interoperable products. 

National Coordinator for Health Information Technology in the Department of Health 

and Human Services has contracted with the American National Standards Institute 

(ANSI) to organize the Healthcare Information Technology Standards Panel (HITSP

HITSP serves as a cooperative partnership between the public and private sectors for the

purpose of achieving a widely accepted and useful set of standards specifically to enable 

and support widespread interoperability among health related software applications. The 

HITSP is comprised of a wide range of stakeholders that will assist in the harmonization 

of the standards needed for the U.S. Nationwide Health Information Network (NHIN). 

and secure standards-based authentication architecture to support Federal E-Government 

applications and initiatives. Standards will provide a uniform process for establishing 

electronic identity and eliminate the need for each initiative to develop a redundant 

solution for the verification of identity and electronic signatures. E-Authentication’s 

distributed architecture will also allow citizens and businesses to use non-government 

issued credentials to conduct transactions with the government. 

public and the Federal government. Citizens and businesses will have a secure, easy-touse and consistent method of proving identity to the government and will be spared the 

burden of having to keep track of multiple sets of registration information. Federal 

7
agencies will be able to reduce authentication system development and acquisition c

and reallocate labor resources previously used to develop such systems. 

osts 

lso, in 2003, ANSI formed the American National Standards Institute's Homeland 

s, or, 

e nation 

e expect to see increased public-private partnerships focusing on strategic standards 

e also 

een 

.0 – Federal Agency Conformity Assessment Activities 

he NTTAA requires NIST to coordinate Federal, State, and local standards activities 

ation 

s of 

ncy 

 of 

 of 

ironmental 

ch agency is responsible for coordinating its conformity assessment activities with 

ble 

his year, agencies reported several examples of using existing public and private sector 

conformity assessment systems to reduce the duplication of programs and associated 

A

Security Standards Panel (ANSI-HSSP) which identifies existing consensus standard

if none exist, assists the Department of Homeland Security (DHS) and those sectors 

requesting assistance to accelerate development and adoption of consensus standards

critical to homeland security. The ANSI-HSSP promotes a positive, cooperative 

partnership between the public and private sectors in order to meet the needs of th

in this critical area. 

W

needs in the future as both government and private sector work together to identify 

standards that are critical to facilitating innovation and global competitiveness, whil

protecting public health, safety and the environment. Both OMB Circular A-119 and the 

NTTAA recognize the valuable contributions that standards make in enabling the 

government to carry out its responsibilities. Close interaction and cooperation betw

the public and private sectors are critical to developing and using standards that serve 

national needs and support innovation and competitiveness. 

5

T

and conformity assessment activities with private sector standards activities and 

conformity assessment activities, with the goal of eliminating unnecessary duplic

and complexity in the development and promulgation of conformity assessment 

requirements and measures. Federal conformity assessment activities are a mean

providing assurance that the products and services regulated or procured by Federal 

agencies have the required characteristics and/or perform in a specified manner. Age

conformity assessment procedures may include sampling and testing, inspection, 

accreditation, certification; licensing; product listing; the submission to an agency

manufacturing, operational, and related data for review; manufacturer self-declaration

conformity to agency requirements; mandatory labeling and advertising requirements; 

establishment of national requirements which are adopted/enforced at state and local 

government levels; issuance of regulatory guidelines; pre-marketing approval 

requirements; post-marketing monitoring requirements; and the conduct of env

impact assessments. 

 

Ea

those of other cognizant government agencies and with those of the private sector in 

order to make more productive use of the increasingly limited federal resources availa

for the conduct of conformity assessment activities and to reduce unnecessary 

duplication. 

T

8
costs. Examples of ongoing cooperation in conformity assessment activities include the 

following: 

The Department of Health and Human Services (HHS) reported several activities 

including: 

participation on ongoing conformity assessment activities such as the 

ANSI Accreditation and International Conformity Assessment Committees and 

ing 

gical Health allows a medical device 

manufacturer to submit a Declaration of Conformity to a "recognized standard" as 

g of 

 to 

ffairs (FDA/ORA) actively participates in the 

National Cooperation for Laboratory Accreditation (NACLA), serving as a 

al 

of 

hancing international credibility and recognition, FDA’s 

Center for Food Safety and Applied Nutrition (CFSAN) is moving towards ISO 

GS including 

direct inspection, testing, supplier and third party testing, and product qualification 

d that all of its 28 conformity assessment programs under the HUD 

Building-Products Standards & Certification Programs are in compliance with ISO 

ate 

Contract Administration Services, including substantial conformity assessment 

FDA’s 

ANSI’s Board Committee on Conformity Assessment, as well as American 

Society for Testing and Materials (ASTM) Committee E-36 on Conformity 

Assessment allows FDA to ensure that its needs are met while utilizing exist

recognition and accreditation criteria. 

FDA’s Center for Devices and Radiolo

described in ISO/IEC Guide 22 in its standards recognition program and has 

developed an MRA with the European Union on mutual recognition of each 

other's conformity assessment procedures related to manufacture and marketin

medical devices. This reduces costs for manufacturers and decreases the time

market for approved products. 

The FDA Office of Regulatory A

member of the NACLA Executive Board of Directors and participating in the 

NACLA Recognition Committee for Accrediting Bodies who apply for mutu

recognition. This participation may form the basis for the future accreditation 

FDA laboratories. 

With the idea of en

accreditation of its own laboratories that perform regulatory work. 

A reported employing a number of conformity assessment activities

and listing. 

HUD reporte

guidelines and procedures. Reliance on these standards is consistent with the priv

sector practices and provides uniformity in the conformity assessment process, 

whether administered by HUD or by private sector organizations referenced by HUD. 

NASA reported that it routinely utilizes other government agencies to assist with its 

activities. The Defense Contract and Audit Agency, Defense Contract Management 

9
Agency, Office of Naval Research, and other activities continue to provide 

conformity assessment services for NASA Programs. 

The Department of Commerce reported that the Nuclear Regulatory Commission 

. 

armonize 

NIST staff worked with the Consumer Product Safety Commission (CPSC) to 

e 

 

NIST staff provided advice and expertise to the Department of Homeland 

ogram 

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

.0 – Evaluation of the Effectiveness of OMB Circular A-119 

uring FY 2005, the majority of reporting agencies either had no comments on the 

tive 

ne department reported that the existing OMB policy concerning participation in VCSs 

collect 

(NRC) now accepts accreditation by qualified laboratory accreditation bodies as an

acceptable alternative to a supplier audit, commercial-grade survey, or in-process 

surveillance for the qualification of commercial grade calibration service suppliers

This reduces resource burdens on industry and eliminates costs related to redundant 

audits. The Department also reported that: 

NIST provides technical support for the Inter-American Accreditation 

Cooperation (IAAC). Such arrangements/agreements are designed to h

conformity assessment practices and promote the global acceptance of conformity

assessment results from qualified bodies to minimize the need for and cost of 

redundant conformity assessment activities. 

refine the conformity assessment portion of CPSC's China strategy (to reduce th

number of unsafe consumer products imported from China into the United States).

Security for the design and implementation of a laboratory accreditation pr

for laboratories that test radiation detectors for homeland security application by 

federal, state, and local personnel. The laboratory accreditation program, to be 

carried out by NVLAP, is intended to be the first step towards establishing a 

comprehensive certification program for radiation detectors. 

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

D

effectiveness of OMB Circular A-119 or indicated that they found the Circular effec

in helping them manage their standards development programs. However, some agencies

did provide substantive comments concerning the Circular. Several recommended that 

consideration be given to simplifying the Circular and its reporting requirements. 

Agency comments are summarized below. 

O

activities is a tool that many agencies could employ to encourage support for VCSs 

programs. However, that department noted that it is difficult to implement the 

requirement to collect participant data effectively and recommended that NIST 

10
comprehensive participant data from standards developing organizations, rather than ea

agency reporting individually. 

ch 

nother agency recommended obtaining feedback from regulated communities on the 

d 

.0 – The Interagency Committee on Standards Policy 

uring FY 2005, 54 individuals served on the ICSP including agency Standards 

he 

ive 

 new organizational member was added to the ICSP in FY 2005: the U.S. Access 

ral 

s. 

he ICSP met three times in FY 2005, including one joint meeting with the American 

to 

me of the issues discussed during the FY 2005 ICSP meetings included: 

. The ANSI/EPA efforts on Environmentally Preferable Purchasing (EPP). 

ding 

3. for Standardization (ISO) Social 

4. ent 

5. ernment sector. 

s Strategy. 

dards developing 

.0 – Challenges and Opportunities

ederal agencies continue to experience personnel turnover at all organizational levels 

A

use of VCSs, noting that it has received relatively few comments in response to propose

regulations focusing on the use of VCSs. 

7

D

Executives, their alternates, NIST support staff, and representation from OMB. T

Committee experienced significant turnover in FY 2005, with eight Standards Execut

positions vacant at the end of the year. The Department heads of those agencies with 

vacant Standards Executive positions will be contacted emphasizing the need and 

importance of filling these positions. 

A

Board, formerly the Architectural and Transportation Barrier Compliance Board, 

accepted an invitation to join the ICSP. The Access Board is an independent Fede

Board created by Congress in 1973 to address public access for persons with disabilitie

The Access Board makes extensive use of voluntary consensus standards. 

T

National Standards Institute’s Government Member Forum. The Committee continues 

explore possible future joint meetings with other organizations having related interests. 

 

So

1

2. The Leadership in Energy and Environmental Design (LEEDs) Green Buil

Rating System and its use by Federal agencies. 

Current status of the International Organization 

Responsibility Working Group and ANSI’s Homeland Security Standards Panel. 

The Department of Energy's information system for managing standards developm

and participation; i.e., RevCom. 

Personnel certification in the gov

6. Revision and implementation of the U.S. Standard

7. Changes in requirements of the ANSI program to accredit stan

organizations. 

8

F

due to reorganizations, accelerated or early retirements, and normal attrition. These 

changes make it difficult for Federal agencies to retain high-level managers who 

understand the importance of standards and who visibly support standards-related

11
activities. Staff turnover has also caused a decrease in “institutional memory” of p

standards policies, responsibilities, and practices. To address this issue, NIST recently

developed and is now providing training for Federal employees who are engaged in 

developing standards and using them in regulation or procurement actions. NIST is a

creating a handbook for Standards Executives so that they will have readily available the 

information needed to make decisions about the use of standards. 

ast 

lso 

he availability and dissemination of standards information continues to be a challenge 

r 

FR). 

rts with 

gency 

ustained high-level Federal agency leadership has been identified as the primary driver 

sed 

inally, there are opportunities for improvement to be made in the methods and data that 

rk 

levant 

hile there is more work to be done, there have been instances of success where 

ards. 

By having all of their Army customers in the Midwestern United States buy to only one 

T

for agencies. The internet portal http://standards.gov created by NIST provides a onestop e-government location for information related to the use of voluntary consensus 

standards. The website offers background, materials, useful links, and search tools fo

locating information about the use of standards in government. In FY 2005, NIST 

updated the inventory of standards referenced in the Code of Federal Regulations (C

This inventory allows for the identification of currently used government-unique 

standards. Identification of these government-unique standards may uncover 

opportunities for agencies to replace these standards through collaborative effo

private-sector standards developers. The web site also serves as a forum for providing 

ongoing, practical guidance, tools, and information needed by agencies to successfully 

implement the NTTAA. For example, Federal agencies can now use standards.gov to 

electronically submit their annual reports on standards and conformity assessment 

activities. The electronic reporting system is designed to reduce paperwork at the a

level, to decrease the level of effort previously needed to organize and analyze agency 

data, and to facilitate and expedite the preparation of NIST’s annual report to OMB. 

S

of successful NTTAA implementation. Top agency leaders have the ability to direct 

policy and resources in ways that bring about other desirable outcomes, such as increa

Federal participation and collaboration with the private sector. Ensuring that agency 

Standards Executives have the tools at hand to show how standards and the standards 

making process contribute to their agency’s mission is a continuing priority. 

F

underpin sound economic analyses of the benefits of greater use of private sector 

standards and conformity assessment activities. NIST is now laying the groundwo

necessary for relevant economic analyses to be conducted across the spectrum of 

government agencies. As a first step, existing economic analyses of the impact of

standards on the economy are being collected as a basis for determining the most re

factors. The goal is to have the tools and data in place within three to five years to be 

able to produce the quantitative and objective analyses necessary to demonstrate the 

utility of voluntary consensus standards for the government. 

W

voluntary consensus standards have been used in lieu of government-unique stand

Some examples are: 

- 

12
ASTM specification, the Defense Logistics Agency’s Defense Energy Support Center 

(DESC) was able to accrue savings of $820,000 in both 2004 and 2005. 

- The United States Access Board, coordinating extensively with model building code 

t 

. 

he Nuclear Regulatory Commission’s (NRC) endorsement of Sections III 

echanical 

ot only 

 of 

 a few cases, agencies are able to demonstrate clear economic benefits on a case-byctor on 

• Reduced labor costs to operate and maintain equipment; 

nt readiness; and 

ty, and availability of equipment and parts 

 addition, some Federal agencies are able to point to specific instances where they have 

dged the 

such 

ll these efforts indicate a real and growing reliance on voluntary consensus standards 

organizations, revised its Americans with Disabilities Act and Architectural Barriers Ac

(ABA) Accessibility Guidelines to make them more consistent with model building codes

and industry standards such as those from the National Fire Protection Association and 

the International Code Council. This effort will allow harmonization with model codes 

and standards, greatly facilitating these two Acts and fostering a better understanding 

between the building community and the Access Board as to the needs for accessibility

T

(Construction) and XI (In-service Inspection) of the American Society of M

Engineers (ASME) Boiler and Pressure Vessel Code and Code for Operation and 

Maintenance of Nuclear Power Plants (In-service Testing of Pumps and Valves) n

saved the Commission valuable time and resources but also encouraged uniform 

application of requirements, promotion of regulatory efficiency and enhancement

public confidence in the regulatory process. 

In

case basis. The Department of Defense has conducted several case studies that 

demonstrate a range of positive results from its collaborations with the private se

standardization issues. Some of DoD’s documented benefits include: 

• Lower inventory costs; 

• Improved safety; 

• Improved equipme

• Enhanced interchangeability, reliabili

and better equipment performance. 

In

benefited from NTTAA implementation in ways that cannot be quantitatively measured. 

For example, the Environmental Protection Agency (EPA) is making "beyondregulation" use of voluntary consensus bodies and of ANSI. EPA has acknowle

important role that voluntary consensus organizations play in the development and 

promulgation of standards for environmentally conscientious products. EPA has 

partnered with ANSI to educate and train standards organizations on the need for 

standards. Together, EPA and ANSI have provided organizations with criteria that can 

serve as a guideline for use by standards committees working in this area. ANSI has also

conducted several workshops and training sessions in cooperation with EPA and posted 

useful information in this area on ANSI’s website. 

A

benefiting not only the government, but also businesses and the American public 

13
Appendix A – FY 2005 List of Federal Agencies That Report 

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 Homeland Security DHS 

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 

A-1
Appendix B – FY 2005 Federal Agency Use of Standards and Participation in Private Sector Standards 

Bodies 

FY 2005 Federal Agency Information On Participation/Adoption Of Private Sector Standards Activities 

Required by OMB Circular A-119 

Agency 

Government 

unique standards 

used in lieu of 

voluntary 

consensus 

standards 

Private sector 

standards 

substituted for 

government 

unique 

standards 

Private 

sector 

standards 

used this 

year 

Employee 

participation in 

private sector 

standards 

bodies 

Change 

from 

previous 

year 

Private sector 

standards 

bodies with 

agency 

participation 

Change 

from 

previous 

year 

USDA 1 10 238 52 -30 17 -18 

DOC 0 0 0 442 4 98 4 

DoD * 227 227 1106 670 118 -5 

DOE 0 0 1430 761 32 70 5 

ED 0 0 60 4 4 5 5 

HHS 2 3 945 594 91 114 -68 

DHS 0 0 1000 160 150 50 43 

HUD 2 0 300 4 -6 4 -1 

DOI 0 2 768 74 -195 26 7 

DOJ 0 0 0 1 -4 0 -1 

DOL 5 0 1 52 -2 16 -3 

DOS 0 0 0 8 1 1 0 

DOT 3 0 381 209 42 47 6 

TRES NR NR NR NR NR NR NR 

VA 0 0 0 4 0 20 2 

EPA 50 0 50 52 7 26 3 

USAID NR NR NR NR NR NR NR 

GSA 2 0 516 22 -69 25 -1 

NARA 1 0 89 16 -3 10 0 

NASA * 1 195 172 25 31 1 

NSF 0 0 0 4 -1 4 -1 

CPSC 2 0 28 28 -2 8 0 

FCC 0 0 0 36 31 13 6 

FTC 0 0 0 0 0 0 0 

NRC 0 0 1 153 8 15 2 

GPO 0 0 0 0 -2 0 -6 

Totals 68 243 6229 3954 736 ** ** 

NR: Not Reported 

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

** Totals not provided. (Totals would include multiple counting of certain bodies that enjoy simultaneous 

participation from two or more Federal agencies.) 

B-1
Appendix C –Government-Unique Standards Used in Lieu of Voluntary Consensus 

Standards 

Appendix C.1 – Government-Unique Standards Used in Lieu of Voluntary 

Consensus Standards Incorporated in FY 2005 

Agency: Department of Agriculture (USDA)

Government Standard: USDA Forest Service Specification 5100-307; International Specification 

for Fire Suppressant Foam for Wild land Fires, Aircraft or Ground Application [Incorporated 

2005] 

Voluntary Standard Rationale 

NFPA 1150 - Standard on Fire-Fighting Foam 

Chemicals for Class A Fuels in Rural, 

Suburban, and Vegetated Areas. 

Foam fire suppressants contain foaming and wetting agents. The 

foaming agents affect the accuracy of an aerial drop, how fast the water 

drains from the foam and how well the product clings to the fuel 

surfaces. The wetting agents increase the ability of the drained water to 

penetrate fuels. Foam fire suppressants are supplied as wet 

concentrates. 

This standard was developed with international cooperation for Class A 

Foam used in wild land fire suppression situations and equipment. This 

standard was created by the USDA Forest Service in cooperation with 

the Department of Interior (DOI), the State of California, Department of 

Forestry and Fire Protection and the Canadian Interagency Forest Fire 

Center. 

The National Fire Protection Association (NFPA) does have a standard 

for Class A Foam, (NFPA 1150 - Standard on Fire-Fighting Foam 

Chemicals for Class A Fuels in Rural, Suburban, and Vegetated Areas). 

The Forest Service has not chosen to utilize NFPA 1150 as it is 

designed specifically for application by municipal fire agencies in the 

wild land-urban interface, utilizing apparatus and situations that they are 

likely to encounter. The Forest Service’s GUS for foam products is 

specific to use by wild land fire equipment and situations that are 

unique, e.g. helicopter use of foams, remote storage situations, and 

varied quality of water sources in the wild land settings. The agency 

feels this standard more accurately reflects the needs and mission of the 

federal wild land fire suppression agencies. 

C-1
Appendix C.2 –Instances of Government-Unique Standards Used in lieu of 

Voluntary Consensus Standards Discontinued in FY 2005 

Agency: Government Printing Office (GPO) 

Government Standard: FED-STD 209 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ISO 14644-1 & ISO 14644-2 Military and Federal quality assurance standards used and gradually 

phased out. 

 

Government Standard: MIL-STD 105 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ANSI/ASQC Z1.4 Military and Federal quality assurance standards used and gradually 

phased out. 

 

 

Government Standard: MIL-STD 1189 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ANSI/AIM X5-2 & ANSI X3.182 Military and Federal quality assurance standards used and gradually 

phased out. 

 

 

Government Standard: MIL-STD 498 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

IEEE/EIA 12207.0, IEEE/EIA 12207.1, & 

IEEE/EIA 12207.2 

 Military and Federal quality assurance standards used and gradually 

phased out. 

C-2
Appendix C.3 – Government-Unique Standards Used in Lieu of Voluntary Consensus 

Standards from FY 1997 through FY 2005

 

Agency: Consumer Product Safety Commission (CPSC) 

Government Standard: CPSC CFR Parts 1213, 1500, and 1513 [Incorporated: 2000] 

Voluntary Standard Rationale 

ASTM F1427-96 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. 

 

 

Government Standard: FR/Vol. 68, No. 75/Friday, April 18, 2003, pp. 19142-19147, Metal-Cored 

Candlewicks Containing Lead and Candles With Such Wicks [Incorporated: 2003] 

Voluntary Standard Rationale 

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, 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. 

 

 

Agency: Department of Labor (DOL) 

Government Standard: Electric Motor-Drive Equipment Rule [Incorporated: 2001] 

Voluntary Standard Rationale 

IEEE Standard 242-1986 Recommended Practice 

for Protection and Coordination of Industrial and 

Commercial Power Systems (IEEE Buff Book) and 

NFPA 70 - national Electric 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. 

 

 

Government Standard: Exit Routes, Emergency Action Plans, and Fire Prevention Plans, 29 CFR 

1910, Subpart E [Incorporated: 2003] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: Fire Protection for Shipyards, 29 CFR Part 1915, Subpart 

P [Incorporated: 2004] 

Voluntary Standard Rationale 

NFPA 312-2000 Standard for Protection of 

Vessels During Construction, Repair, and Lay-Up 

NFPA 33-2003 Standard for Spray Application 

Using Flammable or Combustible Materials 

Many consensus standards were relied on for various provisions in 

OSHA's final rule, including 15 consensus standards that are 

incorporated by reference. However, OSHA and its negotiated 

rulemaking committee determined that there was no single 

consensus standard available that covered all the topics in the rule. 

 

C-3
 

Government Standard: Sanitary Toilets in Coal Mines, 30 CFR 71, Subpart E [Incorporated: 

2003] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: Steel Erection Standards [Incorporated: 2002] 

Voluntary Standard Rationale 

ANSI A10.13 - Steel Erection; ASME/ANSI B30 

Series Cranes Standards 

There was no one consensus standard available that covered all of 

the topics covered by OSHA's final rule. 

 

 

Agency: Department of Transportation (DOT) 

Government Standard: 63 FR 17976; April 13, 1998 - Product Safety Signs and 

Labels [Incorporated: 1998] 

Voluntary Standard Rationale 

ANSI Z535.4 - ANSI Requirements for Color 

Coded Header Messages for the Different Levels 

of Hazard 

NHTSA explained in the NPRM that the American National 

Standard Institute (ANSI) has a standard4 for product safety signs 

and labels (ANSI Z535.4) that identifies a hierarchy of hazard levels 

ranging from extremely serious to moderately serious and specifies 

corresponding hierarchies of signal words, i.e., “danger,” “warning,” 

and “caution,” and of colors. For the header, the ANSI standard 

specifies a red background with white text for “danger,” an orange 

background with black text for “warning,” and a yellow background 

with black text for caution.” 

The ANSI standard specifies that pictograms should be black on 

white, with occasional uses of color for emphasis, and that 

message text should be black on white. The agency noted in the 

NPRM that when it earlier updated the requirements for air bag 

warning labels to require the addition of color and pictograms, it had 

chosen not to adopt the colors specified in the ANSI standard. 

NHTSA chose to use yellow instead of orange in the background of 

the heading for the air bag warning label, even though the word 

“warning” was used, because of overwhelming focus group 

preference for yellow. Only two of the 53 participants preferred 

orange. Participants generally stated that yellow was more eyecatching than orange. Participants also noted that red (stop) and 

yellow (caution) had meaning to them, but not orange. 

NHTSA asked for comment on three color options for the revised 

utility vehicle rollover warning label. Proposed label 1 used the 

ANSI color format with the heading background in orange with the 

words in black. The remainder of the label had a white background 

with black text and drawings. Proposed label 2 used a color 

scheme like the air bag warning labels, which is the same as the 

ANSI color format except that the background color for the heading 

in the label is yellow. Proposed label 3 employed the color scheme 

used in the focus groups - the heading area had a red background 

with white text. The graphic areas had a yellow background with 

C-4
black and white drawings. The text area had a black background 

with yellow text. 

Despite focus group preference for the signal word “danger,” the 

agency proposed the use of the word “warning” as more 

appropriate to the level of risk. The agency also noted that the 

word “warning” is used in the air bag warning label. 

Recognizing that it might encounter additional conflicts between 

focus group preferences and the ANSI standard in future 

rulemakings, NHTSA requested comments in the NPRM on the 

extent to which any final choice regarding colors and signal words 

should be guided by the focus group preferences instead of the 

ANSI standard. NHTSA also requested comments on the broader 

issue of the circumstances in which it would be appropriate for 

agency rulemaking decisions to be guided by focus group results or 

other information when such information is contrary to a voluntary 

consensus standard such as the ANSI standard. 

At this time (February 22, 1999), a final decision is still pending 

regarding its proposal to upgrade the rollover warning label. As to 

the general questions it posed in the NPRM, NHTSA recognizes 

that ANSI’s mission differs somewhat from that of the agency’s 

focus groups with respect to the labeling of hazardous situations. 

ANSI’s mission is to develop and maintain a standard for 

communicating information about a comprehensive hierarchy of 

hazards, while the focus groups’ mission is to design an effective 

label for a specific hazard. The agency recognizes further that, 

given the difference in their missions, their conclusions about the 

appropriate manner of communication might differ on occasion. 

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. 

 

 

Government Standard: Air Bag Warning Label (1997) [Incorporated: 1997] 

Voluntary Standard Rationale 

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 

the industry standards. 

 

 

Government Standard: Brake Performance, 49 CFR 393.52 - FMCSA's Performance-Based 

Brake Testers (PBBTs) Requirement [Incorporated: 2002] 

Voluntary Standard Rationale 

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 

C-5
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 heavyduty 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. 

 

 

Agency: Environmental Protection Agency (EPA) 

Government Standard: 40 CFR 89 - Control of Emissions from New and In-Use Non-Road 

Compression Ignition Engines [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

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. 

 

 

Government Standard: 40 CFR 90 - Control of Emission from Non-Road Spark Ignition Engines 

at or below 19KV [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

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. 

 

 

Government Standard: 40 CFR 92 - Control of Air Pollution from Locomotives and Locomotive 

Engines [Incorporated: 2000] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

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. 

 

 

Government Standard: EPA Method 1 – Traverse Points, Stationary Sources [Incorporated: 

1999] 

Voluntary Standard Rationale 

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. 

 

C-6
ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube Method) 

The standard is too general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory requirements. 

 

 

Government Standard: EPA Method 10 - Carbon Monoxide, NDIR [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D3162 (1994) Standard Test Method for 

Carbon Monoxide in the Atmosphere (Continuous 

Measurement by Non-dispersive 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). 

 

CAN/CSA Z223.21-M1978, Method for the 

Measurement of Carbon Monoxide: 3—Method of 

Analysis by Non-Dispersive Infrared Spectrometry

1. This standard 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, 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. 

 

 

Government Standard: EPA Method 101 - Mercury Emissions, Chlor-Alkali Plants 

(Air) [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 - Standard Practice for Opacity 

Monitor Manufacturers to Certify Conformance 

with Design and Performance Specifications. 

The EPA incorporates 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. 

 

Government Standard: EPA Method 101a - Mercury Emissions Sewer/Sludge 

Incinerator [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 - Standard Practice for Opacity 

Monitor Manufacturers to Certify Conformance 

with Design and Performance Specifications. 

The EPA incorporates 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. 

 

 

Government Standard: EPA Method 10A – Carbon Monoxide for Certifying CEMS [Incorporated: 

2001] 

Voluntary Standard Rationale 

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 

C-7
the target concentration; (5) mandatory instrument performance 

characteristics (e.g., rise time, fall time, zero drift, span drift, 

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. 

 

 

Government Standard: EPA Method 12 – Inorganic Lead, Stationary Sources [Incorporated: 

2001] 

Voluntary Standard Rationale 

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 non-glass fiber media, which cannot be considered 

equivalent to EPA Method 29. 

 

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 non-glass 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 non-glass fiber media, which cannot be considered 

equivalent to EPA Method 29. 

 

 

C-8
Government Standard: EPA Method 15 - Hydrogen Sulfide/Carbon Disulfide/Carbon 

Sulfide [Incorporated: 1999] 

Voluntary Standard Rationale 

ASME C00031 or PTC 19-10-1981 - Part 10 Flue 

and Exhaust Gas Analyses 

The standard is too broad to be useful in regulatory sense. Covers 

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

 

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. 

 

 

Government Standard: EPA Method 1650 - Organic Halides, Absorbable (AOX) [Incorporated: 

1998] 

Voluntary Standard Rationale 

ISO, DIN, SCAN, and Standard Methods (SM 

5320) 

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. 

 

 

Government Standard: EPA Method 17 - Particle Matter (PM) In Stack Filtration [Incorporated: 

1999] 

Voluntary Standard Rationale 

ASME C00049 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. 

 

ASTM D3685/3685M-95 - Standard Test method 

for Sampling and Determination of Particle 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. 

 

 

Government Standard: EPA Method 18 - VOC/GC [Incorporated: 1999] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: EPA Method 180.1 - Turbidity Nephelometric [Incorporated: 1999] 

Voluntary Standard Rationale 

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. 

 

C-9
 

Government Standard: EPA Method 2 – Velocity and S-type Pitot [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM 3796-90 (1998), Standard Practice for 

Calibration of Type S Pitot Tubes 

They are too general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory requirements. 

 

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) 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

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. 

 

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. 

 

 

Government Standard: EPA Method 21 - Volatile Organic Compound (VOC) 

Leaks [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM E1211-97 - Standard Practice for Leak 

Detection and Location Using Surface-Mounted 

Acoustic Emission Sensors 

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 against a primary instrument. Background noise 

interference in some source situations could also make this 

standard difficult to use effectively. 

 

 

Government Standard: EPA Method 23 – Dioxin and Furan (PCDD and PCDF) [Incorporated: 

1999] 

Voluntary Standard Rationale 

European Committee for Standardization (CEN) 

EN 1948-3 (1997), Determination of the Mass 

Concentration of PCDD'S/PCDF'S--Part 3: 

Identification and Quantification 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

Government Standard: EPA Method 24 – Surface Coatings, Volatile Matter 

Content [Incorporated: 1998] 

Voluntary Standard Rationale 

ISO 11890-1 (2000) part 1, Paints and Varnishes--

Determination of Volatile Organic Compound 

Measured nonvolatile matter content can vary with experimental 

factors such as temperature, length of heating period, size of 

C-10
(VOC) Content-Difference Method 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 Celsius 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. 

 

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. 

 

 

Government Standard: EPA Method 25 – Gaseous Nonmethane Organic 

Emissions [Incorporated: 2001] 

Voluntary Standard Rationale 

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. 

 

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. 

 

 

Government Standard: EPA Method 25A – Gaseous Organic Concentration, Flame 

Ionization [Incorporated: 2001] 

Voluntary Standard Rationale 

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. 

 

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. 

 

 

Government Standard: EPA Method 26 – Hydrogen Chloride, Halides, Halogens 

Emissions [Incorporated: 1999] 

Voluntary Standard Rationale 

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 

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 

C-11
Solutions Analysis and Calculation 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. 

 

 

Government Standard: EPA Method 26A – Hydrogen Halide and Halogen, 

Isokinetic [Incorporated: 1999] 

Voluntary Standard Rationale 

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 

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. 

 

 

Government Standard: EPA Method 28 (Section 10.1) – Wood Heaters, Certificate and 

Auditing [Incorporated: 2003] 

Voluntary Standard Rationale 

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. 

 

ASTM E319-85 (Re-approved 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. 

 

 

Government Standard: EPA Method 29 – Metals Emissions from Stationary 

Sources [Incorporated: 2001] 

Voluntary Standard Rationale 

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 non-glass fiber media, which cannot be considered 

equivalent to EPA Method 29. 

 

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, 

C-12
whereas these three ASTM standards require cellulose filters and 

other probable non-glass 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 non-glass fiber media, which cannot be considered 

equivalent to EPA Method 29. 

 

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. 

 

 

Government Standard: EPA Method 2C – Velocity and Flow Rate, Standard Pitot [Incorporated: 

1999] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: EPA Method 3 – Molecular Weight Carbon Dioxide, 

Oxygen [Incorporated: 1999] 

Voluntary Standard Rationale 

ASME C00031 or PTC 19-10-1981--part 10, "Flue 

and Exhaust Gas Analyses" 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

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. 

 

C-13
 

Government Standard: EPA Method 306 - Chromium Emissions, Electroplating and 

Anodizing [Incorporated: 2002] 

Voluntary Standard Rationale 

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). 

 

 

Government Standard: EPA Method 306a - Chromium Emissions, Electroplating -- Mason 

Jar [Incorporated: 2002] 

Voluntary Standard Rationale 

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). 

 

 

Government Standard: EPA Method 320 – Vapor Phase Organic and Inorganic Emissions, 

FTIR [Incorporated: 1999] 

Voluntary Standard Rationale 

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 an 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 caseby-case basis. 

 

 

Government Standard: EPA Method 3A – Carbon Dioxide and Oxygen Concentrations, 

IAP [Incorporated: 1999] 

Voluntary Standard Rationale 

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 

C-14
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. It 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. 

 

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 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. 

 

 

Government Standard: EPA Method 3B – Oxygen, Carbon Dioxide, Carbon Monoxide, Emission 

Rate Correction Factor [Incorporated: 1999] 

Voluntary Standard Rationale 

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) 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

C-15
 

Government Standard: EPA Method 4 – Moisture Content in Stack Gases [Incorporated: 1999] 

Voluntary Standard Rationale 

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) 

It 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 Wet- and Dry-Bulb 

Temperatures) 

They are too general, too broad, or not sufficiently detailed to 

assure compliance with EPA regulatory requirements. 

 

 

Government Standard: EPA Method 5 – Particulate Matter, Stationary Sources [Incorporated: 

1999] 

Voluntary Standard Rationale 

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. 

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. 

 

 

Government Standard: EPA Method 515.1 - Chlorinated Acids in Water by 

CC/ECD [Incorporated: 1998 and 2003] 

Voluntary Standard Rationale 

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 contamination. EPA plans to offer 

to work with the Standard Methods committee to resolve this issue 

prior to the next publication. 

 

 

Government Standard: EPA Method 515.4 – Chlorinated Acids in DW by LL Fast 

CG/ECD [Incorporated: 2003] 

Voluntary Standard Rationale 

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. 

C-16
Therefore, this method permits unacceptably large control limits, 

which include 0 percent recovery. 

 

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. 

 

 

Government Standard: EPA Method 531.2 – N-Methylcarbamoylozimes/ates, Aqueous 

In/HPLC [Incorporated: 2003] 

Voluntary Standard Rationale 

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. 

 

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. 

 

 

Government Standard: EPA Method 5i - Low Level Particulate Matter, Stationary 

Sources [Incorporated: 2001] 

Voluntary Standard Rationale 

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 

C-17
the EPA method and which are appropriate to use in this rule. 

 

 

Government Standard: EPA Method 6 - Sulphur Dioxide Emissions [Incorporated: 1999] 

Voluntary Standard Rationale 

ASME C00031 or PTC 19-10-1981 - Part 10 Flue 

and Exhaust Gas Analyses 

They are too broad to be useful in regulatory sense. Covers 

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

 

ISO 11632:1998 - Stationary Source Emissions - 

Determination of the Mass Concentration of Sulfur 

Dioxide - Ion Chromatography 

 

ISO 7934:1998 - Stationary Source Emissions - 

Determination of the Mass Concentration of Sulfur 

Dioxide - Hydrogen Peroxide/Barium Perchlorate/ 

Thorin Method 

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 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. 

 

 

Government Standard: EPA Method 6c - Sulphur Dioxide Emissions Stationary by 

IAP [Incorporated: 1999] 

Voluntary Standard Rationale 

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, CTM 022, the standard 

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 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and 

Oxides of Nitrogen in Enclosed Combustion Flue 

Gas Streams 

It is 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. 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

It duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022 and lacks in 

detail and quality assurance plus quality control requirements. 

Similar to ASTM D5835. 

 

 

Government Standard: EPA Method 7 - Nitrogen Oxide Emissions Stationary 

Sources [Incorporated: 1999] 

Voluntary Standard Rationale 

ASME C00031 or PTC 19-10-1981 - Part 10 Flue 

and Exhaust Gas Analyses 

It is too broad to be useful in regulatory sense. Covers Methods 3, 

6, 7, and 15 with variants. 

 

 

Government Standard: EPA Method 7e - Nitrogen Oxide, Instrumental [Incorporated: 1999] 

Voluntary Standard Rationale 

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, CTM 022, It 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 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and 

Oxides of Nitrogen in Enclosed Combustion Flue 

Gas Streams 

It is 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. 

 

C-18
ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

It duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022 and lacks in 

detail and quality assurance plus quality control requirements; 

similar to ASTM D5835. 

 

 

Government Standard: EPA Method ALT 004 [Incorporated: 2002] 

Voluntary Standard Rationale 

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, CTM 022, it lacks in 

detail and quality assurance and quality control requirements; very 

similar to ISO 10396. 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

It duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022 and lacks in 

detail and quality assurance plus quality control requirements; 

similar to ASTM D5835. 

 

 

Government Standard: EPA Method CTM 022 [Incorporated: 2002] 

Voluntary Standard Rationale 

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, CTM 022, it lacks in 

detail and quality assurance and quality control requirements; very 

similar to ISO 10396. 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

It duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022 and lacks in 

detail and quality assurance plus quality control requirements; 

similar to ASTM D5835. 

 

 

Government Standard: EPA Method GG – (Title not found in index) [Incorporated: 2003] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: EPA Performance Specification 1 [Incorporated 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 –Standard Procedure for Opacity 

Monitor Manufacturers to Certify Conformance 

with Design and Performance Specifications 

EPA incorporates ASTM D6216 (manufacturers certification) by 

reference into EPA Performance Specification 1, Sections 5 and 6 

in another rulemaking. ASTM D6216 does not address all the 

requirements specified in PS-1. 

 

 

Government Standard: EPA Performance Specification 2 (sulfur dioxide portion 

only) [Incorporated: 2001] (nitrogen oxide portion only) [Incorporated: 2001] 

Voluntary Standard Rationale 

ISO 7935:1992, Stationary Source Emissions--

Determination of the Mass Concentration of Sulfur 

Dioxide--Performance Characteristics of 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

C-19
Automated Measuring Methods" 

Voluntary Standard Rationale 

ISO 10849:1996, Determination of the Mass 

Concentration of Nitrogen Oxides--Performance 

It is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

 

Government Standard: EPA Performance Specifications 11 - Particulate Matter Continuous 

Monitoring System [Incorporated: 1999] 

Voluntary Standard Rationale 

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 PM CEMS performance specification similar to 

EPA Performance Specification 11, but does not contain detailed 

RATA procedures. Also, EPA doesn’t have a final performance 

specification to compare this to. 

 

 

Government Standard: GLI Method 2 [Incorporated: 1999] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: Standard Method 2130B [Incorporated: 1999] 

Voluntary Standard Rationale 

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. 

 

 

Government Standard: SW846-6010b [Incorporated: 2002] 

Voluntary Standard Rationale 

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. 

 

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 PlasmaAtomic 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. 

C-20
 

 

Agency: Government Printing Office (GPO) 

Government Standard: FED-STD 209 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ISO 14644-1 & ISO 14644-2 Military and Federal quality assurance standards used and 

gradually phased out. 

 

 

Government Standard: MIL-STD 105 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ANSI/ASQC Z1.4 Military and Federal quality assurance standards used and 

gradually phased out. 

 

 

Government Standard: MIL-STD 1189 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

ANSI/AIM X5-2 & ANSI X3.182 Military and Federal quality assurance standards used and 

gradually phased out. 

 

 

Government Standard: MIL-STD 498 [Incorporated: 2000] [Discontinued: 2005] 

Voluntary Standard Rationale 

IEEE/EIA 12207.0, IEEE/EIA 12207.1, & IEEE/EIA 

12207.2 

Military and Federal quality assurance standards used and 

gradually phased out. 

 

 

Agency: General Services Administration (GSA) 

Government Standard: FF-L-2740 Locks, Combination [Incorporated: 1999] [Discontinued: 

2002]; AA-D-600B and AA-V-2737, Door Vault Security and Modular Vault Systems [Incorported: 

2000] [Discontinued: 2001] 

Voluntary Standard Rationale 

UL 608/UL 768 The government standards were justified for protection of National 

security information. 

 

Government Standard: Federal Specification KKK-A-1822E - Federal Specification for 

Ambulances [Incorporated: 2000] 

Voluntary Standard Rationale 

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 

C-21
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 

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. 

 

 

Government Standard: MIL-G-9954 - Glass Beads for Cleaning and Peening [Incorporated: 

2003] 

Voluntary Standard Rationale 

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. 

C-22
________________________________________________________________________________ 

Government Standard: Federal Specification A-A-1925 - Shield, Expansion (Nail 

Anchors) [Incorporated: 2000] [Discontinued: 2004] 

Voluntary Standard Rationale 

Not applicable Upon subsequent review, it was determined that this is not a 

government-unique standard. Rather, it is described by the Defense 

Logistics Agency, the originator of the document, as a Commercial 

Item Description (CID), and it does not replace the applicable test 

method standard ASTM E488. 

 

Agency: Department of Health and Human Services (HHS) 

Government Standard: FDA Guidelines on Asceptic Processing (2004) [Incorporated: 1997] 

Voluntary Standard Rationale 

ISO 13408-1 Asceptic Processing of Health Care 

Products, Part 1, General Requirements 

FDA 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, freezedrying, 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. 

_________________________________________________________________________ 

Government Standard: National Standard Format [Incorporated: 1997] [Discontinued: 2004] 

Voluntary Standard Rationale 

ANSI X12 837 The NSF was used widely across the health care payment industry 

and has become a defacto national standard. However, the 

Centers for Medicare and Medicaid Services (CMS) directed their 

contractors to discontinue use of the NSF standard and replace it 

with ANSI X12 837 by the beginning of FY 2003. 

 

 

Government Standard: FR Notice dated June 17, 1994 Tentative Final Monograph for Health 

Care Antiseptic Drug Products; Proposed Rule [Incorporated: 1997] 

Voluntary Standard Rationale 

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 Pre-injection Skin Preparations 

Sensitivity and bias of the ASTM Standard has not been 

established. 

 

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. 

 

C-23
 

Agency: Department of Housing and Urban Development (HUD) 

Government Standard: 24 CFR 200.935 – 24 CFR 200.955 - Administrator qualifications and 

procedures for HUD building products and certification programs [Incorporated: 2000] 

Voluntary Standard Rationale 

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”. HUD uses 

VC together with program administrators who are qualified to 

validate manufacturers’ certifications that particular building 

products or materials meet applicable HUD standards. VCS without 

conformity assessments would not provide assurances that the 

products conform to HUD requirements. 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. 

 

 

Government Standard: 24 CFR 3280 - Manufactured Home Construction and Safety 

Standards [Incorporated: 2000] 

Voluntary Standard Rationale 

NFPA 501, Standard on Manufactured Housing HUD-Unique Manufactured Home Construction & Safety Standards. 

HUD was required by legislation to “establish Federal Manufactured 

Housing Construction and Safety Standards that comport with the 

purposes of the National Manufacturing Housing and Construction 

Safety Standards Act. As a result of recent changes in the Act, 

HUD is now required to consider recommendations for revising the 

standards that are developed by the Manufactured Housing 

Consensus Committee (MHCC) through its consensus standards 

development process. While the NFPA 501 standard has served as 

the basis for a number of the revisions recommended by the MHCC 

to the Secretary, the MHCC has modified or did not accept other 

provisions of the NFPA 501 standard because those requirements 

did not fully conform to all purposes of the Act. 

 

Agency: National Archives and Records Administration (NARA) 

Government Standard: NARA data standard [Incorporated: 2000] 

Voluntary Standard Rationale 

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)); 

Encoded Archival Description (EAD); 

Machine Readable Cataloging (MARC) 

These voluntary standards do not meet the precise needs of the 

agency. 

C-24
 

Agency: Department of Agriculture (USDA) 

Government Standard: USDA Forest Service Specification 5100-307; International Specification 

for Fire Suppressant Foam for Wild land Fires, Aircraft or Ground Application [Incorporated: 

2005] 

Voluntary Standard Rationale 

NFPA 1150 - Standard on Fire-Fighting Foam 

Chemicals for Class A Fuels in Rural, Suburban, 

and Vegetated Areas. 

Foam fire suppressants contain foaming and wetting agents. The 

foaming agents affect the accuracy of an aerial drop, how fast the 

water drains from the foam and how well the product clings to the 

fuel surfaces. The wetting agents increase the ability of the 

drained water to penetrate fuels. Foam fire suppressants are 

supplied as wet concentrates. 

This standard was developed with international cooperation for 

Class A Foam used in wild land fire suppression situations and 

equipment. This standard was created by the USDA Forest 

Service in cooperation with the Department of Interior (DOI), the 

State of California, Department of Forestry and Fire Protection and 

the Canadian Interagency Forest Fire Center. 

The National Fire Protection Association (NFPA) does have a 

standard for Class A Foam, (NFPA 1150 - Standard on FireFighting Foam Chemicals for Class A Fuels in Rural, Suburban, 

and Vegetated Areas). The Forest Service has not chosen to 

utilize NFPA 1150 as it is designed specifically for application by 

municipal fire agencies in the wild land-urban interface, utilizing 

apparatus and situations that they are likely to encounter. The 

Forest Service’s GUS for foam products is specific to use by wild 

land fire equipment and situations that are unique, e.g. helicopter 

use of foams, remote storage situations, and varied quality of 

water sources in the wild land settings. The agency feels this 

standard more accurately reflects the needs and mission of the 

federal wild land fire suppression agencies. 

C-25
Addendum to the 

Ninth Annual Report on Federal

Agency Use of Voluntary

Consensus Standards and 

Conformity Assessment
i

Table of Contents for Supplemental Appendices

Note:  Appendices A, B, and C are contained in the full report to the Office of

Management and Budget

Appendix D – Individual, Unabridged Departmental Reports........................................D­1

Department of Agriculture........................................................................................................... D­1 

Department of Commerce............................................................................................................ D­6 

Department of Defense .............................................................................................................. D­25 

Department of Energy................................................................................................................ D­45 

Department of Health and Human Services................................................................................ D­52 

Department of Homeland Security............................................................................................. D­75 

Department of Housing and Urban Development ....................................................................... D­80 

Department of the Interior.......................................................................................................... D­85 

Department of Justice .............................................................................................................. D­102 

Department of Labor ............................................................................................................... D­105 

Department of State................................................................................................................. D­110 

Department of Transportation .................................................................................................. D­113 

Department of the Treasury ..................................................................................................... D­123

Appendix E – Individual, Unabridged Commission and other Agency Reports.............E­1

Agency for International Development..........................................................................................E­1 

Environmental Protection Agency.................................................................................................E­7 

Federal Communications Commission ........................................................................................E­42 

Federal Trade Commission .........................................................................................................E­44 

National Archives and Records Administration ...........................................................................E­63 

National Science Foundation ......................................................................................................E­66

Appendix F – Federal Agency Activities Related to Use of Private Sector Standards.... F­1 

Appendix G – The Interagency Committee on Standards Policy (ICSP)....................... G­1 

Appendix H – Publications Related to the National Technology Transfer and

Advancement Act (NTTAA) and Office of Management and Budget (OMB) Circular A119 .................................................................................................................................... H­1
D­1

Appendix D – Individual, Unabridged Departmental Reports

Note:  This appendix contains the unabridged reports submitted to NIST by the Cabinet 

level Departments as they were submitted to NIST. Department of Agriculture 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The United States Department of Agriculture follows various voluntary 

consensus standards adopted by voluntary consensus standards bodies such as

the International Organization for Standardization (ISO). The benefits of 

utilizing consistent standards are significant. For example, conforming to the 

international standards adopted by ISO has allowed USDA to interface more 

readily with other industry partners within and outside of the United States. 

They agree on specifications and criteria to be applied consistently in the

classification of materials, in the manufacture and supply of products, in 

testing and analysis, with sharing data, in terminology and in the provision of 

services. In this way, the standards provide a reference framework, or a 

common technological language, between USDA and USDA stakeholders that 

facilitates trade and the transfer of technology. In utilizing these standards, 

the time and cost spent in translating and converting data are significantly

reduced. Using and conforming to standards, embracing widely accepted

methods, promotes credibility and acceptance of the USDA. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 1

1. Government Unique Standard: Name: WILDLAND FIRE FOAM Number: USDA 

Forest Service Specification 5100‐307; July, 2000 Title: International

Specification for Fire Suppressant Foam for Wild land Fires, Aircraft or 

Ground Application) (Incorporated: 2005) 

Voluntary Standard
D­2 

NFPA 1150 ‐ Standard on Fire‐Fighting Foam Chemicals for Class A Fuels in 

Rural, Suburban, and Vegetated Areas.

Rationale 

Foam fire suppressants contain foaming and wetting agents. The foaming

agents affect the accuracy of an aerial drop, how fast the water drains from 

the foam and how well the product clings to the fuel surfaces. The wetting

agents increase the ability of the drained water to penetrate fuels. Foam 

fire suppressants are supplied as wet concentrates. 

This standard was developed with international cooperation for Class A Foam

used in wildland fire suppression situations and equipment. Standard created

by the USDA Forest Service in cooperation with the Department of Interior

(DOI), the State of California, Department of Forestry and Fire Protection 

and the Canadian Interagency Forest Fire Center. 

The National Fire Protection Association (NFPA) does have a standard for

Class A Foam, (NFPA 1150 ‐ Standard on Fire‐Fighting Foam Chemicals for

Class A Fuels in Rural, Suburban, and Vegetated Areas). The Forest Service 

has not chosen to utilize NFPA 1150 as it is designed specifically for 

application by municipal fire agencies in the wildland‐urban interface, 

utilizing apparatus and situations that they are likely to encounter. The 

Forest Service’s GUS for foam products is specific to use by wildland fire 

equipment and situations that are unique, e.g. helicopter use of foams, 

remote storage situations, and varied quality of water sources in the

wildland settings. The agency feels this standard more accurately reflects

the needs and mission of the federal wildland fire suppression agencies. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 10 

Voluntary Standard Government Standard

A Guide to Writing the Security Features User's Guide 

for Trusted Systems,NCSC‐TG‐026, September 1991, 

NATIONAL COMPUTER SECURITY CENTER, Library No.

USDA/RD Standard
D­3 

5‐237,294 Version 1 

American National Standards Institute (ANSI) 

Accredited Standards Committee (ASC) X12 ‐ Approved Format Transaction Set 203 Quarterly

Status Reporting 

USDA/RD Standard

American National Standards Institute (ANSI) 

Accredited Standards Committee (ASC) X12 ‐ Approved Format Transaction Set 264 Monthly

Default Status Reporting 

USDA/RD Standard

ANSI Standard for Structured Query Language (SQL) USDA/FNS Standard

COM / DCOM Security Standards USDA/RD Standard

Guide to Understanding Trusted Facility

Management, NCSC‐TG‐O15, June 1989, National

Computer Security Center, Library No. S‐231, 429 

USDA/RD Standard

Guidelines for Writing Trusted Facility Manuals, NCSC‐TG‐016, Oct. 1992, NATIONAL COMPUTER 

SECURITY CENTER, Library No. S239,639 Version 1. 

USDA/RD Standard

ISO/BS 17799 Audit Checklist (6/08/2003), BS 

7799.2: 

USDA/RD Standard

J2EE Architectural Standards USDA/RD Standard

Unified Modeling Language (UML) Standards for 

Documentation, Version 2 

USDA/RD Standard

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 238

Other Technical Standards: 0

Rationale: N/A
D­4 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 17 

Voluntary Consensus Standards Body Acronym

American Association of Textile Chemists and

Colorists

AATCC

American National Standards Institute ANSI 

American Society for Testing and Materials ASTM

Association of Official Analytical Chemists 

International

AOACI

Codex CODEX

Industry‐wide Cooperative Meat Identification 

Standards Committee

ICMISC

International Dairy Federation IDF 

International Organization for Standardization ISO 

International Organization for

Standardization/International Electrotechnical

Commission 

ISO/IEC

International Seed Testing Association ISTA 

National Cooperation for Laboratory Accreditation NACLA

National Fire Protection Association NFPA 

National Information Standards Organization NISO 

Organization for Economic Cooperation and 

Development 

OECD 

Project Management Institute PMI 

The Open Group TOG 

United Nations Economic Commission for Europe WP 

.29/GRSP 

UNECE

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 52
D­5 

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

72 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The OMB Circular A‐119 policy is sufficient. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No additional comments. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

No additional comments

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 1
D­6 

Department of Commerce

Title: Department of Commerce (DOC) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Standards have been an integral part of the mission of the National Institute of 

Standards and Technology, U.S. Department of Commerce, since its 

establishment in 1901. NIST staff contribute to the development of voluntary 

consensus standards by providing laboratory research for technical content and 

participating in standards developing committees. This participation supports 

NIST's mission to promote U.S. innovation and industrial competitiveness. 

Reducing Standards‐Related Barriers to Trade 

Since 2003 when Secretary Evans launched the Standards Initiative, NIST has 

launched Notify U.S. (described below) as a direct reply to the need for an 

early warning system that would give the U.S private sector and other 

interested stakeholders the opportunity to learn about proposed foreign 

technical regulations that might impact their areas of export. Furthermore,

NIST has also promoted the use of U.S. technical standards in global markets 

through its Standards in Trade Program. Since 2003 NIST has held 12 SIT

workshops working with many private sector stakeholders to deliver a coherent 

and influential message about the U.S. standardization system. 

The National Center for Standards and Certification Information (NCSCI) is the 

U.S. source for standards and standards‐related information at home and

abroad. The Center provides information on U.S., foreign, regional, and

international voluntary standards, mandatory government regulations, and 

conformity assessment procedures for nonagricultural products. Resources

include an extensive collection of reference materials, including U.S. military 

and other Federal Government specifications, U.S. industry and national

standards, international standards, and selected foreign national standards. NCSCI responds to requests for specialized standards information, provides
D­7 

contact points for translations of foreign standards and regulations, and

disseminates information to U.S. industry concerning proposed foreign

regulations and general standards issues. 

In fulfillment of U.S. obligations under the World Trade Organization (WTO)

Agreement on Technical Barriers to Trade (TBT) and the North American Free

Trade Agreement (NAFTA), NCSCI serves as the U.S. national Inquiry Point and

national Notification Authority. Signatories to the WTO TBT Agreement are 

required to notify the WTO Secretariat in Geneva of proposed technical

regulations that could affect world trade and provide a 60‐day comment period

for review and comment by other WTO Members. On July 1, 2005, NCSCI 

launched a web‐based email subscription service, Notify U.S., to disseminate 

WTO summary notifications at no charge to U.S. entities (citizens, industries, organizations). Notify U.S. provides industry with an opportunity to review and 

comment on proposed foreign technical regulations that can affect their 

businesses and their access to international markets. NCSCI acquires the full

texts of the proposed technical regulations from the relevant foreign inquiry

points and distributes them via Notify U.S. to interested U.S. industries. 

Further details regarding Notify U.S. can be viewed at www.nist.gov/notifyus. 

In 2005, NCSCI staff handled over 12,250 requests for standards and technical

barriers to trade information. NCSCI developed and hosted a 5‐day workshop in 

June 2005 on operation of a WTO TBT Inquiry Point for eighteen inquiry point 

staff from the Caribbean Community (Caricom) member nations. NCSCI staff 

led planning for the annual observance of World Standards Day in October 2005 

jointly with the American National Standards Institute (ANSI). 

NCSCI is the U.S. member of the International Organization for Standardization 

(ISO) Information Network (ISONET). NCSCI networks with other national

standards organizations to exchange standards‐related information and share 

access to foreign trade‐related standards, technical regulations, and

conformity assessment procedures. 

The Standards in Trade (SIT) program is a major activity of the Global 

Standards and Information Group (GSIG) in the NIST Standards Services Division 

(SSD). The workshops are designed to provide timely information to foreign
D­8 

standards officials on U.S. practices in standards and conformity assessment. 

Participants are introduced to U.S. technology and principles in metrology, 

standards development and application, and conformity assessment systems. The workshop agenda includes briefing panels on strategies to enhance trade 

between the United States and the invited countries.

NIST works closely with the private sector including small and medium sized

companies to develop a one week program offering a comprehensive overview

of the roles of the U.S. government, private sector, and regional and 

international organizations involved in standards development and conformity

assessment practices that impact trade. SIT offers an excellent opportunity

where U.S. stakeholders, including small and medium sized enterprises, make 

professional contacts of great value when trying to get their products exported 

to countries where standards related requirements have to be met. As

mentioned about since 2003 when Secretary Evans launched the Standards

Initiative, NIST has organized 12 SIT workshops. The upcoming 2006 workshops

are: 

1. Electrical Safety for the Americas

2. Iraq Construction Sector, and

3. Building and Construction for the Middle East. 

More detailed information about the SIT program can be found at 

http://ts.nist.gov/ts/htdocs/210/gsig/sitdescr.htm. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐
D­9 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 98 

Voluntary Consensus Standards Body Acronym

Acoustical Society of America ASA

Air Conditioning & Refrigeration Institute ACRI

Alliance for Telecommunications Industry Solutions ATIS 

American Association of Physicists in Medicine AAPM

American Concrete Institute ACI 

American Dental Association ADA 

American Gas Association AGA

American Institute of Aeronautics and Astronautics AIAA 

American National Standards Institute ANSI 

American Nuclear Society ANS 

American Society for Testing and Materials ASTM

American Society of Civil Engineers ASCE

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

American Society of Quality Control ASQC

American Vacuum Society AVS 

American Welding Society AWS 

Association for Information and Image Management AIIM
D­10 

Association of Biomolecular Research Facilities ABRF 

Basic Linear Algebra Subprograms Technical Forum BLAS 

Biometrics Application Programming Interface BioAPI 

British Standards Institution BSI 

Canadian General Standards Board CGSB 

Clinical and Laboratory Standards Institute CSLI 

Codex CODEX

Committee on Data for Science and Technology CODATA 

Common Criteria Management Committee CCMC

Consumer Electronics Association CEA 

Council on Ionizing Radiation Measurements and 

Standards

CIRMS 

Council on Optical Radiation Measurements CORM

Electronic Industries Alliance EIA 

Engineering Sciences Data Unit International ESDU 

Illuminating Engineering Society of North America IES 

Industrial Truck Association ITA 

Institute for Interconnecting and Packaging

Electronic Circuits 

IPEC

Institute of Electrical and Electronic Engineers IEEE

Inter‐American Accreditation Cooperation IAAC

Inter‐American Metrology System SIM

International Association for the Properties of Water 

and Steam

IAPWS

International Atomic Energy Agency IAEA 

International Bureau of Weights and Measures BIPM

International Cartographic Association ICA 

International Civil Aviation Organization ICAO 

International Code Council ICC

International Commission for Illumination CIE

International Commission on Radiation Units and ICRU
D­11 

Measurements, Inc. 

InterNational Committee for Information Technology

Standards

INCITS 

International Committee for Weights and Measures CIPM

International Council for Science ICSU 

International Earth Rotation and Reference Systems

Service 

IERS 

International Electrotechnical Commission IEC

International Federation on Information Processing IFIP

International Hydrographic Organization IHO 

International Imaging Industry Association IIIA 

International Organization for Legal Metrology OIML 

International Organization for Standardization ISO 

International Organization for

Standardization/International Electrotechnical

Commission 

ISO/IEC

International Telecommunication Union ITU 

International Union of Laboratories and Experts in 

Materials, System and Structures/International

Council for Research and Innovation in Building and 

Construction 

RILEM/CIB 

International Union of Laboratories and Experts in 

Materials, Systems and Structures

RILEM

International Union of Pure and Applied Chemistry IUPAC

Internet Engineering Task Force IETF 

Internet Software Consortium ISC

JANNAF ‐ Interagency Propulion Committee JANNF 

Java Grande Forum JGF 

Joint Electron Device Engineering Council JEDEC

National Academy of Sciences NAS 

National Conference of Standards Laboratories NCSL

National Conference on Weights and Measures NCWM
D­12 

National Council of Radiation Protection and

Measurements

NCRPM

National Fire Protection Association NFPA 

National Fluid Power Association NFPA 

North American Open Math Initiative NAOMI

Open Applications Group OAGi

Open DeviceNet Vendor Association ODVA

Open Geospatial Consortium OGC

Open Management Group OMG 

Optical Internetworking Forum OIF 

Optical Society of America OSA 

Optical Storage Technology Association OSTA 

Optics and Electro‐Optics Standards Council OEOSC

Organization for the Advancement of Structured

Information Systems

OASIS 

Pan‐American Standards Commission COPANT 

Robotics Industry Association RIA 

Semiconductor Equipment and Materials

International

SEMI 

Simulation Interoperability Standards Organization SISO 

Society of Automotive Engineers SAE 

Society of Motion Picture and Television Engineers SMPTE

Standards Engineering Society SES 

Telecommunications Industry Association TIA 

The Instrumentation, Systems, and Automation 

Society

ISAS 

U.S. Product Data Association US PRO 

Underwriters Laboratories UL 

Versailles Project on Advanced Materials and 

Standards

VAMAS 

Video Electronics Standards Association VESA
D­13 

World Intellectual Property Organization WIPO 

World Meteorological Organization WMO 

World Wide Web Consortium W3C 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 442

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

National Voluntary Laboratory Accreditation Program (NVLAP) 

The National Voluntary Laboratory Accreditation Program (NVLAP) provides

third‐party accreditation to testing and calibration laboratories. NVLAP's 

accreditation programs are established in response to Congressional mandates

or administrative actions by the Federal Government or from requests by

private‐sector organizations. NVLAP is in full conformance with the standards

of the International Organization for Standardization (ISO) and the 

International Electrotechnical Commission (IEC), including ISO/IEC 17025 and 

Guide 58 (ISO/IEC 17011 as of January 1, 2006). NVLAP identifies its 

laboratories in its NVLAP‐Accredited Laboratories Directory which is published

online at www.nist.gov/nvlap. NVLAP is a signatory to the International

Laboratory Accreditation Cooperation (ILAC), the Asia‐Pacific Laboratory

Accreditation Cooperation (APLAC), and the National Cooperation for

Laboratory Accreditation (NACLA) Mutual Recognition Arrangements. By

participating in these Cooperations, NVLAP facilitates the mutual recognition of 

accredited test and measurement results of its signatory partners, reducing the 

need redundant testing and lower costs to customers.

National Voluntary Conformity Assessment System Evaluation (NVCASE) Program

The National Voluntary Conformity Assessment System Evaluation (NVCASE) 

Program enables U.S. industry to satisfy mandated foreign technical

requirements using the results of U.S.‐based conformity assessment programs
D­14 

that perform technical evaluations comparable in their rigor to practices in the

receiving country. Under this program, the Department of Commerce, acting 

through the National Institute of Standards and Technology, evaluates U.S.‐ 

based conformity assessment bodies in order to be able to give assurances to a 

foreign government that qualifying bodies meet that government's

requirements and can provide results that are acceptable to that government. The program provides a technically‐based U.S. approval process for U.S. 

industry to gain foreign market access; the acceptability of conformity

assessment results to the relevant foreign government will be a matter for

agreement between the two governments. Additional information about the 

NVCASE Program can be found at 

http://ts.nist.gov/ts/htdocs/210/gsig/nvcase.htm. 

Conformity Assessment Activities under Mutual Recognition 

Agreements/Arrangement (MRAs) 

The United States and the European Community Mutual Recognition Agreement

(US ‐ EU MRA) is a multi‐sector bilateral government‐to‐government agreement 

between the United States and the 25 Member States of the European Union. 

Under this MRA, NIST is responsible for designating organizations in the US 

Conformity Assessment Bodies (CABs) for three product sectors: 1) 

Electromagnetic Compatibility (EMC), 2) Telecommunications, and 3) 

Recreational Craft. After a lengthy review process, CABs that meet certain 

criteria are formally recognized and may operate as a CAB as described in the

U.S. ‐ EU MRA and the specific technical regulations of the EU governing the

appropriate product sectors. . The U.S.‐EU MRA is an important regulatory and 

trade agreement which provides greater market access in a timelier manner for 

U.S. manufacturers exporting to Europe and European manufacturers exporting 

to the United States. Further information can be obtained at 

http://ts.nist.gov/ts/htdocs/210/gsig/mra.htm. 

The Asia‐Pacific Economic Cooperation (APEC) Mutual Recognition Arrangement

for Conformity Assessment of Telecommunications Equipment is intended to 

streamline the Conformity Assessment Procedures for a wide range of 

telecommunications and telecommunications‐related equipment and hereby to 

facilitate trade among the parties. It provides for the mutual recognition by
D­15 

the importing parties of CABs and mutual acceptance of the results of testing 

and equipment certification procedures undertaken by those bodies in assessing

conformity of equipment to the importing Parties’ own Technical Regulations. 

Under Phase‐I of the APEC Mutual Recognition Arrangement, NIST‐designated

CABs are able to produce test data in their facilities that are accepted as

evidence that the tested product satisfies an APEC economy's appropriate 

technical requirements. CABs operating under Phase‐II of the MRA are able to 

approve products as being in compliance with the technical and administrative 

requirements of the importing economy. The general and specific requirements

that must be met in order to be nominated as a CAB under the APEC Tel MRA, 

as well as the text of the MRA, can be found at www.ts.nist.gov/mra. 

The Inter‐American Telecommunication Commission (CITEL) Mutual Recognition 

Agreement is almost identical to the APEC Tel MRA in purpose and structure. 

The goal of the CITEL MRA is to facilitate trade among the 34 Member States of 

the Organization of American States. The conformity assessment activities 

under this Agreement have yet to become operational. When operational, NIST 

will serve as the Designating Authority of U.S. CABs. In the meantime, NIST 

continues to work towards implementation of the Agreement. More information 

on the CITEL Agreement can be found on 

http://ts.nist.gov/ts/htdocs/210/gsig/mra.htm. 

NIST Committee Participation in Conformity Assessment Activities

NIST's Standards Services Division (NIST/SSD) participates in the American 

National Standards Institute's (ANSI) International Conformity Assessment 

Committee (ICAC). This committee serves as the U.S. Technical Advisory Group

(TAG) to ISO's Council Committee on Conformity Assessment (CASCO). SSD staff 

is also active on CASCO's ad hoc Regulators Interface group. 

NIST/SSD is a member of ANSI's Conformity Assessment Policy Committee

(CAPC), which is the primary focal point for developing, coordinating, and

maintaining ANSI's policies and accreditation activities. The committee makes

policy recommendations to the ANSI Board related to conformity assessment 

and provides oversight for ANSI's conformity assessment programs.
D­16 

NIST/SSD participates in the U.S Technical Advisory Group (TAG) to ISO 

Technical Committee 176, as well as several ISO TC 176 Working Groups. ISO TC

176 is the ISO committee responsible for the development and maintenance of 

the ISO 9000 standards series. SSD staff also chair the American Society for 

Quality (ASQ) Z‐1 Subcommittee on Quality, the U.S. committee responsible for

adoption of the ISO 9000 series and other generic quality system standards as

U.S. national standards. 

In the International Electrotechnical Commission (IEC) area, NIST/SSD 

personnel serve on the U.S. National Committee to the IECEE (IEC System for

Conformity Testing and Certification of Electrical Equipment). The latter is a 

worldwide scheme that allows manufacturers to obtain a test certificate from 

an approved U.S. National Certification Body (NCB) and to use that test report 

to obtain certification marks in other participating countries.

Additionally, NIST provides technical support to the Standards Related

Measures (SRM) Committee under the North American Free Trade Agreement

(NAFTA). The SRM Committee serves as a forum for the resolution of standards

and conformity assessment issues that impact trade among the three NAFTA 

partners. NIST also provides technical support for the Interamerican 

Accreditation Cooperation (IAAC). Such arrangements/agreements are designed

to harmonize conformity assessment practices and promote the global

acceptance of conformity assessment results from qualified bodies to minimize 

the need for and cost of redundant conformity assessments. 

NIST/SSD staff are also working with the Consumer Product Safety Commission 

(CPSC) to refine the conformity assessment portion of CPSC's China strategy (to

reduce the number of unsafe consumer products imported from China into the 

United States), as well as with the U.S. Department of Homeland Security on its

conformity assessment related efforts. 

Finally, NIST/SSD has published a number of directories and reports on 

conformity assessment‐related issues. NIST/SSD also maintains a Web site 

(http://ts.nist.gov) that provides a one‐stop‐shopping source for information 

on various conformity assessment issues.
D­17 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

None at this time. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

DOC BUREAUS (EXCLUDING NIST) ‐ SUMMARY OF STANDARDS‐RELATED 

ACTIVITIES (2005) 

International Trade Administration (ITA) – The ITA participates in seven CODEX

committees and one ICAO committee. This year, ITA’s work in standards

furthered international civil aviation and processed food safety standards

adoption and acceptance worldwide. 

National Oceanic and Atmospheric Administration (NOAA) – Standardization of 

data acquisition and data management practices are vital to the mission at

NOAA. NOAA seeks to establish voluntary standards with selected industrial

associations, academia, and national organizations of state and local

governments (e.g., the American Association of State Climatologists), as well as 

through participation in professional societies (e.g., American Meteorological

Society). All NOAA line organizations participate in standards development 

activities. In general, standards used in many NOAA activities are established in 

conjunction with other federal agencies (e.g., DOD, Federal Aviation 

Administration, U.S. Department of Agriculture, and the Federal Geographic 

Data Committee) either through joint participation in international

organizations such as the World Meteorological Organization, or by means of 

bilateral and multilateral agreements with other nations. These standardization 

activities apply to all phases of environmental data acquisition, processing, and

distribution. 

National Telecommunications and Information Administration (NTIA) – The NTIA 

contributes to the development and application of national and international

telecommunication standards by participating and holding leadership roles in 

various voluntary standards committees at the national and international levels
D­18 

(e.g., Telecommunications Industry Association, International

Telecommunication Union). These standards enhance the quality and reliability

of the domestic telecommunications infrastructure, promote healthy

competition in telecommunications products and services, and expand

international trade opportunities for U.S. telecommunications firms. 

United States Patent and Trademark Office (USPTO) ‐ The USPTO participates 

and contributes to the resolution of identified requirements for international

standards, primarily through the Standing Committee on Information 

Technologies of the World Intellectual Property Organization. USPTO staff also 

participates in standardization activities of the International Patent

Classification Union. 

Bureau of the Census – DOC’s Bureau of the Census is active in the development 

of standards and specifications for: (1) the capture and storage of geographic 

information in computer‐readable formats along with metadata documenting

the characteristics of those data; and (2) the definitions of statistical, economic, and geographic terms. The Census Bureau participates in the

following groups: Federal Geographic Data Committee ‐‐ various subcommittees

and working groups; ANSI/NCITS‐L1 Geographic Information Systems; ISO 

Technical Committee 211; Ad hoc Baseline Committee on the U.S. International

Boundary; U.S.G.S. Spatial Data Transfer Standards (SDTS) Technical Review

Board; International Cartographic Association, Commission on National and

Regional Atlases; U.S.G.S. National Atlas of the United States Steering 

Committee; and the Open GIS Consortium (OGC). 

Commercial Law Development Program (CLDP) – CLDP provides consultative and

training support to developing and transitional nations that are working to 

enhance their economic growth by improving the legal environment for doing 

business in their countries. CLDP staff provided the following standards‐related

assistance in FY2005: 

• The Coordination of SPS Procedures Workshop in Bulgaria, which brought 

together SPS representatives from all of the Stability Pact countries and 

observer UNMIK/Kosovo, to determine problems and procedural impediments to 

efficient implementation of SPS measures within the Stability Pact region. 

• The establishment of three Stability Pact wide regional working groups to
D­19 

cover the areas of food safety, animal health, and plant health with the goals

of exchanging information on legislative and regulatory requirements and 

establishing procedures for dealing with pest and disease outbreaks in the

Southeast Europe region. 

• The inaugural SPS Working Group Meetings in Chisinau, Moldova determined

procedures to bring about the timely exchange of legislative and regulatory

requirements and sector specific procedures for dealing with pest and disease 

outbreaks. Experts from USDA, the Codex Alimentarius of the United Nations

Food and Agriculture Organization (FAO/Codex), the World Organization for

Animal Health (OIE), and the International Plant Protection Convention (IPPC) 

provide ongoing advice to the working groups. • Consultations in the U.S. on American agribusiness standards, and quality

control processes surrounding agricultural products, for a mixed delegation of 

Moroccan agribusiness executives and government officials. • Consultations in the U.S. on American electric and electronic standards for a 

mixed delegation of Moroccan executives and government officials. • Program management meetings of standards focus groups in Morocco for the 

evaluation of previous consultations for auto parts, agribusiness and 

electronic/electric industries, and the planning of requested standards

consultations for the leather industry. • Leather standards consultation in the U.S. for Moroccan Ministry of 

Commerce officials and leather industry representatives on standards and

technical regulations surrounding U.S. imports of leather products. 

OTHER NIST STANDARDS ACTIVITIES 

Federal Information Processing Standards (FIPS) – FY2005 

Under the Federal Information Security Management Act (FISMA), TITLE III of 

the E‐Government Act of 2002, the Secretary of Commerce approves standards

and guidelines that are developed by NIST for federal computer systems. This

includes standards and guidelines needed to ensure the cost‐effective security

and privacy of sensitive information in federal computer systems. These 

standards and guidelines are issued by NIST as FIPS for use government wide. FIPS are issued when there are compelling federal government requirements

such as for security and interoperability and there are no acceptable industry
D­20 

standards or solutions. When FIPS are considered necessary, NIST announces

proposed FIPS in the Federal Register for public review and comment. 

During FY2005, NIST made the following FIPS announcements: 

On January 12, 2005, NIST announced in a Federal Register Notice it plans to 

develop Federal Information Processing Standard (FIPS) 140–3, which will

supersede FIPS 140–2, Security Requirements for Cryptographic Modules

On February 8, 2005, NIST announced in a Federal Register Notice that the 

Secretary of Commerce has approved the withdrawal of seventeen (17) Federal

Information Processing Standards (FIPS) Publications. These FIPS are being

withdrawn because they are obsolete, or have not been updated to adopt 

current voluntary industry standards, current federal data standards, or current 

good practices for information security. This situation preserves obsolete

standards for agency use. Some of these FIPS adopt voluntary industry

standards. Federal agencies and departments are directed by the National

Technology Transfer and Advancement Act of 1995 (Public Law104–113) to use 

technical standards that are developed in voluntary consensus standards

bodies. Consequently, FIPS that duplicate voluntary industry standards are no 

longer needed. 

Additionally, the Secretary of Commerce approved the withdrawal of FIPS 46–3, 

Data Encryption Standard (DES); FIPS 74, Guidelines for Implementing and Using

the NBS Data Encryption Standard; and FIPS 81, DES Modes of Operation. These 

FIPS are withdrawn because FIPS 46–3, DES, no longer provides the security that

is needed to protect Federal government information. FIPS 74 and 81 are 

associated standards that provide for the implementation and operation of the 

DES. Federal government organizations are now encouraged to use FIPS 197, 

Advanced Encryption Standard (AES), which was approved for Federal

government use in November 2001. 

In July of 2005, NIST proposed to withdraw ten (10) Federal Information 

Processing Standards (FIPS) from the FIPS series. The standards proposed for

withdrawal include FIPS 161‐2, FIPS 183, FIPS 184, FIPS 192 and 192‐1, which 

adopt voluntary industry standards for Federal government use. These FIPS are 

obsolete because they have not been updated to reference current or revised

voluntary industry standards. In addition, FIPS 4‐2, FIPS 5‐2, FIPS 6‐4, and FIPS
D­21 

10‐4, adopt specifications or data standards that are developed and maintained 

by other Federal government agencies or by voluntary industry standards

organizations. These FIPS have not been updated to reflect the changes and 

modifications that have been made by the organizations that develop and

maintain the specifications and data representations. FIPS 113, Computer Data 

Authentication, specifies an algorithm for generating and verifying a Message

Authentication Code (MAC). Since the algorithm is based on the Data 

Encryption Standard, which has been recommended for withdrawal, NIST plans 

to recommend the use of newer techniques for data authentication based on 

more secure algorithms. 

On April 8, 2005 The Secretary of Commerce approved the FIPS 201, Standard

for Personal Identity Verification of Federal Employees and Contractors, and

has made it compulsory and binding on Federal agencies for use in issuing a 

secure and reliable form of personal identification to employees and 

contractors. The standard does not apply to personal identification associated

with national security systems as defined by 44 U.S.C. 

The National Institute of Standards and Technology (NIST) announced the 

release of draft Federal Information Processing Standards (FIPS) Publication 

200, Minimum Security Requirements for Federal Information and Information 

Systems for public comment. Draft FIPS Publication 200 is one of a series of 

security standards and guidelines that NIST is developing to help federal

agencies implement their responsibilities under the Federal Information 

Security Management Act (FISMA). The FISMA requires that all federal agencies 

develop, document and implement agency‐wide information security programs

to protect federal information and information systems. Draft FIPS Publication 

200, which will be used with other publications already issued by NIST,

specifies minimum security requirements for federal information and 

information systems and a risk‐based process for selecting the security controls

necessary to satisfy the minimum requirements. 

Telemedicine Standards

The mission of the American Telemedicine Association (ATA) is to promote 

access to medical care by consumers and health professionals via information 

and telecommunications technology. An important element of this mission is to
D­22 

advance the use of telemedicine through the development or identification of 

technology, clinical, and administrative standards related to the ongoing

delivery of health and medical care. Telemedicine allows patients to gain 

access to healthcare professionals, electronically regardless of their location. It 

can provide faster, more affordable healthcare services, especially when

telemedicine is integrated into the entire health and medical care a patient

receives via the traditional in‐person environment. 

Working to accomplish this mission, the NIST's Information Technology 

Laboratory and ATA are working together to define a portfolio of standards and

guidelines to enable the development and advancement of the use of 

telemedicine. In particular, NIST and the ATA have conducted a series of 

workshops to identify standards needed to provide ocular care through 

telecommunications technology. In particular, this effort focused on tele‐ 

retinal imaging for the assessment of diabetic retinopathy (e.g., taking images 

of the eye and evaluating those images to diagnose and treat diabetic 

retinopathy). This is a mature areas of telemedicine for which there is strong 

need for a standards portfolio to guide administrators, clinicians, and others

involved in ocular telehealth. NIST provided leadership in defining the strategy

and subsequent process for establishing the portfolio and as well as expertise in 

defining the technical (i.e., IT related) standards for diabetic retinopathy. NIST 

led and hosted the first workshop on technical standards. 

The result of these workshops is a consensus‐based document that includes the 

identification of appropriate technical standards, clinical protocols, and 

administrative arrangements. It will be promulgated as an ATA Technical

Standard and be published in the ATA Journal. As a Technical Standard, it will

be used to advance the use of telemedicine in fields related to ophthalmology, optometry, and optical engineering. 

The next steps are to expand upon this work to help the industry (e.g., eye 

care practitioners, ophthalmologists, lab technicians, and screening and

imaging equipment vendors) use the standard and develop measurements to 

ensure correct implementation and interoperability. Additionally, the process

by which this diabetic retinopathy portfolio of standards was developed will be 

documented and used as a guide in the development of additional portfolios for
D­23 

other medical disciplines. 

Homeland Security Standards

The Chief of the Standards Services Division of NIST serves as co‐Chair on the

American National Standards Institute's Homeland Security Standards Panel

(ANSI‐HSSP). The mission of the HSSP is to identify existing consensus

standards, or, if none exist, assist the Department of Homeland Security (DHS) 

and those sectors requesting assistance to accelerate development and

adoption of consensus standards critical to homeland security. The ANSI‐HSSP 

promotes a positive, cooperative partnership between the public and private 

sectors in order to meet the needs of the nation in this critical area. 

At the Plenary Meeting of the ANSI HSSP held September 29‐30, 2005, Dr. Charles McQueary, Under Secretary, DHS Standards & Technology (S&T)

Directorate stated, “Standards are the vital underpinnings of homeland security 

efforts to develop the technologies we need to prepare for, protect against and

respond to all manner of high‐consequence events. The availability of 

standards helps us condition the marketplace for the protective technologies

we need to safeguard the nation.” 

The event brought together more than 150 professionals, experts and leaders

from the homeland security standards and conformity assessment community to

review progress that has been made and areas to be further explored. 

Michelle O'Neill, Acting Under Secretary for Technology, Department of 

Commerce further highlighted the importance of standards and work of the 

ANSI‐HSSP in addressing the needs for homeland security standards. 

"Over the past 3 years, members of the Panel and volunteer workshop

participants have identified existing standards related to homeland security 

priorities, catalogued standards projects under way or planned and determined

gaps where security standards are needed. This work has been crucial to focus

the U.S. standards system’s resources on the most pressing needs in security 

related standards." 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards:
D­24 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; E

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
D­25 

Department of Defense 

Title: Department of Defense (DoD) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Supporting the warfighter is the main mission of the Department of 

Defense(DoD).This support can range from acquiring weapons systems to 

training personnel for a multitude of functions to providing food and shelter for 

our troops in combat zones. Standards play a vital role in ensuring appropiate 

goods and services get to the warfigher in a timely,cost effective fashion.Using

standards achieves cost benefits by creating an acquisiton environment which 

allows for larger economical buys, reduces development and maintenance 

costs,and lessens the need for stockpiling large amounts of inventory. The Department has found relying on different types of acqusition documents

such as military‐unique standards and non‐government standards enhances the 

possbility for technology insertion in weapons systems,ensures a high reliability

in parts and systems,levels the manufacturer's playing field, thereby, 

increasing competition,and also reduces development costs. For many years, DoD has been focusing on replacing military unique standardization documents

in commodity areas having commercial application in an effort to promote the 

intergration of commercial and military manufacturig facilities and provide 

freedom of choice in selecting items which meet warfigher requirements.DoD's 

reliance on non‐government standards as acquisition vehicles whenever 

practical continues to be a strong and cost effective policy. The following DoD case studies illustrate how standards and standardization 

have contibuted to providing the warfighter with equipment and services in a 

timely and cost consciencous manner. 

AN/PRC‐12 Survival Radio ‐ Downed military pilots use a survival radio to signal 

their location to rescuers. The AN/PRC‐112C operates only in line‐of‐sight 

conditions and lacks geo‐positioning information thus recovering downed pilots

can be very difficult.Also,many of the parts in this piece of equipment are 

obsolete.The Army has devised a method to sustain and support the AN/PRC‐12
D­26 

Survival Radio by retrofitting existent radios with commercial circuitry and 

batteries.This initiative has designed out obsolescence, decreased power 

consumption and designed in commercial batteries,compressed development 

cycle tiem, improved reliability and reduced acquisition costs. 

Joint Precision Approach and Landing System (JPALS) ‐ In the early 1990’s, DoD 

recognized the need to develop an improved landing navigation system that 

would be rapidly deployable, operate in adverse weather and adverse terrain, 

be survivable and maintainable, and be interoperable with other military and

civilian sector systems. To solve this problem, DoD initiated a formal research 

program. JPALS is a joint military program, with the Air Force as the lead for 

developing the land‐based solutions and the Navy as the lead for a shipboard

solution. The team evaluated 27 different technology alternatives against five 

key functional objectives and four operational environments. Only one 

technology – Differential Global Positioning System (DGPS) technology – 

satisfied all objectives in all operational environments. As a result, military and

civil aviation communities will realize many benefits from the work of the 

JPALS team. The key benefits are increased safety, reduced cost, improved

operations and enhanced interoperability. 

Joint Tactical Radio System(JTRS)‐ Combat communication has been a problem 

largely because each military tactical radio had a dedicated function. 

Consequently, a warfighter needing to communicate with a dozen different

functional activities might require a dozen different radios. Legacy radios are 

hardware based, and most use proprietary designs and components. Logistics

support is complex, and upgrades to add new capabilities or to overcome 

technical limitations are costly, significantly increasing system life‐cycle costs. The JTRS Team decided that the key to the solution was a software defined

radio that relies on state‐of‐the‐art object‐oriented technology and used a 

standard open architecture. As a result, DoD now has a common tactical radio 

system that dramatically increases the capability of the warfighters to 

communicate with one another – independent of echelon, locations, or 

situations – greatly improving the probability of victory and most certainly

saving many lives. 

Acoustic—Rapid Commercial Off‐the‐Shelf Insertion (A‐RCI)‐ The use of modern
D­27 

Commercial Off‐the‐Shelf (COTS) processors and commercial software 

languages in A‐RCI opens the door to easier future upgrades of sonar systems. Because A‐RCI is designed to use commercial open standards, the Navy can 

select from a number of available components. The software design also makes

upgrading easier by its use of middleware to handle hardware specific aspects

of design instead of hardware‐specific application code. This approach 

eliminates the traditional problem of block obsolescence and the need to buy

large quantities of expensive spares to support a long equipment lifetime. The 

Navy will benefit from A‐RCI in five key ways: improved sonar performance, 

increased number of modernized submarines, increased commonality across

sonar systems, faster introduction of improvements, lower development, 

acquisition, and support costs. 

All of DoD's case studies can be located on the Defense Standardization 

Program Office website ‐ 

http://dsp.dla.mil/case‐abstracts.htm. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 

This agency reports voluntary consensus standards usage on a category basis

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 227 

Voluntary Standard Government Standard

PIA‐PS70098 MS70098

SAE‐ AS5809 MIL‐C‐5809 

SAE‐25427 MIL‐C‐25427

SAE‐AMS‐T‐9047 MIL‐T‐9047 

SAE‐AMS5617 MIL‐S‐83311 

SAE‐AS15002 MS15002

SAE‐AS15004 MS15004

SAE‐AS15005 MS15005
D­28 

SAE‐AS15006 MS15006

SAE‐AS15720 MS15720

SAE‐AS21984 MS21984

SAE‐AS22073 MS22073

SAE‐AS22074 MS22074

SAE‐AS22759 (documents 1 ‐ 92) MIL‐W‐22759 (documents 1‐92) 

SAE‐AS22759(1) MIL‐W‐22759(1) 

SAE‐AS22759(10) MIL‐W‐22759(10) 

SAE‐AS22759(11) MIL‐W‐22759(11) 

SAE‐AS22759(12) MIL‐W‐22759(12) 

SAE‐AS22759(13) MIL‐W‐22759(13) 

SAE‐AS22759(14) MIL‐W‐22759(14) 

SAE‐AS22759(15) MIL‐W‐22759(15) 

SAE‐AS22759(16) MIL‐W‐22759(16) 

SAE‐AS22759(17) MIL‐W‐22759(17) 

SAE‐AS22759(18) MIL‐W‐22759(18) 

SAE‐AS22759(19) MIL‐W‐22759(19) 

SAE‐AS22759(2) MIL‐W‐22759(2) 

SAE‐AS22759(20) MIL‐W‐22759(20) 

SAE‐AS22759(21) MIL‐W‐22759(21) 

SAE‐AS22759(22) MIL‐W‐22759(22) 

SAE‐AS22759(23) MIL‐W‐22759(23) 

SAE‐AS22759(24) MIL‐W‐22759(24) 

SAE‐AS22759(25) MIL‐W‐22759(25) 

SAE‐AS22759(26) MIL‐W‐22759(26) 

SAE‐AS22759(27) MIL‐W‐22759(27) 

SAE‐AS22759(28) MIL‐W‐22759(28) 

SAE‐AS22759(29) MIL‐W‐22759(29) 

SAE‐AS22759(3) MIL‐W‐22759(3) 

SAE‐AS22759(30) MIL‐W‐22759(30)
D­29 

SAE‐AS22759(31) MIL‐W‐22759(31) 

SAE‐AS22759(32) MIL‐W‐22759(32) 

SAE‐AS22759(33) MIL‐W‐22759(33) 

SAE‐AS22759(34) MIL‐W‐22759(34) 

SAE‐AS22759(35) MIL‐W‐22759(35) 

SAE‐AS22759(36) MIL‐W‐22759(36) 

SAE‐AS22759(37) MIL‐W‐22759(37) 

SAE‐AS22759(38) MIL‐W‐22759(38) 

SAE‐AS22759(39) MIL‐W‐22759(39) 

SAE‐AS22759(4) MIL‐W‐22759(4) 

SAE‐AS22759(40) MIL‐W‐22759(40) 

SAE‐AS22759(41) MIL‐W‐22759(41) 

SAE‐AS22759(42) MIL‐W‐22759(42) 

SAE‐AS22759(43) MIL‐W‐22759(43) 

SAE‐AS22759(44) MIL‐W‐22759(44) 

SAE‐AS22759(45) MIL‐W‐22759(45) 

SAE‐AS22759(46) MIL‐W‐22759(46) 

SAE‐AS22759(47) MIL‐W‐22759(47) 

SAE‐AS22759(48) MIL‐W‐22759(48) 

SAE‐AS22759(49) MIL‐W‐22759(49) 

SAE‐AS22759(5) MIL‐W‐22759(5) 

SAE‐AS22759(50) MIL‐W‐22759(50) 

SAE‐AS22759(51) MIL‐W‐22759(51) 

SAE‐AS22759(52) MIL‐W‐22759(52) 

SAE‐AS22759(53) MIL‐W‐22759(53) 

SAE‐AS22759(54) MIL‐W‐22759(54) 

SAE‐AS22759(55) MIL‐W‐22759(55) 

SAE‐AS22759(56) MIL‐W‐22759(56) 

SAE‐AS22759(57) MIL‐W‐22759(57) 

SAE‐AS22759(58) MIL‐W‐22759(58)
D­30 

SAE‐AS22759(59) MIL‐W‐22759(59) 

SAE‐AS22759(6) MIL‐W‐22759(6) 

SAE‐AS22759(60) MIL‐W‐22759(60) 

SAE‐AS22759(61) MIL‐W‐22759(61) 

SAE‐AS22759(62) MIL‐W‐22759(62) 

SAE‐AS22759(63) MIL‐W‐22759(63) 

SAE‐AS22759(64) MIL‐W‐22759(64) 

SAE‐AS22759(65) MIL‐W‐22759(65) 

SAE‐AS22759(66) MIL‐W‐22759(66) 

SAE‐AS22759(67) MIL‐W‐22759(67) 

SAE‐AS22759(68) MIL‐W‐22759(68) 

SAE‐AS22759(69) MIL‐W‐22759(69) 

SAE‐AS22759(7) MIL‐W‐22759(7) 

SAE‐AS22759(70) MIL‐W‐22759(70) 

SAE‐AS22759(71) MIL‐W‐22759(71) 

SAE‐AS22759(72) MIL‐W‐22759(72) 

SAE‐AS22759(73) MIL‐W‐22759(73) 

SAE‐AS22759(74) MIL‐W‐22759(74) 

SAE‐AS22759(75) MIL‐W‐22759(75) 

SAE‐AS22759(76) MIL‐W‐22759(76) 

SAE‐AS22759(77) MIL‐W‐22759(77) 

SAE‐AS22759(78) MIL‐W‐22759(78) 

SAE‐AS22759(79) MIL‐W‐22759(79) 

SAE‐AS22759(8) MIL‐W‐22759(8) 

SAE‐AS22759(80) MIL‐W‐22759(80) 

SAE‐AS22759(81) MIL‐W‐22759(81) 

SAE‐AS22759(82) MIL‐W‐22759(82) 

SAE‐AS22759(83) MIL‐W‐22759(83) 

SAE‐AS22759(84) MIL‐W‐22759(84) 

SAE‐AS22759(85) MIL‐W‐22759(85)
D­31 

SAE‐AS22759(86) MIL‐W‐22759(86) 

SAE‐AS22759(87) MIL‐W‐22759(87) 

SAE‐AS22759(88) MIL‐W‐22759(88) 

SAE‐AS22759(89) MIL‐W‐22759(89) 

SAE‐AS22759(9) MIL‐W‐22759(9) 

SAE‐AS22759(90) MIL‐W‐22759(90) 

SAE‐AS22759(91) MIL‐W‐22759(91) 

SAE‐AS22759(92) MIL‐W‐22759(92) 

SAE‐AS24333 MS24333

SAE‐AS24334 MS24334

SAE‐AS24335 MS24335

SAE‐AS25244 MS25244

SAE‐AS25337 MS25337

SAE‐AS25361 MS25361

SAE‐AS26574 MS26574

SAE‐AS39029(1) MIL‐C‐39029(1) 

SAE‐AS39029(10) MIL‐C‐39029(10) 

SAE‐AS39029(100) MIL‐C‐39029(100) 

SAE‐AS39029(101) MIL‐C‐39029(101) 

SAE‐AS39029(102) MIL‐C‐39029(102) 

SAE‐AS39029(103) MIL‐C‐39029(103) 

SAE‐AS39029(104) MIL‐C‐39029(104) 

SAE‐AS39029(105) MIL‐C‐39029(105) 

SAE‐AS39029(106) MIL‐C‐39029(106) 

SAE‐AS39029(107) MIL‐C‐39029(107) 

SAE‐AS39029(108) MIL‐C‐39029(108) 

SAE‐AS39029(109) MIL‐C‐39029(109) 

SAE‐AS39029(11) MIL‐C‐39029(11) 

SAE‐AS39029(12) MIL‐C‐39029(12) 

SAE‐AS39029(13) MIL‐C‐39029(13)
D­32 

SAE‐AS39029(14) MIL‐C‐39029(14) 

SAE‐AS39029(15) MIL‐C‐39029(15) 

SAE‐AS39029(16) MIL‐C‐39029(16) 

SAE‐AS39029(17) MIL‐C‐39029(17) 

SAE‐AS39029(18) MIL‐C‐39029(18) 

SAE‐AS39029(19) MIL‐C‐39029(19) 

SAE‐AS39029(2) MIL‐C‐39029(2) 

SAE‐AS39029(20) MIL‐C‐39029(20) 

SAE‐AS39029(21) MIL‐C‐39029(21) 

SAE‐AS39029(22) MIL‐C‐39029(22) 

SAE‐AS39029(23) MIL‐C‐39029(23) 

SAE‐AS39029(24) MIL‐C‐39029(24) 

SAE‐AS39029(25) MIL‐C‐39029(25) 

SAE‐AS39029(26) MIL‐C‐39029(26) 

SAE‐AS39029(27) MIL‐C‐39029(27) 

SAE‐AS39029(28) MIL‐C‐39029(28) 

SAE‐AS39029(29) MIL‐C‐39029(29) 

SAE‐AS39029(3) MIL‐C‐39029(3) 

SAE‐AS39029(30) MIL‐C‐39029(30) 

SAE‐AS39029(31) MIL‐C‐39029(31) 

SAE‐AS39029(32) MIL‐C‐39029(32) 

SAE‐AS39029(33) MIL‐C‐39029(33) 

SAE‐AS39029(34) MIL‐C‐39029(34) 

SAE‐AS39029(35) MIL‐C‐39029(35) 

SAE‐AS39029(36) MIL‐C‐39029(36) 

SAE‐AS39029(37) MIL‐C‐39029(37) 

SAE‐AS39029(38) MIL‐C‐39029(38) 

SAE‐AS39029(39) MIL‐C‐39029(39) 

SAE‐AS39029(4) MIL‐C‐39029(4) 

SAE‐AS39029(40) MIL‐C‐39029(40)
D­33 

SAE‐AS39029(41) MIL‐C‐39029(41) 

SAE‐AS39029(42) MIL‐C‐39029(42) 

SAE‐AS39029(43) MIL‐C‐39029(43) 

SAE‐AS39029(44) MIL‐C‐39029(4) 

SAE‐AS39029(45) MIL‐C‐39029(45) 

SAE‐AS39029(46) MIL‐C‐39029(46) 

SAE‐AS39029(47) MIL‐C‐39029(47) 

SAE‐AS39029(48) MIL‐C‐39029(48) 

SAE‐AS39029(49) MIL‐C‐39029(49) 

SAE‐AS39029(5) MIL‐C‐39029(5) 

SAE‐AS39029(50) MIL‐C‐39029(50) 

SAE‐AS39029(51) MIL‐C‐39029(51) 

SAE‐AS39029(52) MIL‐C‐39029(52) 

SAE‐AS39029(53) MIL‐C‐39029(53) 

SAE‐AS39029(54) MIL‐C‐39029(54) 

SAE‐AS39029(55) MIL‐C‐39029(55) 

SAE‐AS39029(56) MIL‐C‐39029(56) 

SAE‐AS39029(57) MIL‐C‐39029(57) 

SAE‐AS39029(58) MIL‐C‐39029(58) 

SAE‐AS39029(59) MIL‐C‐39029(59) 

SAE‐AS39029(6) MIL‐C‐39029(6) 

SAE‐AS39029(60) MIL‐C‐39029(60) 

SAE‐AS39029(61) MIL‐C‐39029(61) 

SAE‐AS39029(62) MIL‐C‐39029(62) 

SAE‐AS39029(63) MIL‐C‐39029(63) 

SAE‐AS39029(64) MIL‐C‐39029(64) 

SAE‐AS39029(65) MIL‐C‐39029(65) 

SAE‐AS39029(66) MIL‐C‐39029(66) 

SAE‐AS39029(67) MIL‐C‐39029(67) 

SAE‐AS39029(68) MIL‐C‐39029(68)
D­34 

SAE‐AS39029(69) MIL‐C‐39029(69) 

SAE‐AS39029(7) MIL‐C‐39029(7) 

SAE‐AS39029(70) MIL‐C‐39029(70) 

SAE‐AS39029(71) MIL‐C‐39029(71) 

SAE‐AS39029(72) MIL‐C‐39029(72) 

SAE‐AS39029(73) MIL‐C‐39029(73) 

SAE‐AS39029(74) MIL‐C‐39029(64) 

SAE‐AS39029(75) MIL‐C‐39029(75) 

SAE‐AS39029(76) MIL‐C‐39029(76) 

SAE‐AS39029(77) MIL‐W‐22759(77) 

SAE‐AS39029(78) MIL‐C‐39029(78) 

SAE‐AS39029(79) MIL‐C‐39029(79) 

SAE‐AS39029(8) MIL‐C‐39029(8) 

SAE‐AS39029(80) MIL‐C‐39029(80) 

SAE‐AS39029(81) MIL‐C‐39029(81) 

SAE‐AS39029(82) MIL‐C‐39029(82) 

SAE‐AS39029(83) MIL‐C‐39029(83) 

SAE‐AS39029(84) MIL‐C‐39029(84) 

SAE‐AS39029(85) MIL‐C‐39029(85) 

SAE‐AS39029(86) MIL‐C‐39029(86) 

SAE‐AS39029(87) MIL‐C‐39029(87) 

SAE‐AS39029(88) MIL‐C‐39029(88) 

SAE‐AS39029(89) MIL‐C‐39029(89) 

SAE‐AS39029(9) MIL‐C‐39029(9) 

SAE‐AS39029(90) MIL‐C‐39029(90) 

SAE‐AS39029(91) MIL‐C‐39029(91) 

SAE‐AS39029(92) MIL‐C‐39029(92) 

SAE‐AS39029(93) MIL‐C‐39029(93) 

SAE‐AS39029(94) MIL‐C‐39029(94) 

SAE‐AS39029(95) MIL‐C‐39029(95)
D­35 

SAE‐AS39029(96) MIL‐C‐39029(96) 

SAE‐AS39029(97) MIL‐C‐39029(97) 

SAE‐AS39029(98) MIL‐C‐39029(98) 

SAE‐AS39029(99) MIL‐C‐39029(99) 

SAE‐AS39029(documents 1 ‐109) MIL‐C‐39029(documents 1‐109) 

SAE‐AS7195 MIL‐H‐7195

SAE‐AS7365 MIL‐H‐7365

SAE‐AS8102 MIL‐C‐8102 

SAE‐J2360 MIL‐PRF‐2105E 

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 9083

Other Technical Standards: 248

Rationale: The Department relies on all categories of non‐government

standards to meet mission essential requirements. Specifically, due to the 

prevalence of consortium standards in the information arena, the Defense 

Informatio Systems Agency relies on this type document to meet requirements. The number of Other Technical Standards used during FY2005 is an 

approximation. The Department does not officially collect this information.

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 118 

Voluntary Consensus Standards Body Acronym

Aerospace Industries Association of America AIA 

Air Conditioning & Refrigeration Institute ACRI

Air Movement and Control Association AMCA
D­36 

Alliance for Telecommunications Industry Solutions ATIS 

Aluminum Association AA 

American Architectural Manufacturers Association AAMA 

American Association of State Highway and Transportation Officials AASHTO 

American Association of Textile Chemists and Colorists AATCC

American Bearing Manufacturers Association ABMA 

American Boat and Yacht Council ABYC

American Concrete Institute ACI 

American Conference of Governmental Industrial Hygienists ACGIH 

American Dental Association ADA 

American Gas Association AGA

American Gear Manufacturers Association AGMA 

American Hardboard Association AHA

American Industrial Hygiene Association AIHA 

American Institute of Aeronautics and Astronautics AIAA 

American Institute of Steel Construction AISC

American Institute of Timber Construction AITC

American National Metric Council ANMC

American National Standards Institute ANSI 

American Petroleum Institute API

American Railway Engineering & Maintenance‐of‐Way Association AREMA 

American Society for Nondestructive Testing ASNT 

American Society for Testing and Materials ASTM

American Society of Cinematographers ASC 

American Society of Civil Engineers ASCE

American Society of Heating, Refrigerating, and Air‐Conditioning 

Engineers 

ASHRAE

American Society of Mechanical Engineers ASME

American Society of Quality Control ASQC

American Society of Sanitary Engineering ASSE

American Water Works Association AWWA
D­37 

American Welding Society AWS 

American Wood Preservers Association AWPA 

APA The Engineering Wood Association APA 

Association for Automatic Indentification & Mobility AIM

Association for the Advancement of Medical Instrumentation AAMI

British Standards Institute BSI 

Builders Hardware Manufacturers Association BHMA 

Building Officials and Code Administrators International BOCA 

Canadian General Standards Board CGSB 

Cast Iron Soil Pipe Institute CISPI 

Compressed Gas Association CGA 

Construction Specifications Institute CSI 

Cooling Technology Institute CTI

Cordage Institute CI 

Data Interchange Standards Association, Inc. DISAI 

Deep Foundations Institute DFI 

Deutsches Institut fur Nomung ‐ German Institute for Standardization DIN

Electronic Commerce Code Management Association ECCMA 

Electronic Components Assemblies & Materials Association ECAMA 

Electronic Industries Alliance EIA 

Electrostatic Discharge Association EDA

FM Global FMG 

Government Electronics & Information Technology Association GEITA 

Graphic Communications Association GCA 

Gypsum Association GYP

Hardwood Plywood & Veneer Association HPVA 

High Frequency Industry Association HFIA 

Human Factors and Ergonomics Society, Inc. HFESI 

Illuminating Engineering Society of North America IES 

Information Technology Industry Council ITI
D­38 

Institute for Interconnecting and Packaging Electronic Circuits IPEC

Institute of Clean Air Companies ICAC

Institute of Electrical and Electronic Engineers IEEE

Institute of Environmental Sciences & Technology IEST 

Insulated Cable Engineers Association ICEA 

International Association of Plumbing and Mechanical Officials IAPMO 

InterNational Committee for Information Technology Standards INCITS 

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

International Telecommunication Union ITU 

Internet Engineering Task Force IETF 

Joint Electron Device Engineering Council JEDEC

Machinery Informaiton Management Open Systems MIMOSA 

Magnetic Materials Producers Association MMPA 

Manufacturers Standardization Society of the Valve and Fittings 

Industry

MSSVFI 

Master Painters Institute MPI 

National Association of Corrosion Engineers International NACE

National Association of Relay Manufacturers NARM

National Conference of Standards Laboratories NCSL

National Electrical Manufacturers Association NEMA 

National Fire Protection Association NFPA 

National Fluid Power Association NFPA 

National Information Standards Organization NISO 

National Institute of Building Sciences NIBS 

National Petroleum Management Association NPMA 

NSF International NSF 

Optics and Electro‐Optics Standards Council OEO 

Parachute Industry Association PIA 

Pipe Fabrication Institiute PFI 

Plastic Pipe Institute PPI
D­39 

Plumbing and Draining Institute PDI 

Plumbing‐Heating‐Cooling Contractors Association PHCCA 

Quarter‐Inch Cartridge Drive Standards, Inc. QCDS

Rack Manufacturers Institute RMI 

Resistance Welders Manufacturers Association RWMA 

Rubber Manufacturers Association RMA 

Scientific Apparatus Makers Association SAMA 

Sheet Metal & Air Conditioning Contractors National Association SHACCNA 

Simulation Interoperability Standards Organization SISO 

Society for Protective Coatings SPC

Society of Allied Weight Engineers SAWE

Society of Automotive Engineers SAE 

Standards Engineering Society SES 

Steel Door Institute SDI 

Steel Founders Society of America SFSA 

Telecommunications Industry Association TIA 

The Instrumentation, Systems, and Automation Society ISAS 

The Open Group TOG 

The Soap and Detergent Association SDA 

The Tire and Rim Association, Inc. TRAI 

Truck Trailer Manufacturers Association TTMA 

UN Centre for Trade Facilitation & Electronic Business UCTFEB 

Underwriters Laboratories UL 

Window and Door Manufacturers Association WDMA 

World Wide Web Consortium W3C 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 1106
D­40 

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

The Department does not collect this information. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The exisiting OMB policy concerning participation in voluntary consenus

standards activities is perhaps a tool that many agencies need to employ to 

support voluntary standards programs. Since Department employees 

participated in the development of voluntary consensus standards prior to

development of Circular A‐119 it is questionable whether the policy has had 

any major impact on increasing support for the voluntary consensus standard

initiative. 

The Dapartment questions the accuracy of the data collected related to 

participant information. Therefore, it is very possible the figures regarding the 

number of employees participating in voluntary consenus standards activies is

highly distorted and presents a false impression to Congress. Furthermore, the 

participant data is particularly difficult to collect and the return on investment

is questionable. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

The Department suggests the ICSP A‐119 subcommittee review the mission,

objectives, goals of the report and ascertain information that would provide 

Congress with a clear understanding of the government's role in voluntary 

consensus standards activities.

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

The information provided by the voluntary consensus standards bodies

regarding participant activities is highly suspect. After reviewing the collected 

information it was discovered the listings included the names of participants
D­41 

who had retired from government service and no longer lived in the area, 

therefore, it would be assumed they could not be involved in extensive 

committee work. 

Also, it is suggested that the database provide a means of printing the input

prior to submittal. 

10‐1. Removed [This question was deprecated in 2005]

10‐2. Removed [This question was deprecated in 2005]

10‐3. Removed [This question was deprecated in 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­42 

Department of Education 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The National Center for Education Statistics (NCES), the principal statistical

agency within the U.S. Department of Education uses standards to provide high 

quality, reliable, useful, and informative statistical information to public policy

decision makers and to the general public. In particular, the standards that 

NCES follows are intended for use by NCES staff and contractors to guide them

in their data collection, analysis, and dissemination activities. These standards

are also intended to present a clear statement for data users regarding how 

data should be collected in NCES surveys, and the limits of acceptable 

applications and use. Beyond these immediate uses, NCES hope that other 

organizations involved in similar public endeavors will find the contents of 

some of NCES standards useful in their work. (Source: NCES Statistical Support 

Standards: NCES 2003‐601) 

The Department of Education also uses standards in the implementation of 

Information Technology for the Department which ultimately enhances the 

delivery of Department Education services to citizens. The Department of 

Education uses Information Technology Standards to implement common 

enabling services and infrastructure services. These Information Technology 

standards used in the Department of Education’s Enterprise Architecture also 

fulfill OMB’s requirement for a Standards Profile. (Source: Department of 

Education Enterprise Standards and Guidelines Technology Standards Profile, 

Volume I: Enterprise Standards Profile Version 1.0) 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0
D­43 

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐ 

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 60

Other Technical Standards: 0

Rationale: Not Applicable. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 5 

Voluntary Consensus Standards Body Acronym

National Forum on Education Statistics NCES Forum 

Post Secondary Electronic Standards Organization PESC

School Interoperability Framework Association SIFA 

Semantic Interoperability Community of Practice SICOP

XML Community of Practice xmlCOP

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 4

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

None 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

No Comments.
D­44 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No Comments. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 1
D­45 

Department of Energy 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

DOE uses VCSs extensively in managing, operating, and regulating our 

diverse sites, laboratories, operations, facilities, and activities – over a range 

that includes nuclear weapons and materials production, energy research, 

energy efficiency, oil storage, hydroelectric power, accelerator operations, nuclear facility decommissioning, and fusion experiments. VCSs are consulted, 

referenced and applied in mission‐related design, procurement, construction,

operations, maintenance, emergency operations, and decommissioning efforts; 

in environment, safety and health management; in DOE research and 

development activities; in security and safeguards programs; and in overall

business operations and management. 

Other areas where DOE and its contractors use VCSs at DOE facilities and 

activities that may not be fully documented and reported include: 

1) writing procedures; 

2) establishing safety criteria (e.g., for worker job task analyses, fire 

protection, nuclear criticality safety, nuclear facility safety); and 

3) citing supporting references in internal DOE Technical Standards. 

Examples/Case Studies: 

1. The Department of Energy (DOE) has historically used voluntary consensus 

standards (VCS) promulgated by the National Fire Protection Association (NFPA) 

in the development and implementation of fire safety and emergency response 

programs at its sites. DOE and its predecessor agencies (AEC, ERDA) have done 

so for a number of reasons. NFPA is universally recognized for the diverse 

expertise of the members of its technical committees. (DOE and its contractor

employees are widely represented within these committees.) The scope of fire 

safety issues with the Department is vast. Attempting to address these issues
D­46 

solely with internal directives would be cost prohibitive. NFPA codes and

standards, through the “Equivalency” principle, allows for the flexible and

cost‐effective implementation of requirements. DOE has saved literally

hundreds of thousands of dollars in the inspection and testing of fire protection 

systems through the adaptation of this principle, as delineated in NFPA 

Standards 25 (superscript 1) and 72 (superscript 2), to site circumstances. 

1 Inspection, Testing and Maintenance of Water‐Based Fire Protection Systems

2 National Fire Alarm Code 

___________________________

2. This is not a specific case, however it is important to mention that because 

of DOE's use of VCSs, local contractors performing work for the Department's

National Labs have been more successful when bidding for jobs than if DOE 

used only internally generated standards. We feel that VCSs are responsible 

because they provide more universally accepted approaches to getting work 

completed. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 1430

Other Technical Standards: 0
D­47 

Rationale: This reflects an increase of 105 additional standards being used this

year (2005). 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 70 

Voluntary Consensus Standards Body Acronym

Air Movement and Control Association International,

Inc. 

AMCA 

Air‐Conditioning & Refrigeration Institute ARI 

American Architectural Manufacturers Association AAMA 

American Association of State Highway and 

Transportation Officials

AASHTO 

American Concrete Institute ACI 

American Industrial Hygiene Association AIHA 

American Institute of Steel Construction AISC

American Iron and Steel Institute AISI 

American Medical Association AMA 

American National Standards Institute ANSI 

American Nuclear Society ANS 

American Petroleum Institute API

American Public Health Association APHA 

American Railway Engineering & Maintenance‐of‐

Way Association 

AREMA 

American Society for Nondestructive Testing ASNT 

American Society for Quality ASQ

American Society for Testing and Materials ASTM

American Society of Civil Engineers ASCE

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

American Water Works Association AWWA
D­48 

American Welding Society AWS 

Association for Information and Image Management AIIM

Association for the Advancement of Cost Engineering AACE Int. 

Building Officials and Code Administrators

International, Inc.

BOCA 

Ceilings and Interior Systems Construction 

Association 

CISCA 

Compressed Gas Association CGA 

Construction Safety Association of Ontario CSAO 

Cooling Tower Institute CTI

Crane Manufacturing Association of America CMAA 

Electronic Industries Alliance EIA 

Institute of Electrical and Electronic Engineers IEEE

Institute of Makers of Explosives IME

Institute of Transportation Engineers ITE

Instrumentation, Systems, and Automation Society ISA 

Insulated Steel Door Systems Institute ISDSI 

International Air Transport Association IATA 

International Association of Plumbing and Mechanical 

Officials

IAPMO 

International Atomic Energy Agency IAEA 

International Civil Aviation Organization ICAO 

International Commission on Radiation Protection ICRP

International Commission on Radiation Units and

Measurements, Inc. 

ICRU

International Conference of Building Officials ICBO 

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

Metal Lath/Steel Framing Association, A Division of 

NAAMM

MLSFA 

National Association of Architectural Metal NAAMM
D­49 

Manufacturers 

National Conference of Standards Laboratories NCSL

National Council on Radiation Protection and

Measurements

NCRP

National Electrical Manufacturers Association NEMA 

National Electrical Safety Code NESC

National Fire Protection Association NFPA 

National Information Standards Organization NISO 

National Safety Council NSC

National Window and Door Association NWDA 

Post‐Tensioning Institute PTI

Precast/Prestressed Concrete Institute PCI 

Resilient Floor Covering Institute RFCI 

Scaffolding, Shoring, and Forming Institute, Inc. SSFI 

Screen Manufacturers Association SMA 

Sheet Metal and Air Conditioning Contractors' National Association SMACNA 

Single Ply Roofing Institute SPRI 

Society of Automotive Engineers SAE 

Society of Fire Protection Engineers SFPE

Southern Building Code Congress International, Inc. SBCCI 

Steel Door Institute SDI 

Steel Joist Institute SJI 

Steel Window Institute SWI 

Underwriters Laboratories UL 

Water Environment Federation WEF 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 761
D­50 

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

This number is unchanged from previous years. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

OMB A‐119 continues to be adequate. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

Because of declining budgets, it has become increasingly difficult to fund VCS 

participation by DOE and contractor personnel. As a result, it becomes less

likely that the Department's needs are adequately addressed during VCS 

development/revision, particularly those that relate to important international

standards. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10.7 continued. Periodically as needed but no less than every 5 years.

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; B
D­51 

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­52 

Department of Health and Human Services

Title: Department of Health and Human Services (HHS) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

As noted below, the individual agencies of DHHS believe the use of non‐ 

government standards, both voluntary consensus standards and non‐consensus

but non‐government unique standards, are integral to the success of their 

missions. 

Food and Drug Administration 

The central purpose for FDA involvement in the development and use of 

standards is to assist the agency in fulfilling its domestic public health and

regulatory missions. The agency participates widely in the development of 

standards, both domestic and international, and adopts or uses standards when

this action enhances its ability to protect consumers and increases the 

effectiveness or efficiency of its regulatory efforts. Further, using standards, especially international ones, is a means to facilitate the harmonization of FDA

regulatory requirements with those of foreign governments, and thus to

improve domestic and global public health protection. Therefore, FDA 

encourages participation in the development of standards as a useful adjunct 

to regulatory controls. 

FDA has been involved in standards activities for more than twenty years. In 

January 1977 the agency promulgated a final regulation now found at 21 CFR 

10.95 covering participation by FDA employees in standards development 

activities outside the agency. This regulation encourages FDA participation in 

standards activities that are in the public interest, and specifies the 

circumstances under which FDA employees can participate in various types of 

standards bodies. The agency built upon that rule with a final policy statement

published in the Federal Register on October 11, 1995, entitled International

Harmonization; Policy on Standards. It provides the agency's overall policy on
D­53 

development and use of standards for all product areas regulated by the 

agency. 

For FDA, voluntary consensus standards are most relevant for medical devices, where they are used extensively in the agency's regulatory work and where the 

majority of the agency's standards activities are centered. In the areas of 

human and veterinary pharmaceuticals, biological products and foods, 

voluntary consensus are generally not available nor being developed. Here FDA 

works within other national and international organizations such as the World

Health Organization (WHO), the Food and Agriculture Organization (FAO), the 

Organization for Economic Cooperation and Development (OECD), the United

States Pharmacopeia, and the International Conference on Harmonization of 

Technical Requirements for Registration of Pharmaceuticals for Human Use 

(ICH) to develop appropriate standards. 

FDA/CDRH Success Story

The FDA Center for Devices and Radiological Health (CDRH) is the world leader 

in the development of standards for safety of implants in the MR environment. 

Since it was convened in May, 1998, ASTM Committee F04, Medical and Surgical

Devices and Materials, Subcommittee 15, Test Methods, has hosted a Task 

Force 11 (ASTM F04.15.11) on Magnetic Resonance (MR) compatibility of 

implant materials and medical devices in the MR environment. Led by Dr. Terry

Woods, FDA/CDRH, this Task Force has written and published 5 standards

addressing the safety of implants in the MR environment. The four standard

test methods address the 4 principal issues that can affect the safety of a 

medical device in the MR environment. They are: ASTM F2052‐02 Standard Test 

Method for Measurement of Magnetically Induced Displacement Force on 

Medical Devices in the Magnetic Resonance Environment, ASTM F2119‐01 

Standard Test Method for Evaluation of MR Image Artifacts from Passive 

Implants, ASTM F2182‐02a Standard Test Method for Measurement of 

Measurement of Radio Frequency Induced Heating Near Passive Implants During

Magnetic Resonance Imaging, and ASTM F2213‐04 Standard Test Method for

Measurement of Magnetically Induced Torque on Medical Devices in the

Magnetic Resonance Environment. The fifth standard, ASTM Standard Practice 

for Marking Medical Devices and Other Items for Safety in the Magnetic 

Resonance Environment (ASTM F2503‐05), was published in August, 2005. The
D­54 

symbols and the associated MR safety terminology defined in the standard

practice have been urgently needed by the MR community. Within two days of 

being notified that ASTM F2503 had been published, Dr. Woods was contacted

by members of the MR community congratulating her on the publication and 

thanking her for leading this vital effort. This group included Johnson &

Johnson, Medtronic, Guidant, the University of Southern California, the 

Institute for Magnetic Resonance Safety, Education, and Research, Brigham &

Women's Hospital, the Mayo Clinic, the University of Pittsburgh Medical Center, 

ECRI, the UK’s Medicines and Healthcare products Regulatory Agency, and the 

major consultants in the area of MR safety. The ASTM MR standards are the first 

and only published standards that define general test methods to address

safety and compatibility of medical devices in the MR environment. They

provide invaluable assistance to device manufacturers and to FDA reviewers in 

the determination of device safety in the MR environment. 

FDA/CBER Success Story

Standards developed by FDA Center for Biologics Evaluation and Research 

(CBER) or through interactions with various standard development bodies, 

including voluntary consensus standard organizations and or industry consortia 

can provide benefit to stakeholders in multiple ways. CBER interactions with 

these organizations have resulted in development of several standards that 

affect various aspects (e.g., clinical, product, pharmacology/ toxicology

clinical, statistical, inspectional, IT) for products CBER regulates and ultimately

facilitate development, approval and improvements in new products, and

appropriate regulation including compliance activities with existing products.

Typically standards provide a generally acceptable path that developers and 

manufacturers can follow in product development and approval. However, the 

option almost always remains for developers and manufacturers to adapt 

general standards to specific products and/or to follow a more acceptable 

approach. 

Establishment and use of standards result in benefits to CBER that include: 

international standards that can be used by multiple regulatory regions; 

following our legal mandate to facilitate harmonization on an international

level; often better utilization of limited internal resources; more direct 

participation by various stakeholders in development of standards
D­55 

CBER also has created unique opportunities to develop standards, by

participating in standards development in a unique collaborative effort with

service or material donations from multiple organizations including academic 

and corporate institutions. For example, CBER organized an Adenovirus

Reference Materials Working Group that developed an adenoviral virus

reference material and adenoviral virus associated reference material. The 

reference material is used to define the particle and infectious units for 

adenovirus vectors used in gene therapy thus facilitating advancement in this

developing field and helping to assure patient safety. 

The FDA Center for Food Safety and Applied Nutrition (CFSAN) staff participate 

in the activities of the Codex Alimentarius Commission of the FAO and the 

WHO. CFSAN

experts are actively involved in Codex Alimentarius activities and in activities 

of methods validation organizations on which Codex Alimentarius relies, such as

ISO, the Association of Official Analytical Chemists (AOAC), and the 

International Dairy Federation (IDF). CFSAN has provided the U.S. Delegate or

Alternate Delegate to 80% (17 out of 21) of the technical committees and task 

forces and also provided technical experts to assist on the work of developing

more that 90 Codex standards and guidelines. Voluntary consensus standards

have limited relevance to food and veterinary medicine products. However, 

since the standards activities of multilateral organizations such as the WHO, FAO, the World Trade Organization (WTO) and the OECD are important in these 

areas, CFSAN is actively engaged in standards and policy development with

these organizations. CFSAN is also engaged in standards review in the 

International Organization for Standardization in Microbiology. 

International/Treaty Standards‐Related Activities ‐ FDA takes part in a variety

of international standards activities that fall under treaty organizations, and

thus are not reportable under the provisions of Circular A‐119. These standards

activities are nonetheless important to the agency in fulfilling its public health

regulatory mission. Some of these are referred to above, i.e. WHO, FAO, and

OECD. 

FDA/CFSAN Success Story
D­56 

3‐A Sanitary Standards, Inc.: Milk Safety Team (MST) standardizes FDA Office of 

Regulatory Affairs’ (FDA/ORA) Regional Milk Specialists (RMS) who conduct 

check‐ratings (audits) of Interstate Milk Shippers and State Regulatory Agency

enforcement activities as they relate to the National Conference on Interstate 

Milk Shippers (NCIMS) Grade “A” National Milk Safety Program. During this field

standardization exercise, MST and the RMS evaluate pieces of dairy processing

equipment in relationship to meeting 3‐A Sanitary Standards and Accepted 

Practices for dairy equipment sanitary design and cleanability in relationship to 

the Grade “A” Pasteurized Milk Ordinance (PMO). 

The FDA/ORA RMS routinely conduct audits of these IMS Listed Shippers (dairy

plants) of which one segment of the audit is to evaluate dairy processing

equipment utilized in the plant for conformity to 3‐A Sanitary Standards and

Accepted Practices and the PMO. 

This program has enhanced public health protection by: 

o verifying conformity of equipment to consensus‐based sanitary standards; 

o improving the quality and safety of milk and milk products processed on 

acceptably designed equipment; and 

o ready acceptance by both Regulatory Agencies and the dairy industry. 

Grade “A” Pasteurized Milk Ordinance: The Grade “A” Pasteurized Milk 

Ordinance (PMO) is the national sanitary model ordinance for the production 

and processing of Grade “A” milk and milk products. It is uniformly applied by

all 50 States and Puerto Rico under the National Conference on Interstate Milk 

Shippers (NCIMS) Grade “A” Milk Safety Program. This model ordinance is

incorporated by reference in Federal specifications for procurement of milk 

and milk products; is used as the sanitary regulation for milk and milk products

served on interstate carriers; and is recognized by the Public Health Agencies, 

the milk industry, and many others as the national standard for milk sanitation.

The Grade “A” PMO adopted and uniformly applied will continue to provide 

effective public health protection without being unduly burdensome to either 

Regulatory Agencies or the dairy industry. It represents a “grass‐roots” 

consensus of current knowledge and experience and as such represents a
D­57 

practical and equitable milk sanitation standard for the nation. This model

ordinance has been developed over the last 50 years as a compliment to the 

federal GMP’s. 

Agency for Healthcare Research and Quality – 

AHRQ funds and participates with the National Quality Forum (NQF) in the

endorsement of standards for performance measures of quality among various

providers. This effort brings all stakeholders together to make a determination 

founded in a membership‐driven NTAA‐compliant consensus process. In 2003, AHRQ incorporated NQF standards in its National Quality Report that was 

mandated by Congress and is in clearance within HHS. The AHRQ Director has a 

permanent seat on the Board of Directors of NQF and participates in the

endorsement of the consensus driven standards (measures) through a voting 

process. AHRQ provides support to NQF. 

AHRQ is a member and supports the meetings of the ANSI Health Informatics

Standards Board, a board that coordinates the U.S. standards developing

organizations for health information exchange. Other federal agencies, 

professional health organizations, and vendors are members. Duplication and 

overlap of health data standards domains and other issues are voluntarily

resolved through ANSI HISB. 

AHRQ is a member and supports the meetings of the U.S. Technical Advisory

Group to ISO Technical Committee 215, Health Informatics. The U.S. TAG 

formulates and reaches consensus on the U.S. position on health data issues 

taken at ISO TC 215 meetings. 

AHRQ supported the Institute of Medicine's letter report recommending eight

functions be included in the definition of an electronic health record. These 

functions were used by Health Level 7 to produce a balloted standard on the 

functional definition of an EHR in September 2003. The ballot has reached

consensus in 2004 and is beginning to be used by clinical information software 

vendors to disclose their support of specific functions defined in these 

standards.
D­58 

AHRQ participates as a liaison to the National Committee on Vital and Health

Statistics (NCVHS), an advisory committee that advises the Secretary of HHS on 

health information policy. NCVHS recommended adoption of four ANSI 

standards to the Secretary for use in federal health program information 

exchange. On February 21, 2003, the Secretary adopted 5 messaging standards. 

In FY 2004, NCVHS will recommend a core set of terminology standards to the 

Secretary for adoption. The Secretary adopted 15 more clinical data standards

in the Spring 2004 for federal government sector use.

AHRQ participates in one of the administration's 24 e‐Government initiatives‐ 

the Consolidated Health Informatics (CHI) initiative. In 2003, CHI recommended

four messaging standards and one terminology standard to the Secretary of HHS 

for adoption. He adopted all five. CHI is working selecting voluntary consensus 

standards for a total of 24 domain areas. 

AHRQ supported the founding of the Health Level 7 Special Interest Group on 

Patient Safety to begin the process of developing standards for reporting 

patient safety events across the nation in a uniform format. 

AHRQ supports ASTM’s Continuity of Care standard for health information to be 

exchanged among providers and given to patients following an office visit. 

AHRQ devoted $10 million of its $300 million budget in 2004 to the 

development and implementation of health care data standards to improve 

patient safety and quality of care. This includes funding FDA’s development of 

an electronic structured product labeling system, an electronic product listing 

of all products approved by FDA for sale in the US, a coding system for all drug 

components—active and inactive ingredients, and improvements in the National

Drug Code; and funding for transmission of this information in electronic form 

to the National Library of Medicine (NLM). Additionally, AHRQ funded NLM to 

develop a system to post this information on its DailyMed web site quarterly

and to map selected terminologies (ICD, CPT, MedDRA, others) to SNOMED. Also 

AHRQ funded NIST and CMS to develop web‐based, publicly available systems

for displaying the landscape of standards developing activities in the US and 

the data components of specific data standards. AHRQ is studying how patient

safety event data reported by 24 states may use existing American National

Standards and what ANS standards need to be developed to make this
D­59 

information more uniform and accurate. 

Centers for Disease Control

The Agency is very involved in the voluntary standards process and has been for 

a number of years. See http://www.cdc.gov/phin/ for an example of a current 

system using voluntary consensus standards. Additionally, this years report 

asks, for the first time, about information regarding Other Technical Standards. CDC has been requesting the ability to provide this information for several

years. The Public Health Surveillance System in the US is a true Federal, State 

and Local partnership driven by many consensus processes with a variety of 

partner organizations such as the Council of State and Territorial

Epidemiologists (CSTE), Association of State and Local Territorial Health 

Officials (ASTHO), Association of Public Health Laboratories (APHL), National

Association for Public Health Statistics and Information System (NAPHSIS),

National Association of Health Data Organizations (NADHO), etc. These 

partnerships result in guidelines or local laws invoked at the state and local 

level to provide uniform and professional public health surveillance and 

reporting system in the US. The notification of this change came while many of 

the CDC Personnel involved in these activities were focused on emergency

response deployments in the Gulf States and other then a mention in this 

report, full details will be delayed. It is estimated that the number of people 

involved in these activities greatly exceeds that of those involved with the

more formal VCS process. 

Centers for Medicare and Medicaid Services

CMS is participating with the National Quality Forum (NQF) in the endorsement

of standards for performing measures of quality among providers. This effort 

brings all stakeholders together to make a determination founded in a 

membership‐driven NTAA‐compliant consensus process. The NQF endorsed

quality measures for nursing home quality and hospitals in FY 2003. In FY 2004, CMS submitted measures to the NQF for endorsement in the home health and 

ambulatory settings. CMS incorporated NQF endorsed quality measures into its 

demonstrations, public reporting or quality improvement activities.
D­60 

The CMS Administrator has a permanent seat on the Board of Directors of the 

NQF and participates through an appointed designee. As a dues paying member 

of the NQF, CMS also participates on the Purchaser Council. 

The Consolidated Health Initiative (CHI) as one of 24 critically important E‐ Government (eGov) initiatives, that will provide the federal health enterprise 

with one of the essential components needed to enable federal agencies to 

build interoperable health data systems: clinical health data and messaging 

standards. Standards will enable this large enterprise to exchange comparable 

health data across the wide range of federal activities. Three federal

departments lead the initiative: Department of Health and Human Services

(DHHS), Department of Defense (DoD), and Department of Veterans Affairs

(VA). To date, the CHI work has led to the adoption of eleven sets of standards

covering twenty healthcare specific domains. This wide spread adoption of 

standards marks the first time the entire federal health enterprise has 

committed to use the same vocabularies to enable exchange of health

information. 

Within CMS, the implementation of the CHI standards requires a multi‐ 

component effort that cuts across various CMS business processes. The Office 

of Information Services’ (OIS) Enterprise Architecture (EA) organization will

employ a standardized implementation methodology for incorporating the CHI 

adopted standards across the framework architecture to facilitate CMS’ 

implementation of the CHI standards. The EA group will integrate the CHI 

adopted standards into the data and information infrastructures and will

identify potential business functions and areas where the CHI clinical messaging 

and vocabulary standards may apply. 

CHI’s initial portfolio identified 24 domain/subject areas requiring data and

messaging standards. To date, 20 domains/sub‐domains have adopted 

standards. (Government only standards are highlighted) 

They are: 

Domain Area Outcome 

Laboratory Results Names LOINC adopted
D­61 

Messaging Standards: Patient care including scheduling, medical record and

image management, patient administration, observation reporting, financial

management, public health notification, and patient care HL7 adopted 

Messaging Standards: Retail pharmacy transactions NCPDP SCRIPT adopted

Messaging Standards: Connectivity IEEE 1073 adopted 

Messaging Standards: Image information to workstations DICOM adopted

Medications Set of federal terminologies adopted including: 

• Food and Drug Administration’s names and codes for ingredients, 

manufactured dosage forms, drug products, and medication packages (FDA 

Ingredient Names & UNII Code; CDER Standard, NDC codes) 

• National Library of Medicine’s RxNORM

• Veterans Administration’s National Drug File Reference Terminology (NDF‐RT)

for specific drug classifications

• LOINC SPL for label section headers

• HL7 Gender, Race & Ethnicity for special populations

Demographics HL7 adopted 

Immunizations HL7 adopted

Clinical Encounters HL7 adopted 

Units HL7 adopted 

Interventions and Procedures: 

A. Non‐laboratory

SNOMED CT adopted

Interventions and Procedures: 

B. Laboratory test names LOINC adopted 

Lab Result Contents SNOMED CT adopted 

Diagnoses and Problems SNOMED CT adopted 

Anatomy SNOMED CT and NCI Thesaurus adopted 

Nursing SNOMED CT adopted 

Text‐based Reports HL7 clinical document architecture 

Genes Human genome nomenclature adopted (HGNC) 

Chemicals EPA’s substance registry system

Financial and Payment HIPAA transactions and code sets 

History and Physical No standard ready for adoption. Follow‐up

recommendations provided.
D­62 

Population Health

Multimedia 

Medical Devices and Supplies 

Disability

Proteins 

Physiology

Examples of case studies of standards successes include:

• Significant savings of electronic claims versus paper claims

• Ended Medicare claim contingency on October 1, 2005 

• MREP developed; enables ending the contingency for remittance legacy

formats. 

National Institutes of Health/National Cancer Institute 

The Nanotechnology Characterization Laboratory (NCL) is part of the National

Cancer Institute (NCI), which is part of the National Institutes of Health (NIH). 

The intent of the NCL is to accelerate the transition of basic nanotechnology

research into clinical applications. It seeks to establish and standardize an 

analytical cascade for nanomaterial characterization and to facilitate clinical

development and regulatory review of nanomaterials. The use of voluntary 

consensus standards (VCS) is, and will continue to be, critical in this endeavor. 

NCL is therefore taking a lead role in developing standard protocols for 

characterization of nanoparticles, which then enable appropriate assessment of 

the biological activity of these products. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 2

1. Government Unique Standard: FDA Guidelines on Asceptic Processing (2004) 

(Incorporated: 2004) 

Voluntary Standard

ISO 13408‐1 Asceptic Process ing of Health Care Products, Part 1, General 

Requirements
D­63 

Rationale 

FDA 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

2. Government Unique Standard: FR Notice dated June 17, 1994 Tentative 

Final Monograph for Health Care Antiseptic Drug Products; Proposed Rule 

(Incorporated: 1997) 

Voluntary Standard

ASTM Standard E1115 ‐ Test Method for Evaluation of Surgical Hand Scrub 

Formulations

Rationale 

Sensitivity and bias of the ASTM Standard has not been established. Voluntary Standard

ASTM Standard E1173‐93 ‐ Standard Test Method of an Evaluation of 

Preoperative, precatheterization, or Preinjection Skin Preparations

Rationale 

Sensitivity and bias of the ASTM Standard has not been established. Voluntary Standard

ASTM Standard E1174‐00 ‐ Standard Test method for the Evaluation of the 

Effectiveness of Health Care Personnel or Consumer Handwash Formulations

Rationale 

Sensitivity and bias of the ASTM Standard has not been established. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 3 

Voluntary Standard Government Standard

HL 7 Annotated ECG Waveform Data Standard FDA Guidance 21 CFR Part
D­64 

11 

HL 7 Structured Product Labeling FDA Guidance 21 CFR Part 

314

Voluntary Product Accessibility Template (VPAT) CMS Section 508 Checklist 

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 945

Other Technical Standards: 0

Rationale: The number reported here as Voluntary Consensus standards is only

an estimate of the total number of VCS and non‐consensus standards used by

DHHS Agencies. The proportion of these that are non‐consensus standards is

unknown. While the data provided elsewhere in this report indicate 

considerable involvement with voluntary consensus standard setting

organizations, they are not reflective of the total DHHS involvement with 

standard setting organizations. A large number of DHHS standards setting

activities are with groups which do not meet OMB’s definition of a voluntary 

consensus standards body: United States Pharmacopeia (USP), International

Conference on Harmonization (ICH), Organization for Economic Cooperation 

and Development (OECD) and the World Health Organization (WHO), etc. For 

example, the primary standards setting organization for FDA/CDER is the 

United States Pharmacopeia (USP). The Food, Drug and Cosmetic Act 

recognizes USP and mandates FDA’s involvement with the USP. OMB Circular 

No. A‐119 states that its definition of standard does not include a standard

created under other legal authority, such as those contained in the United

States Pharmacopeia and the National Formulary. FDA is also active with 

organizations such as Codex Alimentarius, ICH, VICH, CHIC, etc.. These groups

do not qualify as a voluntary standard setting organizations since they are 

treaty or government‐to‐government organizations. FDA also manages many 

products through the standards developed by their trade organizations. These
D­65 

are only a few examples of the types of organizations, manufacturer 

associations, comodity groups and professional societies with whom DHHS 

Agencies interact to develop standards. Last, and by no means least, due to the 

lack of a true consensus process, the WHO does not meet the criteria for a 

voluntary consensus standard body. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 114 

Voluntary Consensus Standards Body Acronym

3‐A Sanitary Standards, Inc 3‐ASS

Accredited Standards Committee X12 X12 

Acoustical Society of America ASA

Adeno Associated Virus Reference Standard Working

Group 

AAVSWG 

American Academy of Pediatrics AACP

American Association for Clinical Chemistry AACC

American Association of Blood Banks AABB 

American Association of Physicists in Medicine AAPM

American Association of Tissue Banks AATB 

American Chemical Society ACS 

American College of Surgeons ACOS 

American Conference of Governmental Industrial

Hygienists 

ACGIH 

American Industrial Hygiene Association AIHA 

American Institute of Ultrasound Manufacturers AIUM

American National Standards Institute ANSI 

American Red Cross ARC

American Society for Blood and Marrow 

Transplantation 

ASBMTT

American Society for Reproductive Medicine ASRM

American Society for Testing and Materials

International

ASTMI
D­66 

American Society of Agricultrial Engineers ASAE

American Society of Agricultural and Biological

Engineers 

ASABE

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

Association for Assessment and Accreditation of 

Laboratory Animal Care International

AAALAC

Association for Electronic Health Care Transactions AFEHCT 

Association for the Advancement of Medical

Instrumentation 

AAMI

Association of Food and Drug Officials AFDO 

Association of Official Analytical Chemists 

International

AOACI

Baking Industry Sanitary Standards Committee BISSC

Clinical and Laboratory Standards Institute CLSI 

Clinical Data Interchange Standards Consortium CDISC

Codex Alimentarius CODEX

College of American Pathologists CAP 

Conference for Food Protection CFP 

Congress of International Organizations of Medical

Sciences

CIOMS 

Consolidated Health Informatics CHI 

Cosmetic Ingredient Review CIR

Cosmetic Toiletry and Fragrance Association CTFA 

Council on Ionizing Radiation Measurements and 

Standards

CIRMS 

Designated Standards Maintenance Organizations

Board

DSMO 

European Directorate for Quality of Medicines EDQM 

External RNA Controls Consortium ERCC 

Eye Bank Association of AMerica EBAA
D­67 

foundation for Accrediation of Cellular Therapies FACS 

Fresh Produce Association of America FPA 

Health Level Seven HL7 

Healthcare Information and Management Systems

Society

HIMSS 

Independent Cosmetic Manufacturers and 

Distributers 

ICMAD

Industrial Safety and Equipment Association ISEA 

Institute of Electrical and Electronic Engineers IEEE

International Association for Food Protection IAFP 

International Association of Cancer Registrars IACR 

International Blood Group Reference Laboratory IBRGL

International Commission for Illumination CIE

International Commission on Harmonization of 

Technical Requirements for Registration of 

Pharmaceuticals for Veterinary Use 

VICH` 

International Committee for Cosmetic Harmonization 

and International Cooperation 

CHIC

International Conference on the Harmonization of 

Technical Requirements for Registration of 

Pharmaceuticals for Human Use 

ICH 

International Coordinating Committee on the

Validation of Alternative Methods

ICCVAM 

International Dairy Foods Association IDFA 

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

International Organization for Standardization in 

Microbiology

ISOB 

International Organization for

Standardization/International Electrotechnical

Commission 

ISO/IEC

International Regulatory Alternatives Group IRAG
D­68 

International Society for Analytical Cytology ISAC

International Society for Blood Transfusion ISBT

International Society for Cardiovascular Surgery ISCVS 

International Society for Cell Therapy ISCT 

International Society for Measurement and Control ISA 

International Society of Oncology Pharmacy

Practitioners

ISOPP

International Society on Thrombosis and Homeostasis ISTH 

International Union Against Cancer UICC

International Union of Pure and Applied Chemistry IUPAC

Interstate Shellfish Sanitation Conference ISSC

Joint FAO/WHO Expert Committee on Food Additives JECFA 

Logical Observation Identifier Names and Codes LOINC

National Cancer Registrar Assciation NCRA 

National Center for Vital and Health Statistics NCVHS 

National Committee on Vital and Health Statistics NCVHS 

National Conference for Interstate Milk Shipments NCIMS 

National Cooperation for Laboratory Accreditation NACLA

National Coordinating Council for Cancer 

Surveillance 

NCCCS 

National Council for Prescription Drug Program NCPDP 

National Council of Radiation Protection and

Measurements

NCRPM

National Dialog on Cancer NDC 

National Electrical Manufacturers Association NEMA 

National Environmental Health Association NEHA 

National Fire Protection Association NFPA 

National Institute for Biological Sciences and 

Controls

NIBSC

National Marow Doner Program NMDP 

National Sanitary Foundation International NSFI
D­69 

National Skill Standards Board NSSB 

National Uniform Billing Committee NUBC

National Uniform Claim Committee NUCC

North American Association of Central Cancer 

Registries 

NAACCR 

Organization for Economic Cooperation and 

Development 

OECD 

Organization for the Advancement of Structured

Information Standards

OASIS 

Pan American Health Organization PAHO 

Pasteurized Milk Ordinance PMO 

Portable Sanitation Association International PSIA 

Produce Marketing Association PMA 

Rehabilitation Engineering and Assistive Technology 

Society of North America 

RESNA 

Research Institute for Fragrance Materials RIFM 

Society of Automotive Engineers SAE 

Society of Cosmetic Chemists SCC

Standard for Exchange of Nonclinical Data SEND

Strategic National Implementation Process SNIP

U.S. Adopted Names Council USANC

Underwriters Laboratories UL 

United Fresh Furit and Vegetable Association UFFVA 

United States Adopted Names USAN

United States Pharmacopoeia USP

Workgroup for Electronic Data Interchange WEDI 

World Health Organization WHO 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 594
D­70 

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

U.S. Food and Drug Administration –

FDA inspects manufacturers of regulated products (pharmaceuticals, veterinary

drugs, medical devices, biologicals) for compliance with current Good

Manufacturing Practice (cGMP)and/or Quality System (QSR)Regulations

requirements. FDA inspects laboratories that provide pivotal animal studies for 

drug approvals for compliance with Good Laboratory Practice (GLP). FDA

participates on the ANSI Accreditation Committee, the ANSI International

Conformity Assessment Committee, ANSI Board Committee on Conformity

Assessment, and ASTM Committee E‐36 on Conformity Assessment. Within FDA, 

the Center for Devices and Radiological Health allows a medical device 

manufacturer to submit a Declaration of Conformity to a "recognized standard" 

as described in ISO/IEC Guide 22 in its standards recognition program and has 

developed an MRA with the European Union on mutual recognition of each 

other's conformity assessment procedures related to manufacture and 

marketing of medical devices. The FDA Office of Regulatory Affairs (FDA/ORA) 

actively participates with the National Cooperation for Laboratory

Accreditation (NACLA), serving as a member of the NACLA Executive Board of 

Directors and and participating in the NACLA Recognition Committee for 

Accrediting Bodies who apply for mutual recognition. Other FDA officials

participate with NACLA in the evaluation of accrediting bodies under ISO/IEC 58 

and ISO/IEC 17025 and sit on NACLA technical committees. 

CDER ‐ The conformity assessment activities in which the Center has been 

involved as described in the Federal Register, Vol. 65, No. 155, Thursday, 

August 10, 2000, Guidance on Federal Conformity Assessment Activities, and 

the 9/7/00 NIST document “Information on Voluntary Reporting on Federal

Conformity Assessment Activities for the Agency Annual Report. 

CFSAN ‐ Conformity Assessment Activity participation included: 

a. Grade A Milk Laboratory Certification Program ‐ The Grade A Milk safety

laboratory certification program relies on on‐site
D­71 

inspection as well as annual proficiency testing Evaluation forms developed

through common agreement by all parties are used to review records, 

facilities, and analysts’ performance of tests. The proficiencies cover the range 

of testing for which the laboratories are certified and the results are 

evaluated statistically. This program has enhanced public health protection by: 

o verifying analysts’ abilities to perform testing successfully; 

o improving the quality of the work performed by the analysts, analysts’ 

knowledge , and the credibility of results; 

o more rapidly and accurately identifying pathogens leading to earlier and 

more successful treatment; and

o keeping drugs out of the milk supply. 

With the idea of enhancing international credibility and recognition, CFSAN is

moving towards ISO accreditation of its own laboratories that perform 

regulatory work. 

b. Retail food managers’ certification program ‐ Via participation in the 

Conference for Food Protection (CFP), CFSA was involved in a certification / 

accreditation program. The CFP now owns copyrighted Food Manager 

Certification Standards which are administered by ANSI under contract with the

CFP. An FDA employee sits on an ANSI/CFP accreditation committee to ensure 

those Standards are administered, consistent with CFP's intent. This is the 

culmination of over 20 years of work to arrive at legally defensible national

standards to which all the stakeholders have agreed; meaningful certification; 

a basis for reciprocity among the 3000+ regulatory agencies in the U.S.; a single 

process for industry; and a straightforward method of fulfilling the FDA model

Food Code. 

Centers for Medicare and Medicaid Services

Sampled remittances (835 transactions) generated by Medicare Part A 

contractors to determine the use of Claim Adjustment Reason Code ‘A7’. This 

code value represents a forced‐balance situation with the claim and should be 

rarely used. a. Before = 75% out of balance 

b. After = 47% out of balance
D­72 

Project continues; next sampling will be taken in January 2006 for 1st quarter 

results. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

Food and Drug Administration 

U.S. Food and Drug Administration ‐ The policy and recommendations

contained in Circular A‐119 are consistent with FDA's framework for standards

management as announced in the Federal Register on October 11, 1995, and 

enhanced by the Food and Drug Administration Modernization Act (FDAMA). Resource constraints oblige the agency to focus attention on the highest 

priority activities and to strive to make its participation in those activities very

effective. FDA participates in several hundred standards development activities

(the exact number is not known as there is not established procedure to gather 

this information) within 165 voluntary consensus standards bodies. 

Centers for Disease Control

CDC’s major issue with prior OMB A‐119 reporting revolved around our inability

to report the majority of our work with partner organizations that are not 

SDOs. This has been corrected this year, but knowledge came too late to 

effectively organize any data collection mechanism. Collecting this information 

will be a major resource burden for the Agency as all essentially all CDC 

programs are involved. In light of our difficulty in collecting present data, we 

realize the information content will better reflect our work, but will still

question completeness. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

Agency for Healthcare Research and Quality

Agency for Healthcare Research and Quality ‐ AHRQ has supported voluntary 

consensus standards development and processes for many years because
D­73 

uniform information exchange can lead to better research data having more 

powerful findings and because informatics tools can better access the 

knowledge to improve patient safety, quality of care, the cost of care, and 

access to care. In 2004 AHRQ increased its pace of support for health data 

standards and code sets by $10 million. 

Centers for Disease Control

The notification for this year’s NTTAA Report came while many of the CDC

Personnel involved in these activities were focused on emergency response 

deployments in the Gulf States. Full details will be delayed until next year’s

report. 

Federal recognition of VCS is increasing, but Agency recognition is still weak. Until the importance is elevated so that it is part of the planning process

involving the Agency Director full advantage of the VCS process will not be 

obtained. Likewise, complete reporting will remain out‐of‐reach. At CDC a 

good example may be seen by the level of reporting by our National Institute 

for Occupational Safety and Health (NIOSH) which works effectively though 

numerous partnerships, with a large outreach to the VCS community and good

tracking of VCS work. A similar situation does not exist in most other areas of 

CDC.

Center for Medicare and Medicaid Services

An evaluation period is planned for carriers during FY 2006 to assess

remittances that are out of balance. 

National Institutes of Health/National Cancer Institute 

NCL is actively involved in the development of new standards for 

characterization of nanotechnology products for medical use. It must interact 

with national and international agencies. Considerable effort is being put into 

evaluating existing standards for applicability and developing new protocols

when needed. NCL is part of one agency (NCI), but its “products” must be 

approved by a different agency (FDA). It cannot select which VCS are
D­74 

acceptable and which GUS must be used, but must follow the regulations of the 

FDA centers involved. It does hope to promote the development of standards

that will be acceptable to the FDA and will aid in the commercialization of 

nanotechnology products.

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0 

Title: Department of Health and Human Services (HHS) Fiscal Year 2005 Agency Report
D­75 

Department of Homeland Security 

Title: Department of Homeland Security (DHS) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The U.S. Department of Homeland Security is committed to developing and 

adopting nationally and internationally recognized standards as a means to 

improve homeland, air and maritime safety, marine environmental protection, 

and to promote an internationally competitive U.S. maritime industry. One of 

the goals of our Standards program is to develop a comprehensive set of 

nationally recognized, internationally compatible standards through active 

participation in national standards organizations. While the adoption of 

industry standards enables the Homeland Security Department to fulfill its 

regulatory functions more efficiently, this capability would be useless without 

the existence of meaningful standards. Recognizing this reality early on, the 

Coast Guard aggressively pursued membership on a full range of standards‐ organizations. Today the Coast Guard supports at least 30 non‐government

organizations and actively participate on over 100 standards‐committees. This

active participation enables us to raise genuine issues of public safety and

preservation of the marine environment. Additionally, where industry has not 

established suitable safety requirements, we catalyze their development. 

Becoming an integral part in this process has enabled the Coast Guard to avoid

drafting unnecessarily detailed regulations and in some cases avoiding

regulation completely. It has also helped us to evolve from a regulatory process

which reacts to disaster to a more orderly process which recognizes technical 

innovation and progressive ideas aimed at preventing disaster. 

To date we have adopted over 450 industry standards, saving over 25,000 pages

of federal regulations and the associated regulation maintenance, while 

specifying standards already familiar to the industry regulated. We estimate 

that our participation on standards committees saves us over $1.5M annually

and increases our inspection and technical force 100 times.
D­76 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 1000

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 50 

Voluntary Consensus Standards Body Acronym

3rd Generation Partnership Project 3GPP

3rd Generation Partnership Project 2 3GPP2 

Alliance for Telecommunications Industry Solutions ATIS 

American Association for Budget and Program

Analysis

AABPA 

American Association of State Highway and 

Transportation Officials

AASHTO 

American Boat and Yacht Council ABYC

American Bureau of Shipping ‐‐SELECT‐‐ 

American National Standards Institute ANSI 

American Railway Engineering & Maintenance‐of‐

Way Association 

AREMA
D­77 

American Society for Testing and Materials ASTM

American Society of Civil Engineers ASCE

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

American Society of Naval Engineers ASNE

American Towing Tank Conference ‐‐SELECT‐‐ 

American Welding Society AWS 

Association of Diving Contractors International ‐‐SELECT‐‐ 

Chlorine Institute ‐‐SELECT‐‐ 

Compressed Gas Association CGA 

Council on Ionizing Radiation Measurements and 

Standards

CIRMS 

Electronic Industries Alliance EIA 

Health Physics Society HPS 

Human Factors Society HFS

Institute of Electrical and Electronic Engineers IEEE

Instrumentation Society of America ‐‐SELECT‐‐ 

International Association of Drilling Contractors IADC

International Association of Lighthouse Authorities ‐‐SELECT‐‐ 

International Atomic Energy Agency IAEA 

International Civil Aviation Organization ICAO 

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

International Radio Consultative Committee IRCC

International Ship and Offshore Structures Congress ISOSC

International Telecommunication Union ‐ Telecommunication Standardization SectorITU‐T 

Internet Engineering Task Force IETF 

Joint Aeronautical Commander's Group ‐‐SELECT‐‐ Marine Technology Society MTS
D­78 

National Cargo Bureau, Inc NCB 

National Committee for Information Technology

Standards

NCITS 

National Council of Radiation Protection and

Measurements

NCRPM

National Defense Industrial Association NDIA 

National Fire Protection Association NFPA 

National Marine Electronics Association ‐‐SELECT‐‐ National Marine Manufacturers Association ? 

National Sanitation Foundation ? 

Radio Technical Commission for Maritime Services RTCM

Society of Naval Architects and Marine Engineers SNAME

Telecommunications Industry Association TIA 

Telemanagement Forum TMF 

Underwriters Laboratories UL 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 160

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

TSL's Trace Certification Program created pursuant to ATSA Act of 2001 and 

registered to ISO‐9001:2000 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The USCG encourages government‐wide use of risk‐based methodologies in 

standards development and assessments. The Coast Guard uses risk‐based

methodologies to determine the level and degree of standardization needed. Using risk‐based methods in a top down systems engineering approach we can
D­79 

determine the relative safety hazards and determine the effective level of 

standardization needed. Using risk‐based methods on specially designed cargo

vessels, we saved over $2m per vessel. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

none 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

haphazardly by component 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­80 

Department of Housing and Urban Development 

Title: Department of Housing and Urban Development (HUD) Fiscal Year 2005 Agency

Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Standards are of significant value in the accomplishment of the HUD mission.

Because the HUD housing and community development mission closely parallels

other construction and coummunity development activities in America's cities,

counties and states, HUD relies on the use of standards common to both 

activities such as local, regional or national construction codes. 

HUD has been successful (and welcomed) in recent efforts to participate in the 

development of national model construction codes. During the 2005 

International Code Council hearings, HUD testified on code change proposals

regarding rehabilitation codes and accessibility. This involvement was well

received by the other participants at the hearings. 

Based on a recent Office of Policy Development & Research (PD&R) assessment 

of HUD’s own Minimum Property Standards (MPS) and Technical Suitability of 

Products (TSP) program, discussions continue to determine the future of the 

MPS and TSP program. This major study recommends that the Department

extend its reliance on voluntary standard in two ways. First, the study

recommends that HUD totally abandon the MPS for single‐family housing in all

aspects totally relying on the model codes, especially the ICC & IRC codes and 

remove all remaining references to the MPS in HUD regulations. This would

clarify the decision by HUD regarding not issuing construction standards. 

Second the study recommends that HUD abandon its own “Technical Suitability

of Products” program relying instead on the National Evaluation Service to 

review al innovative or other products that do not meet the prescriptive 

standards of the model codes. This study is under review by the assistant

Secretary for Housing. If adopted, this will strengthen HUD's reliance on the 

voluntary and private consensus process in lieu of HUD developed standards
D­81 

and criteria. 

Work continues on the development of a revision to the HUD Manufactured

Home Construction and Safety Standards (24 CFR 3280) being developed

through a concensus process with NFPA. This will remain a Government Unique 

Standard. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 2

1. Government Unique Standard: 24 CFR 200.935 ‐ Administrator qualifications

and procedures for HUD building products and certififcation programs

(Incorporated: 2000) 

Voluntary Standard

ANSI A119.1 N ‐ Recreation Vehicles 

Rationale 

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 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. 

2. Government Unique Standard: 24 CFR 3280 ‐ Manufactured Home 

Construction and Safety Standards (Incorporated: 2000) 

Voluntary Standard

ANSI A119.1 ‐ Recreation Vehicles and NFPA 501C ‐ Standard on Recreational

Vehicles 

Rationale 

HUD‐Unique Manufactured Home Construction & Safety Standards. HUD was

required by legislation to “establish Federal construction and safety
D­82 

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. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 300

Other Technical Standards: 0

Rationale: Because of the nature of the HUD work, the value of VCS used in 

2005 is an estimate. Most of these standards are used in the execution of the 

HUD mission by HUD contractors and grantees. No known Other Technical

Standards were identified on an agency‐wide survey conducted during the year. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 4 

Voluntary Consensus Standards Body Acronym

American Society for Testing and Materials ASTM

Federal Geographic Data Committee FGDC

International Code Council ICC

National Fire Protection Association NFPA
D­83 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 4

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

All of HUD's 25 conformity assessment (CA) programs, under the HUD Building‐ Products Standards & Certification Programs, are in compliance with the ISO 

guidelines & procedures. These are the same standards used by ANSI and other 

nationally recognized third‐party certification agencies.

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

This policy continues to be effective in replacing Federal Standards with 

publicly developed standards. This has resulted in more up‐to‐date and

technically accurate standards. Circular A‐119 might use stronger language to 

encourage agencies to be more active in determining which standards are 

applicable to the agency activities and when standards are identified, motivate 

the agency to be more assertive in enforcing their use. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

N/A 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

n/a

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]
D­84 

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
D­85 

Department of the Interior

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

DOI consists of 8 bureaus. The following is a response from Fish and Wildlife 

Service (FWS): 

The FWS is using data standards to increase the quality and compatibility of its

data and to increase opportunities to share data with clients, cooperators, partners, and the general public. Standards are developed, reviewed, and

adopted according to a formal process. This process is described in detail at 

http://www.fws.gov/stand/standards/process_www.html. The FWS recognizes the importance of using technical standards, in general, and Voluntary Consensus Standards (VCS), in particular, to accomplish a variety

of mission‐related goals and objectives. The following are examples and 

outcomes: 

* To date, over 50 data standards have been formally adopted for Service‐wide 

use and implementation, and several other standards are in progress. A data 

steward is identified for each standard, and this person is responsible for

maintaining both the content of the data standard and any applicable source 

data that is linked from the standard's web page. A complist of the FWS data 

standards is available at http://www.fws.gov/stand/. 

* The FWS is the nation's leading wetlands conservation and restoration agency

within the federal government. For the past decade, FWS national wetlands

standards have been widely used within and outside of the government for

wetlands classification, mapping and data reporting purposes (i.e., non‐ 

regulatory purposes). 

* The FWS has adopted the Department of the Interior's Certification and

Accreditation Guide, November 2004, which provides a standardized approach 

for the certification and accreditation (C&A) of all Interior IT systems. The 

guide complies with OMB, NIST, and other applicable Federal and Departmental

laws, policies, and regulations.
D­86 

* The FWS Analytical Control Facility (ACF), Division of Environmental Quality

(DEQ), uses the ANSI Z87.1 Standard (product standard) for personal protective 

equipment. The ACF also uses the Hazardous Material Information System

(HMIS) (industry standard) for proposed labeling of hazardous chemical being

used in the laboratory. Use of these standards ensures the safety of employees 

who provide analytical support on wildlife refuge investigations in support of 

the FWS mission. 

* The Coastal Barrier Resources Act program utilizes data standards in its 

execution of the Digital Mapping Pilot Project as directed by the Coastal Barrier 

Resources Reauthorization Act of 2000 (P.L. 106‐514 Sec. 6(b)(4)). This pilot 

project supports the Service’s mission goal of resource protection through the

strategy of improving the information base, information management, and

technical assistance. 

* The FWS Endangered Species Program primarily uses Government Standards as

published in ITIS (Integrated Taxonomix Information System) to maintain

consistent nomenclature when referring to listed or candidate species, and

published by the Convention on International Trade in Endangered Species of 

Wild Fauna and Flora (CITES) standard when referring to foreign species

protected under the CITIES international agreement between Governments. It 

is extremely important that FWS adheres to these nomenclature standards to 

ensure consistency in reporting activities related to T&E species and to ensure 

there is no confusion on the part of the public sector and other Federal

government entities.

FWS Outcomes: 

* The implementation and use of adopted FWS data standards has resulted in 

less duplication of effort and a significant improvement in the ability to share 

and exchange data among FWS systems and with other DOI bureaus, in 

particular the U.S. Geological Survey (USGS). 

* The Department of the Interior developed the C&A Guide in response to the 

E‐Government Act (Public Law 107‐347), Title III, Federal Information Security 

Management Act (FISMA), which emphasizes the need to organizations to 

develop, documents, and implement organization‐wide programs to provide
D­87 

information security for the information systems that support operations and

assets. The FWS has officially adopted this policy and is working to incorporate 

its requirements in all IT systems. 

* Standards implementation promotes uniform acquisition and production of 

nationally consistent wetlands data, resulting in significant cost/time savings; 

improved collaboration and cooperation with the public and/or private sectors; 

helps avoid duplication of private sector activities; promotes innovation and

application of better technology; and increased goodwill for the Federal

government. 

* Use of both the ANSI Z87.1 and HMIS standards results in improved safety and 

less lost time/cost due to fewer injuries in the laboratory. 

The following is a response from DOI's Bureau of Land Management (BLM) 

* The BLM's mission statement is to "sustain the health, diversity, and

productivity of the public lands for the use and enjoyment of present and 

future generations". To that end, the BLM maintains relationships with the

stakeholders and neighbors of the public lands and uses standards to provide 

common understanding and meaning behind its land management decisions. The BLM has developed and populated a Corporate Metadata Repository for

bureau‐wide information systems that maintains the definitions and metadata 

for the data elements and themes used by the BLM. This allows for greater 

collaboration internally with the various resources programs and externally, with the interest groups and citizen advisory panels to allow for greater 

cooperation. The BLM recently designated an oversight committee composed

chiefly of data stewards and managers to ensure that the CMR meets the 

business requirements of the BLM. 

Response from DOI's Bureau of Reclamation (BOR): 

Industry standards are incorporated into Regional Construction Specifications

when possible. General Contractor's are more familiar with industry standards

and therefore, usage should result in more economic bid packages. 

Standards are used in the management of construction contracts. Most
D­88 

construction specifications reference one or more set of standards, and

Construction Services personnel must be familiar with the standards in order to 

ensure contract compliance. Contractors are more familiar with voluntary 

consensus standards and their use allows improved collaboration and 

cooperation with the private sector as well as the successful completion of 

construction contracts resulting in properly functioning facilities. 

The regulatory and consensus industry standards are critical to establishing the 

scientific basis for the engineering controls, administrative controls, exposure 

assessments, medical surveillance and personal protective equipment

necessary to protect personnel, contractors and the public from safety and 

health hazards in Reclamation. 

The use of standards is the basal requirement for the accurate communication 

of technical concepts. The use of standards is vital to ensure the results of 

facility inspections; the descriptions of potential concerns; both the 

development and results of investigation; the entire evaluation and design

process; the creation of understandable contract specification; and the 

assurance of contract quality and control. Without the use of a well thought 

out standards system all technical language would be open to interpretation 

and the likely of ensuring a facility’s continued safe and productive function 

would be compromised. 

The geotechnical community has a vast array of nomenclature; sampling and 

testing methodology, sampling and testing procedures; and reporting and

documentation alternatives from which to choose. Reclamation has selected

specific sources, in some cases creating these sources, to ensure a thorough

understanding of Reclamation data. This has allowed Reclamation personnel to 

communicate and work effective with other Reclamation staff and 

representatives from other governmental agencies and the public with

maximum efficiency and minimal misunderstanding. 

Reclamation relies on consensus standards for geospatial activities related to 

metadata for data documentation, maintenance, and data transfer; and also 

data acquisition and development. Voluntary Consensus Standards (VCS) 

through ISO, the Federal Geographic Data Committee (FGDC), ASTM, as well as
D­89 

state and local agencies have reduced the cost of geospatial data acquisition 

and development. Costs to coordinate efforts have risen in respect to the 

increased activity, but are expected to drop as standards are adopted by all

agencies over the next 5 years.

Response from DOI's Minerals Management Service (MMS): 

The Minerals Management Service’s mission is to manage the minerals

resources on the Outer Continental Shelf and Federal and Indian minerals

revenues to enhance public and trust benefits, promote responsible use, and 

realize fair value. In support of this mission, we have adopted the use of 

voluntary consensus standards to promote improved collaboration and 

cooperation with the private sector and industries we regulate and apply

innovative and improved technology. 

In addition, the BLM participates in federal standards bodies, including the 

Federal Geographic Data Committee (FGDC). While the membership is from 

federal agencies, the standards that are developed are often elevated to the 

American National Standards Institute (ANSI) and to the International Standards

Organization (ISO) and will, therefore, receive wider review. BLM's

participation in the North American Weeds Management Association, which 

includes representatives from Canada and Mexico, as well as State and local 

representatives. The result has been the development of standards that can be 

used in both a commercial sense (e.g., cropland management) as well as 

providing an integrated approach to weed control. 

Response from DOI's U.S. Geological Survey (USGS): 

The nature of USGS scientific research and monitoring makes the use of 

voluntary consensus standards a required tool. Our science programs

collaborate with partners and cooperators in the public and private sectors

locally, nationally, and internationally. Thus, agreement on the use of 

standards is essential to our mission. 

The USGS National Geospatial Programs Office (NGPO) hosts the Federal

Geographic Data Committee (FGDC) Secretariat. OMB Circular A‐16 establishes

the FGDC as the interagency coordinating body for developing the National

Spatial Data Infrastructure (NSDI) as the "technology, policies, standards,
D­90 

human resources, and related activities necessary to acquire process, distribute, use, maintain, and preserve spatial data." 

The NSDI Clearinghouse Network is an online community of distributed data 

providers who publish metadata that describe their geospatial data. Users may 

search metadata records published on the NSDI Clearinghouse Network to find 

geospatial data and evaluate the fitness for use. If a user finds already existing 

geospatial data that meets their needs through the NSDI Clearinghouse 

Network, they do not have to create their own data, which results in time and 

costs savings. The NSDI Clearinghouse Network uses the search and retrieval 

protocol in ANSI Z39.50‐1995 (ISO 23950). 

Metadata records published on the NSDI Clearinghouse Network are prepared 

following the FGDC Digital Content Standard for Geospatial Metadata ("FGDC

CSDGM). FGDC CSDGM was developed when there were no equivalent voluntary 

consensus content standards for geospatial metadata and is the foundation for 

many other countries' geospatial metadata standards. ISO 19115, Geographic 

information ‐‐ Metada, adopted by the American National Standards Institute, 

mirrors much of the content found in the FGDC CSDGM. FGDC also contributes

greatly to the US implementation of ISO 19115 and ISO 19139 metadata XML 

Schema and coordinating development of a North American profile with the

Canadian Standards Board. FGDC has also supported development of a 

standalone crosswalk application to convert FGDC CSDGM to ISO 19139 

Metadata Schema. The benefit of the crosswalk is that it will maintain the 

value of existing metadata assets. 

DOI Bureau of Reclamation (BOR) response: Industry standards are 

incorporated into Regional Construction Specifications when possible. General

Contractor's are more familiar with industry standards and therefore, usage

should result in more economic bid packages. 

Standards are used in the management of construction contracts. Most 

construction specifications reference one or more set of standards, and

Construction Services personnel must be familiar with the standards in order to 

ensure contract compliance. Contractors are more familiar with voluntary 

consensus standards and their use allows improved collaboration and
D­91 

cooperation with the private sector as well as the successful completion of 

construction contracts resulting in properly functioning facilities. 

The regulatory and consensus industry standards are critical to establishing the 

scientific basis for the engineering controls, administrative controls, exposure 

assessments, medical surveillance and personal protective equipment

necessary to protect personnel, contractors and the public from safety and 

health hazards in Reclamation. 

The use of standards is the basal requirement for the accurate communication 

of technical concepts. The use of standards is vital to ensure the results of 

facility inspections; the descriptions of potential concerns; both the 

development and results of investigation; the entire evaluation and design

process; the creation of understandable contract specification; and the 

assurance of contract quality and control. Without the use of a well thought 

out standards system all technical language would be open to interpretation 

and the likely of ensuring a facility’s continued safe and productive function 

would be compromised. 

The geotechnical community has a vast array of nomenclature; sampling and 

testing methodology, sampling and testing procedures; and reporting and

documentation alternatives from which to choose. Reclamation has selected

specific sources, in some cases creating these sources, to ensure a thorough

understanding of Reclamation data. This has allowed Reclamation personnel to 

communicate and work effective with other Reclamation staff and 

representatives from other governmental agencies and the public with

maximum efficiency and minimal misunderstanding. 

Reclamation relies on consensus standards for geospatial activities related to 

metadata for data documentation, maintenance, and data transfer; and also 

data acquisition and development. Voluntary Consensus Standards (VCS) 

through ISO, the Federal Geographic Data Committee (FGDC), ASTM, as well as

state and local agencies have reduced the cost of geospatial data acquisition 

and development. Costs to coordinate efforts have risen in respect to the 

increased activity, but are expected to drop as standards are adopted by all

agencies over the next 5 years.
D­92 

DOI Minerals Management Service (MMS) response: The MMS's mission is to 

manage the minerals resources on the Outer Continental Shelf and Federal and 

Indian minerals revenues to enhance public and trust benefits, promote 

responsible use, and realize fair value. In support of this mission, we have 

adopted the use of voluntary consensus standards to promote improved

collaboration and cooperation with the private sector and industries we 

regulate and apply innovative and improved technology. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 1

1. Government Unique Standard: 1. FWS Geospatial Metadata Standard

(adopts the Content Standard for Digital Geospatial Metadata (CSDGM), Version 2.0 FGDC‐STD‐001‐1998. 2. Nomenclature of Endangered and

Threatened Wildlife and Plants (FWS Data Set Standard, Working Draft); 

proposed standard to adopt the Service's official list of scientific names, 

common names, and taxonomic group names for all species of wildlife and

plants t (Incorporated: 2005) 

Voluntary Standard

1. International Organization for Standardization (ISO, ISO 19115:2003, Published Standard on Geographic Information ‐ Metadata 

2. Convention on International Trade in Endangered Species (CITES)of Wild

Fauna and Flora, Checklist of CITES Species; provides the official 

alphabetical list of CITES species, their scientific synonyms, their common 

names in English, French, and Spanish, etc. 

3. 

Rationale 

1. The Federal Geographic Committee (FGDC) developed the Content

Standard for Digital Geospatial Metada (CSDGM) in response to Executive 

Order 12906, which require3d all Federal agencies to document spatial data 

in a consistent manner to facilitate sharing data and to reduce duplication of
D­93 

effort. The FWS officially adopted the FGDC CSDGM, Version 2.0, in August 

1998. ISO 19115, an abstract standard, specified general content for the 

metadata, but does not specify format for the metadata. The FGDC is

working to harmonize the ISO 19115 metadata standard with the CSDGM 

Version 2.0. 

2. Different Service programs maintain species lists in compliance with 

several conservation laws and treaties, including the Endangered Species

Act, Migratory Bird Treaty Act, Lacey Act, and Convention on International

Trade in Endangered Species (CITES). In other words, there is no single 

species list that meets the needs of all Service programs. The list of 

scientific and common names for this data set is published in the Code of 

Federal Regulations (CFR), Title 50‐‐Wildlife and Fisheries, Part 17‐‐ Endangered and Threatened Wildlife and Plants. These values, along with 

the associated species and population codes, are contained in the Service's

official Threatened and Endangered Species System (TESS) database. 

3. Service personnel must comply with the adopted FWS data standard unless

it conflicts with their primary responsibilities. for example, the FWS 

International Affairs Program is responsible for implementing CITE, a treaty 

with 153 member countries. In this capacity, the FWS is bound by resolution 

to use the ISO country codes in its permit numbers rather than the FIPS 

codes to ensure consistency in reporting. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 2 

Voluntary Standard Government Standard

CITES of Wild Fauna and Flora Nomenclature FWS Data Set Standard: 

Nomenclature of 

Endangered and Threatened

Wildlife and Plants (working 

draft) 

ISO 3166‐1:1977, Codes for the Representation of FWS Data Element
D­94 

Names of Countries and their Subdivisions ‐ Part I: 

Country Codes 

Standard: Geopolitical

Entity Name and Code 

(adopts FIPS PUB 10‐4) 

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 768

Other Technical Standards: 65

Rationale: No suitable Voluntary Consensus Standard was available for use at 

the time these standards were adopted. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 26 

Voluntary Consensus Standards Body Acronym

Advisory Committee for water Information ACWI 

American Concrete Institute ACI 

American Institute of Steel Construction AISC

American National Standards Institute ANSI 

American Petroleum Institute API

American Society for Photogrammetry and Remote 

Sensing

ASPRS 

American Society for Testing and Materials ASTM

American Society of Civil Engineers ASCE

American Society of Mechanical Engineers ASME

American Water Works Association AWWA

American Welding Society AWS 

Convention on International Trade in Endangered CITES
D­95 

Species of Wild Fauna and Flora (CITES) 

Cultural Resources Standards with State Historic 

Preservation Offices

SHPO 

Federal Geographic Data Committee FGDC

Ground Water Protection Council GWPC

Institute of Electrical and Electronic Engineers IEEE

International Air Transport Association (IATA) IATA 

International Organization for Standardization ISO 

National Association of Corrosion Engineers NACE

National Environmental Methods Index NEMI 

National Water‐Quality Monitoring Council NWQMC

North American Weeds Management Association NAWMA 

Open Geospatial Consortium OGC

Petrotechnical Open Standards Consortium, Inc. POSC

The National Digital Orthophoto Program NDOP 

Urban and Regional Information Systems Association URISA 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 74

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

DOI ‐ Fish and Wildlife Service (FWS) Activities:

1. FWS Information Technology Bulletin (ITB) 2005‐001, Adoption of the 

Department of the Interior Certification Accreditation Guide, Version 1.1, July

10, 2003: The Department's OCIO issued the Department of the Interior

Certification and Accreditation (C&A) Guide to provide a standardized approach 

for the C&A of all Interior IT systems. The guide complies with OMB, NIST and 

other applicable Federal and Departmental laws, policies and regulations. The 

FWS officially adopted this policy in FY 2005 (November 2004) and is working to 

incorporate its requirements in all IT systems. Utilizing the C^A methodology
D­96 

defined in this guide will result in a standardized IT security C&A program

across Interior. 

2. FWS representatives actively participate in the FGDC Coordination Group, associated National Spatial Data Infrastructure (NSDI) activities, and the 

Geospatial One‐Stop (GOS) initiative. A subgroup of the FGDC Standards Work 

group is working on a process to develop/approve VCS that are consistent with

OMB Circular A‐119. One major objective of GOS is to develop geospatial 

standards and web services for multiple mapping applications by identifying 

common data requirements and structured use of VCS. 

DOI‐ Bureau of Land Management (BLM) Activities: 

1. Interagency trails Data Standards: 

The BLM is one of three major national land management agencies that have 

established data standards for trails information. The membership in this

standards working group included the National Park Service (NPS), the BLM, the 

US Forest Service (USFS), and representatives from trails organizations. Over 

150 participants have furnished comments on the Trails standards and the final

standards will be used in the Recreation.gov effort, of the Presidential E‐ Government initiatives. 

2. National Digital Elevation Program (NDEP) 

The NDEP was established to promote the exchange of accurate digital land 

elevation data among government, private, and nonprofit sectors and the 

academic community and to establish standards and guidance that will benefit 

all users. The NDEP is composed of agencies from the Department of the 

Interior, Commerce, and Agriculture, as well as the National Imagery and

Mapping Agency, National Aeronautics and Space Administration, US Army Corp

of Engineers, and the Federal emergency Management Agency, and

representation from state governments through the National States Geographic 

Information Council. 

3. Pacific Northwest Regional Geospatial Information Council (PNW‐RGIC) 

The BLM participates in voluntary standards that are developed by PNW‐RGIC, which includes the BLM, the US Forest Service, and state natural resource 

partners, particularly in the area of hydrology, fisheries, and related
D­97 

categories. The standards are adopted by the land management agencies for

cooperative forest management. 

DOI Bureau of Reclamation (BOR) Activities: 

Geospatial data acquired by or provided by BOR's mid pacific region is reviewed

for compliance with relevant FGDC and ISO standards for metadata. Data

developed by the Region for land cover analysis is done in coordination with

other Federal and State agencies to ensure compliance with FGDC standards on 

vegetation and land cover. The MP region continues to work toward integrating

standards into the daily business efforts. many of the developed geospatial 

databases preceded the current standards. 

DOI MMS: Is a member of the FGDC with representation on the Standards

working Group and subcommittees developing standards for geospatial data. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

DOI BLM ‐ It is difficult to apply policy retroactively and it is not clear what 

policy implementation documents have been released from NIST or from OMB 

directing agencies to conform to the NTTAA. It might be useful to solicit 

comments during the year on proposals for strengthening the NTTAA and

suggestions for what types of cooperative activities might be appropriate so 

that the agencies can get involved in cooperative efforts to develop consensus

standards as well as their adoption. 

DOI USGS: Since its issuance, Circular A‐119 has worked in a straightforward

manner to encourage the use of voluntary consensus standards. we have no 

recommendations for changes to the Circular. 

DOI MMS: As a direct result of OMB Circular A‐119, MMS continues to increase 

our presence in voluntary standards groups ‐‐ both domestic and international. we believe that A‐119 continues to work in a straightforward manner to

encourage the use of voluntary consensus standards. The MMS has not 

requested any exemptions, nor are we contemplating making such a request. 

We have no recommendations for changes to the Circular.
D­98 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

Comments from DOI ‐ Fish and Wildlife Service (FWS): 

To improve the quality of responses, future request for annual reports should

include the following: 

1. Clear guidance on what type of technical standards should be reported. For

example: 

(a) Question 1 ‐ respondents are asked to describe the importance and use of 

"standards" in general, while the Help Text asks for examples and beneficial

outcomes of VCS in particular. It is not clear if respondents should report 

success stories on the use of all technical standards ‐ or only those that pertain 

to the use of VCS. 

(b) Question 3 ‐ respondents are asked to list the VCS substituted for GUS, but

it is not clear where respondents list NEW VCS that do not meet this criterion.

(c) Question 4 asks for the total NUMBER of VCS AND Other Technical Standards

‐‐ document titles are not requested. Without titles, respondents can not 

identify or track the "new or discontinued uses" that occurred during the 

previous reporting year. 

2. The NIST and/or OMB should identify high priority VCS for implementation by

Federal agencies, especially standards that pertain to E‐Gov initiative and IT 

security requirements. 

3. Definitions and good examples of VCS and GUS, as well as a list of bona fide 

organizations (standards bodies) that develop both types of standards. Previous

reports identify Federal organizations as VCS bodies (e.g., FGDC and NIST).

4. The URL for NIST Standards.gov web site (http://standards.gov/) should be 

provided to all agencies/bureaus for links to the Act, OMB Circular A‐119, 

standards web sites, and NTTAA reports to OMB for previous years. 

5. A digital version o the NTTAA questions in a format that is usable to 

respondents for distribution and data entry proposed (i.e., a form in Word or

PDB that can be used for data entry).
D­99 

6. Agency bureaus (e.g., DOI's FWS, USGS, etc) should be given access to the 

NIST Agency Reporting Tool for the purpose of entering their own information.

The current procedure is both cumbersome and inefficient and puts the burden 

of reporting on one person. 

7. Better guidance and quality control (on information received) is needed to 

obtain accurate data from all Federal agencies. 

Reply from the DOI BLM: 

1. The current report is difficult to categorize in terms of efforts of federal

agencies to engage in cooperative efforts with non‐governmental organizations

in order to develop standards. This seems to be a very worthwhile endeavor but

does not seem to be emphasized in any of the OMB Circular A‐119 reporting. 

DOI USGS: USGS would be interested in a NIST ‐‐ sponsored online forum to 

discuss the interpretation of NTTAA and OMB Circular A‐119. 

DOI BOR: Reclamation needs to continue to resurrect portions of the Design 

Standards that were sunset during the previous administration.

The use of voluntary consensus standards is extremely important in 

accomplishment of Reclamation's activities which are supported by

construction contracts. The standards are accessible and generally familiar to 

contractors. 

Reclamation is in the process of developing an enterprise approach with other 

bureaus in the Department of Interior (DOI) through the DOI Enterprise 

Geographic Information Management (EGIM) team. These efforts extend to 

geospatial data and services. Utilization of the Technical Resources Model

(TRM), associated Enterprise License Agreements (ELA), Services Reference 

Model (SRM), Data Reference Model (DRM), and integration of the Geospatial 

Blue Print the support for implementing standards is becoming more effective 

within the MP Region. These positively impact not only hardware and software 

acquisition, but are impacting geospatial data development. Standardization in 

data structures and services implemented and used in geospatial data 

development have the potential to reduce redundancy, loss of data,
D­100 

inappropriate and appropriate use of geospatial data and services. The 

standardization process can be augmented and improved upon through the 

assistance and greater involvement by voluntary standard organizations. These 

organizations have an established framework for review of proposed standards

with formal procedures for evaluation and review of existing standards. Greater participation with these organizations by both Reclamation and DOI 

staff should provide rapid development of appropriate standards for geospatial 

data structures and services. Having OPM request this level of participation 

from the DOI Bureaus will help support the participation, integration and 

utilization of standards that have the potential to save the federal government

time, effort, and funding in all Bureaus. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

Annual review of VCS; at least quarterly (4 times per year) for FWS standards, 

including all VCS and Government Unique Standards associated with adopted 

FWS standards. 

The BLM requested a review by the data stewards as to the data standards that 

are published in the metadata repository. The BLM also reviews new IT projects

to determine what new data standards might be proposed and will direct the 

proponents to any existing standards to ensure that no duplication or

redundant standards are allowed. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C
D­101 

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­102 

Department of Justice

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The Department, in its primary mission roles, does not specify products requiring 

voluntary consensus standards. Because of the nature of the Departments

missions, DOJ participates in the development of government standards for law

enforcement information representation. The Department developed the National

Information Exchange Model (NIEM) as a critical standard to facilitate the Law

Enforcement Information Sharing Program. NIEM serves as a government standard

for information that lacks voluntary consensus standards. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 0
D­103 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 1

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

n/a

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The Department of Justice offers no recommended changes to Circular A‐119. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

none 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; C

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; D

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No
D­104 

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
D­105 

Department of Labor 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The DOL develops and promulgates safety and health standards which are the 

minimum requirements for the protection of workers in the United States. DOL consults, and routinely relies on Voluntary Consensus Standards (VCS) 

whenever a Federal standard is written or updated. Since the VCS are on a 

shorter review cycle than Federal standards, the VCS provide a more current 

view of industry standards and practices than the Agency can efficiently or 

economically achieve. Furthermore, safety compliance officers use VCS during inspections and 

investigation when there are no Federal standards that apply to a certain

circumstance. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 5

1. Government Unique Standard: Electric Motor‐Drive Equipment Rule 

(Incorporated: 2001) 

Voluntary Standard

IEEE Standard 242‐1986 Recommended Practice for Protection and

Coordination of Industrial and Commercial Power Systems (IEEE Buff Book) 

and NFPA 70 ‐ national Electric Code 

Rationale 

The MSHA rule is a design‐specific standards. 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.
D­106 

2. Government Unique Standard: Exit Routes, Emergency Action Plans, and

Fire Prevention Plans, 29 CFR 1910, Subpart E (Incorporated: 2003) 

Voluntary Standard

Life Safety Code, NFPA 101‐2000 

Rationale 

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. 

3. Government Unique Standard: Fire Protection for Shipyards, 29 CFR Part 

1915, Subpart P (Incorporated: 2004) 

Voluntary Standard

NFPA 312‐2000 Standard for Protection of Vessels During Construction,

Repair, and Lay‐Up

NFPA 33‐2003 Standard for Spray Application Using Flammable or 

Combustible Materials

Rationale 

Many consensus standards were relied on for various provisions in OSHA's

final rule, including 15 consensus standards that are incorporated by

reference. However, OSHA and its negotiated rulemaking committee

determined that there was no, one consensus standard available that 

covered all the topics in the rule. 

4. Government Unique Standard: Sanitary Toilets in Coal Mines, 30 CFR 71, 

Subpart E (Incorporated: 2003)
D­107 

Voluntary Standard

Non‐Sewered Waste Disposal Systems‐‐Minimum Requirements, ANSI Z4.3‐ 

1987 

Rationale 

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 run‐ 

off could contaminate portions of the mine. 

5. Government Unique Standard: Steel Erection Standards (Incorporated: 

2002) 

Voluntary Standard

ANSI A10.13 ‐ Steel Erection; ASME/ANSI B30 Series Cranes Standards

Rationale 

Many consensus standards were relied upon for various provisions in the final 

rule, but there was no one consensus standard available that covered all of 

the topics covered by OSHA's final rule. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 1

Other Technical Standards: 0
D­108 

Rationale: MSHA published one final rule that used VCS. Rule: 30CFR part 57

Diesel Particulate Exposure of Underground Metal and Nonmetal Miners. VCS: 

ANSI Z‐88.2‐1969 American National Standards Practices for Respiratory

Protection, 1969. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 16 

Voluntary Consensus Standards Body Acronym

Acoustical Society of America ASA

American Industrial Hygiene Association AIHA 

American Ladder Institute ALI 

American National Standards Institute ANSI 

American Society of Mechanical Engineers ASME

American Society of Safety Engineers ASSE

American Society of Testing and Materials ASTM

American Welding Society AWS 

Association for Machine Technology AMT

Institute of Electrical and Electronic Engineers IEEE

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

National Fire Protection Association NFPA 

National Safety Council NSC

Society of Automotive Engineers SAE 

Underwriters Laboratories UL 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 52

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005.
D­109 

No comment at this time. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

No comment at this time. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No comment at this time. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; D

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
D­110 

Department of State 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The Department of State represents the U.S. at the International

Telecommunication Union (ITU) where international telecommunication 

standards are agreed. This role is performed by the Bureau of Economic &

Business Affairs, International Communications & Information Policy. The 

Department of State coordinates this work internally in the Government with 

other Agencies such as the FCC, Dept of Commerce/NTIA, and Dept of 

Homeland Security/NCS, and externally with US industry through the 

International Telecommunication Advisory Committee, a Federal Advisory

Committee. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 1
D­111 

Voluntary Consensus Standards Body Acronym

International Telecommunication Union ITU 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 8

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

We do not get involved with conformity testing directly. There have been cases

in which the delegations we lead to ITU have addressed conformity testing. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

No comment. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No comment. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

We are reporting only our involvement in the international telecommunications

standards development process not the procurement practices of the 

Department. The number 5 above is only a place holder. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]
D­112 

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; C

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; E

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­113 

Department of Transportation 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The U.S. Department of Transportation (DOT) and its operating administrations

rely upon an active consensus rulemaking program to support the Department's

primary mission, transportation safety. In addition, DOT relies upon a 

consensus process with various stakeholders to advance transportation 

technology and operational innovations, and to improve the state of 

transportation practice in all modes of transportation, in support of the 

Department's strategic objectives: safety, mobility, global connectivity, environmental stewardship, and security. Voluntary consensus standards, and

the technical interchanges that occur during the process of developing and 

revising codes and standards, are a foundational element for meeting DOT's 

objectives.

Among several case studies of standards success in 2005, two stand out: 

1) Federal Transit Administration (FTA): FTA works directly with the transit

industry and with related Standards Development Organizations to develop

voluntary consensus standards that increase safety of transit systems and

provide capital and operating cost savings. The goal in developing voluntary 

consensus standards is to give transit agencies the information that they need

to make wise decisions about what technology to use, what data to collect, and

what information to provide to their customers. 

The transit industry developed a business case that identified the benefits of 

using standards. Those identified benefits include: safety improvements, 

reduction of manufacturing costs, reduction of operating costs, advancement

of trade policy by providing standards that can guide markets outside the 

United States, and significant return on investments. For new vehicle 

procurement alone, senior transit vehicle manufacturing executives estimated 

that procurement costs can be reduced as much as five percent by using

standards. Assuming a constant rate of procurement investment over the next
D­114 

ten years, industry wide savings could amount to $2.64 billion. 

2) Federal Motor Carrier Safety Administration (FMCSA): FMCSA uses standards

in its safety regulations concerning the operation of commercial motor 

vehicles. An example of FMCSA’s use voluntary consensus standards is

incorporation‐by‐reference (49 CFR Part 393, Subpart I) of private‐sector 

manufacturing standards for cargo securing devices such as chain, wire rope, 

synthetic webbing, steel strapping, and cordage. FMCSA first adopted voluntary 

consensus standards for cargo securing devices in 1994 in response to a petition 

for rulemaking from the Commercial Vehicle Safety Alliance, an organization of 

Federal, State, and Provincial agencies in the United States, Canada and 

Mexico responsible for commercial motor vehicle safety. FMCSA subsequently

updated its incorporations‐by‐reference in its 2002 final rule on cargo securing. 

The 2002 final rule is the result of a multi‐year program to work with

government agencies and the private sector to develop uniform cargo securing 

regulations throughout North America, including the uniform incorporation of 

voluntary consensus standards regarding cargo securing devices. The new cargo

securing rules have generally been regarded by interested parties (the States 

and industry groups) as a significant enhancement of FMCSA's cargo securing 

standards. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 3

1. Government Unique Standard: 63 FR 17976; April 13, 1998 ‐ Product Safety 

Signs and Labels (Incorporated: 1998) 

Voluntary Standard

ANSI Z535.4 ‐ ANSI Requirements for Color Coded Header Messages for the 

Different Levels of Hazard

Rationale 

NHTSA explained in the NPRM that the American National Standard Institute 

(ANSI) has a standard4 for product safety signs and labels (ANSI Z535.4) that

identifies a hierarchy of hazard levels ranging from extremely serious to 

moderately serious and specifies corresponding hierarchies of signal words,
D­115 

i.e., “danger,” “warning,” and “caution,” and of colors. For the header, the 

ANSI standard specifies a red background with white text for “danger,” an 

orange background with black text for “warning,” and a yellow background

with black text for caution.” 

The ANSI standard specifies that pictograms should be black on white, with 

occasional uses of color for emphasis, and that message text should be black 

on white. The agency noted in the NPRM that when it earlier updated the 

requirements for air bag warning labels to require the addition of color and

pictograms, it had chosen not to adopt the colors specified in the ANSI 

standard. NHTSA chose to use yellow instead of orange in the background of 

the heading for the air bag warning label, even though the word “warning” 

was used, because of overwhelming focus group preference for yellow. Only

two of the 53 participants preferred orange. Participants generally stated 

that yellow was more eye‐catching than orange. Participants also noted that 

red (stop) and yellow (caution) had meaning to them, but not orange. 

NHTSA asked for comment on three color options for the revised utility 

vehicle rollover warning label. Proposed label 1 used the ANSI color format 

with the heading background in orange with the words in black. The 

remainder of the label had a white background with black text and drawings. Proposed label 2 used a color scheme like the air bag warning labels, which 

is the same as the ANSI color format except that the background color for 

the heading in the label is yellow. Proposed label 3 employed the color 

scheme used in the focus groups ‐ the heading area had a red background

with white text. The graphic areas had a yellow background with black and 

white drawings. The text area had a black background with yellow text. 

Despite focus group preference for the signal word “danger,” the agency

proposed the use of the word “warning” as more appropriate to the level of 

risk. The agency also noted that the word “warning” is used in the air bag 

warning label. 

Recognizing that it might encounter additional conflicts between focus group

preferences and the ANSI standard in future rulemakings, NHTSA requested
D­116 

comments in the NPRM on the extent to which any final choice regarding

colors and signal words should be guided by the focus group preferences

instead of the ANSI standard. NHTSA also requested comments on the

broader issue of the circumstances in which it would be appropriate for 

agency rulemaking decisions to be guided by focus group results or other 

information when such information is contrary to a voluntary consensus 

standard such as the ANSI standard. 

At this time (February 22, 1999), a final decision is still pending regarding its 

proposal to upgrade the rollover warning label. As to the general questions it 

posed in the NPRM, NHTSA recognizes that ANSI’s mission differs somewhat 

from that of the agency’s focus groups with respect to the labeling of 

hazardous situations. ANSI’s mission is to develop and maintain a standard

for communicating information about a comprehensive hierarchy of hazards, while the focus groups’ mission is to design an effective label for a specific 

hazard. The agency recognizes further that, given the difference in their 

missions, their conclusions about the appropriate manner of communication 

might differ on occasion. 

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. 

2. Government Unique Standard: Air Bag Warning Label (1997) (Incorporated: 

1997) 

Voluntary Standard

ANSI ISO 

Rationale 

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
D­117 

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 the industry standards. 

3. Government Unique Standard: Brake Performance, 49 CFR 393.52 ‐ FMCSA's

Performance‐Based Brake Testers (PBBTs) Requirement (Incorporated: 2002) 

Voluntary Standard

SAE J667 ‐ Brake Test Code Inertia Dynamometer (cancelled February 2002) 

SAE J1854 ‐ Brake Force Distribution Performance Guide ‐ Trucks and Buses 

Rationale 

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.
D­118 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 381

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 47 

Voluntary Consensus Standards Body Acronym

Aerospace Industries Association of America AIA 

American Association of Motor Vehicle 

Administrators

AAMVA 

American Association of State Highway and 

Transportation Officials

AASHTO 

American Gas Association AGA

American Institute of Aeronautics and Astronautics AIAA 

American National Standards Institute ANSI 

American Petroleum Institute API

American Public Transportation Association APTA 

American Pyrotechnics Association APA 

American Railway Engineering & Maintenance‐of‐

Way Association 

AREMA 

American Society for Nondestructive Testing ASNT 

American Society for Testing and Materials ASTM
D­119 

American Society of Civil Engineers ASCE

American Society of Mechanical Engineers ASME

American Trucking Associations ATA 

Association of American Railroads AAR 

Association of Public Health Laboratories APHL 

Canadian General Standards Board CGSB 

Canadian Standards Association CSA 

Chlorine Institute CI 

Commercial Vehicle Safety Alliance CVSA 

Compressed Gas Association CGA 

Gas Technology Institute GTI

Institute of Electrical and Electronic Engineers IEEE

Institute of Transportation Engineers ITE

Intelligent Transportation Society of America ITS America 

International Atomic Energy Agency IAEA 

International Civil Aviation Organization ICAO 

International Commission on Occupational Health ICOH 

International Maritime Organization IMO 

International Organization for Standardization ISO 

Manufacturers Standardization Society of the Valve 

and Fittings Industry 

MSSVFI 

NAFTA Land Transportation Standards Subcommittee NAFTA 

National Association of Corrosion Engineers

International

NACE

National Board of Boiler and Pressure Vessel

Inspectors

NBBPVI

National Committee on Uniform Traffic Control

Devices 

NCUTCD 

National Electrical Manufacturers Association NEMA 

National Fire Protection Association NFPA 

North American Transport of Dangerous Goods NATDGS
D­120 

Standards

Organization for Economic Cooperation and 

Development 

OECD 

Recreation Vehicle Industry Association RVIA 

Rehabilitation Engineering and Assistive Technology 

Society of North America 

RESNA 

Society of Automotive Engineers SAE 

Transportation Research Board TRB 

Truck Trailer Manufacturers Association TTMA 

United Nations Committee on the Transport of 

Dangerous Goods

UNTDG 

United Nations Economic Commission for Europe WP 

.29/GRSP 

UNECE

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 209

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

Federal Railroad Administration (FRA): Under 15 CFR Part 287.4(i): FRA’s

conformity assessment activities are visible internationally through expanded

efforts in the area of safe, uniform international transport of hazardous

materials by participation in the Canadian General Standards Board Tank Car 

Committee and the ASME Transportation Pressure Vessel Committee, as well as

continuing to participate in the North American Transport of Dangerous Goods

Standard (NATDGS) Working Group and the AAR Tank Car Committee. 

Under 15 CFR Part 287.4(j): Participation in the voluntary consensus standards

bodies listed above as well as in numerous committees and sub‐committees of 

those bodies gives FRA access to the developmental stages of private sector

conformity assessment standards to ensure that the agency viewpoint is

considered in the development of these standards.
D­121 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

DOT believes that Circular A‐119 is working effectively. The use of voluntary 

standards saves time and money for regulatory agencies, and for regulated 

entities and industries. Due to the effective implementation of the standards‐ 

related sections of the National Technology Transfer and Advancement Act 

(NTTAA), there is a low volume of government‐unique standards being used in 

lieu of voluntary consensus standards, especially when compared with the

status when NTTAA was passed in 1996. 

DOT recommends that OMB Circular A‐119 be amended to require NTTAA 

reporting on an exception basis only (only report instances of government‐ unique standards being used in lieu of voluntary consensus standards). 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

DOT offers no additional comments. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

The DOT operating administrations have pursued different approaches to the 

management of voluntary consensus standards with their sets of modal 

stakeholders. Document review, including standards included or incorporated

by reference, normally occurs no less frequently than every five years. 

Standards referenced in the Code of Federal Regulations are periodically

reviewed as part of the Section 610 reviews, and as a part of the continuing

rulemaking process, including petitions for rulemaking. Some operating 

administrations also have an internal regulatory effectiveness review function, 

which provides a further opportunity to review both voluntary consensus and

agency‐unique standards. These avenues allow for both ad‐hoc and periodic 

reviews.
D­122 

Standards incorporated into regulations for purposes of international

harmonization are generally reviewed and updated every two years.

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
D­123 

Department of the Treasury 

No report submitted.
D­124 

Department of Veterans Affairs

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

As a Federal Agency our mission is to promote healthcare to our Nations

Veterans. With the use of Standards it allows the Department to reduce cost, 

for services provided, and maintains compliance with guidelines in support of 

the Department's mission. The Department of Veterans Affairs enforces

participation in Standards compliance which eliminates the research process, 

increase of manpower, and the necessity for development of Government‐ unique standards which affects the Departments allocated budget resources. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 20 

Voluntary Consensus Standards Body Acronym
D­125 

American Industrial Hygiene Association AIHA 

American Institute of Timber Construction AITC

American National Metric Council ANMC

American National Standards Institute ANSI 

American Society for Testing and Materials ASTM

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

American Society of Safety Engineers ASSE

Builders Hardware Manufacturers Association BHMA 

Federal Facilities Council FFC

Government Electronics & Information Technology

Association 

GEITA 

Joint Commission on Accreditation of Healthcare 

Organizations

JCAHO 

NAFTA Land Transportation Standards Subcommittee NAFTA 

National Center for Vital and Health Statistics NCVHS 

National Committee for Information Technology

Standards

NCITS 

National Fire Protection Association NFPA 

National Institute for Occupational Safety and Health NIOSH 

National Institute of Building Sciences NIBS 

National Petroleum Management Association NPMA 

Society of Toxicological Pathologists STP

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 4

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005.
D­126 

The VA does not engage in conformity assessments activities. VA strives to use 

industry based standards and commercial off‐the‐shelf products. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The Department of Veterans Affairs has no comment or recommendations for 

changes at this time. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

The Department of Veterans Affairs has no comments at this time. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

The Veterans Health Administration accepts and conforms to standards

developed by the Joint Commission on Accreditation of Healthcare 

Organization (JCAHO) for Veterans Affairs (VA) healthcare facilities. Voluntary 

consensus standard requirements are utilized in the regulatory, contractual and

grants determinations executed by the Veterans Health Administration.

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; A

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes
D­127 

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 1
E­1

Appendix E – Individual, Unabridged Commission and other Agency Reports

Note:  This appendix contains the unabridged Commission and other agency reports as

they were submitted to NIST. Agency for International Development 

No report submitted.
E­2 

Consumer Product Safety Commission 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The U.S. Consumer Product Safety Commission is responsible for protecting the 

American public from unreasonable risks of injury and death from 15,000 types

of consumer products. Since its inception in 1973, the Commission has 

promoted the development of voluntary product safety standards to help it 

accomplish this mission. From 1990 through 2005, the Commission supported 

the development of 304 completed voluntary consensus safety standards while 

issuing 35 mandatory standards, a nearly nine‐to‐one ratio.

An example of the importance of voluntary safety standards in the achievement

of the Commission's mission is found in the case of baby walkers. Baby walkers

used to account for more injuries than any other type of nursery product. In 

1992 an estimated 25,700 children younger than 15 months of age were treated

in U.S. hospital emergency rooms for baby walker injuries, most related to falls

down stairs. CPSC staff worked with ASTM and the baby walker industry and a 

new ASTM safety standard was published in 1997. This standard called for

"gripping strips" under the walker base to stop the walker at the edge of a step. 

By 2003, the estimated number of baby walker injuries treated in hospital 

emergency rooms had dropped dramatically from 25,700 to 3,200, an 88%

reduction. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 2

1. Government Unique Standard: CPSC CFR Parts 1213, 1500, and 1513 

(Incorporated: 2000) 

Voluntary Standard

ASTM F1427‐96 

Rationale
E­3 

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. 

2. Government Unique Standard: FR/Vol. 68, No. 75/Friday, April 18, 2003, 

pp. 19142‐19147, Metal‐Cored Candlewicks Containing Lead and Candles

With Such Wicks (Incorporated: 2003) 

Voluntary Standard

Voices of Safety International (VOSI) standard on lead in candle wicks 

Rationale 

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, 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. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 28

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 8
E­4 

Voluntary Consensus Standards Body Acronym

American National Standards Institute ANSI 

American Society for Testing and Materials ASTM

American Society of Mechanical Engineers ASME

Canadian Standards Association CSA 

International 2‐Up ATV Manufacturers Association I2AMA 

National Fire Protection Association NFPA 

Specialty Vehicle Institute of America SVIA 

Underwriters Laboratories UL 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 28

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

None 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

During FY 2005, the Commission efforts to enhance voluntary safety standards

development was complemented by the overall Federal policy set forth in the 

Circular. There are no recommendations for changes in the Circular at this

time. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

The U.S. Consumer Product Safety Act (CPSA), as amended, requires the 

Commission to defer to issued voluntary standards, rather than promulgate 

mandatory standards, when the voluntary standards will eliminate or 

adequately reduce the risk of injury addressed and it is likely that there will be
E­5 

substantial compliance with the voluntary standards. In addition, the 

Commission is required, after any notice or advance notice of proposed

rulemaking, to provide technical and administrative assistance to persons or 

groups who propose to develop or modify an appropriate voluntary standard. Additionally, the Commission is encouraged to provide technical and

administrative assistance to groups developing product safety standards and 

test methods, taking into account Commission resources and priorities.

Since its inception in 1973, the Commission has promoted the development of 

voluntary product safety standards. Policy statements in support of voluntary 

standards were published by the CPSC in 1975 and 1978. These policy

statements were updated in 1988 (16 U.S.C. 1031), and a staff directive in 

implementation of portions of these policy statements was promulgated in 1989

and updated in October 2001. Since the principles set forth in the OMB Circular 

A‐119 were published, the Commission has consistently supported them. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

With regard to items 10.6 and 10.7, the Commission staff reviews

approximately four standards per year. The Commission reports on it voluntary 

consensus standards activities in its annual Performance and Accountability

Report. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; A
E­6 

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 1
E­7 

Environmental Protection Agency 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Standards are important to EPA in both our regulatory and our voluntary 

programs. 

Analytical test methods, particularly, are important for many EPA regulations. 

In any given year over half of the Agency's regulations include a section on how 

to sample or measure materials, emissions or other things in order to 

determine conformance to the overall requirements of the regulation. In some 

cases the test methods used are ones that were developed by EPA technical

experts with input from experts of the regulated community. The regulated

community sometimes prefers the use of these methods precisely because they

are designed with specific regulations in mind. Other times, the use of test 

methods developed through voluntary consensus bodies are more useful to both 

the purpose of the individual regulatory action and more acceptable to the 

regulated community. Generally (but not always) the latter is true where 

advances in technology or testing equipment is a significant factor in 

determining conformance to the regulation. EPA test methods are compiled

within the Code of Federal Regulations and thus are publicly available. 

EPA has a wide range of non‐regulatory programs that foster pollution 

prevention, energy conservation, public‐private partnerships and beyond‐ 

compliance activities that all add up to greater environmental protection and

improved human health. Voluntary standards play a key role in such programs

as Environmentally Preferable Purchasing, Energy Star, Environmental 

Management for Federal Facilities and Green Buildings. Our employees

participate in a wide range of private sector standards activities and work with 

counterparts from industry, education, non‐government organizations and

consumer groups to help develop voluntary standards for things such as

environmentally safe cleaning products and recyclable electronic products.

Standards organizations and industry not only welcome EPA participation but

seek out our experts so that standards which underpin U.S. manufacturing and
E­8 

products, and are sold world‐wide, benefit from an environmental perspective 

that often helps cost‐savings as well as the other legs of sustainability. 

EPA is pleased to be an active member of the American National Standards

Institute (ANSI), our U.S. National Standards Body and gateway to the 

International Organization for Standardization and the International

Electrotechnical Commission. Through ANSI, EPA is an active member and

leader in standards panels for nanotechnology and homeland security. Likewise 

EPA is proud to participate in the U.S. based international standards bodies 

such as ASTM, IEEE and ASME to name only a very few. Our standards activities

and associations all serve to help the Agency meet it's goals and obligations to 

provide the best for environmental protection and human health. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 50

1. Government Unique Standard: 40 CFR 89 ‐ Control of Emissions from New

and In‐Use Non‐Road Compression Ignition Engines (Incorporated: 1999) 

Voluntary Standard

ISO 8178 ‐ Reciprocating Internal Combustion Engines, Exhaust Emission 

Measurement

Rationale 

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. 

2. Government Unique Standard: 40 CFR 90 ‐ Control of Emission from Non‐ 

Road Spark Ignition Engines at or below 19KV (Incorporated: 1999) 

Voluntary Standard

ISO 8178 ‐ Reciprocating Internal Combustion Engines, Exhaust Emission 

Measurement

Rationale
E­9 

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. 

3. Government Unique Standard: 40 CFR 92 ‐ Control of Air Pollution from 

Locomotives and Locomotive Engines (Incorporated: 1999) 

Voluntary Standard

ISO 8178 ‐ Reciprocating Internal Combustion Engines, Exhaust Emission 

Measurement

Rationale 

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. 

4. Government Unique Standard: EPA Method 1 – Traverse Points, Stationary

Sources (Incorporated: 2001) 

Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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. Voluntary Standard

ASTM D3154‐91 (1995), Standard Method for Average Velocity in a Duct (Pitot 

Tube Method) 

Rationale
E­10 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

5. Government Unique Standard: EPA Method 10 ‐ Carbon Monoxide, NDIR 

(Incorporated: 1999) 

Voluntary Standard

ASTM D3162 (1994) Standard Test Method for Carbon Monoxide in the 

Atmosphere (Continuous Measurement by Non‐dispersive Infrared

Spectrometry) 

Rationale 

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). 

Voluntary Standard

CAN/CSA Z223.21‐M1978, Method for the Measurement of Carbon Monoxide: 

3—Method of Analysis by Non‐Dispersive Infrared Spectrometry

Rationale 

1. This standard 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, 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
E­11 

performance standard. 2. Is too general, too broad, or not sufficiently

detailed to assure compliance with EPA regulatory requirements. 

6. Government Unique Standard: EPA Method 101 ‐ Mercury Emissions, Chlor‐ Alkali Plants (Air) (Incorporated: 2001) 

Voluntary Standard

ASTM D6216‐98 ‐ Standard Practice for Opacity Monitor Manufacturers to 

Certify Conformance with Design and Performance Specifications. Rationale 

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. 

7. Government Unique Standard: EPA Method 101a ‐ Mercury Emissions

Sewer/Sludge Incinerator (Incorporated: 2001) 

Voluntary Standard

ASTM D6216‐98 ‐ Standard Practice for Opacity Monitor Manufacturers to 

Certify Conformance with Design and Performance Specifications. Rationale 

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. 

8. Government Unique Standard: EPA Method 10A – Carbon Monoxide for 

Certifying CEMS (Incorporated: 2001) 

Voluntary Standard

CAN/CSA Z223.21‐M1978, Method for the Measurement of Carbon Monoxide: 

3—Method of Analysis by Non‐Dispersive Infrared Spectrometry.
E­12 

Rationale 

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, 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. 

9. Government Unique Standard: EPA Method 12 – Inorganic Lead, Stationary

Sources (Incorporated: 2000) 

Voluntary Standard

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

Rationale 

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. 

Voluntary Standard
E­13 

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 

Rationale 

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. 

Voluntary Standard

ASTM E1979‐98 (1998), Standard Practice for Ultrasonic Extraction of Paint, 

Dust, Soil, and Air Samples for Subsequent Determination of Lead

Rationale 

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. 

10. Government Unique Standard: EPA Method 15 ‐ Hydrogen Sulfide/Carbon 

Disulfide/Carbon Sulfide (Incorporated: 1999) 

Voluntary Standard

ASME C00031 or PTC 19‐10‐1981 ‐ Part 10 Flue and Exhaust Gas Analyses

Rationale
E­14 

Too broad to be useful in regulatory sense. Covers Methods 3, 6, 7, and 15 

with variants. Voluntary Standard

ASTM D4323‐84 (1997) ‐ Standard Test Method for Hydrogen Sulfide in the 

Atmosphere by Rate of Change of Reflectance 

Rationale 

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. 

11. Government Unique Standard: EPA Method 1650 ‐ Organic Halides, Absorbable (AOX) (Incorporated: 1998) 

Voluntary Standard

ISO, DIN, SCAN, and Standard Methods (SM 5320) 

Rationale 

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. 

12. Government Unique Standard: EPA Method 17 ‐ Particle Matter (PM) In 

Stack Filtration (Incorporated: 2001) 

Voluntary Standard

ASME C00049 

Rationale 

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.
E­15 

Voluntary Standard

ASTM D3685/3685M‐95 ‐ Standard Test method for Sampling and

Determination of Particle Matter in Stack Gases

Rationale 

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. 

13. Government Unique Standard: EPA Method 18 ‐ VOC/GC (Incorporated: 

1999) 

Voluntary Standard

ASTM D6060‐96 (in review 2000) ‐ Practice for Sampling of Process Vents with 

a Portable Gas Chromatography

Rationale 

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. 

14. Government Unique Standard: EPA Method 180.1 ‐ Turbidity Nephelometric 

(Incorporated: 1999) 

Voluntary Standard

ISO 7027 ‐ Water Quality Determination of Turbidity

Rationale 

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. 

15. Government Unique Standard: EPA Method 2 – Velocity and S‐type Pitot 

(Incorporated: 1999)
E­16 

Voluntary Standard

ASTM 3796‐90 (1998), Standard Practice for Calibration of Type S Pitot Tubes

Rationale 

They are too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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. Voluntary Standard

ASTM D3154‐91 (1995), Standard Method for Average Velocity in a Duct (Pitot 

Tube Method) 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. Voluntary Standard

ASTM D3464‐96 (2001), Standard Test Method Average Velocity in a Duct 

Using a Thermal Anemometer 

Rationale 

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.

Voluntary Standard

ISO 10780:1994, Stationary Source Emissions‐‐ Measurement of Velocity and 

Volume Flowrate of Gas Streams in Ducts 

Rationale
E­17 

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. 

16. Government Unique Standard: EPA Method 21 ‐ Volatile Organic Compound

(VOC) Leaks (Incorporated: 2003) 

Voluntary Standard

ASTM E1211‐97 ‐ Standard Practice for Leak Detection and Location Using

Surface‐Mounted Acoustic Emission Sensors

Rationale 

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 against a primary

instrument. Background noise interference in some source situations could

also make this standard difficult to use effectively. 

17. Government Unique Standard: EPA Method 23 – Dioxin and Furan (PCDD and

PCDF) (Incorporated: 1999) 

Voluntary Standard

European Committee for Standardization (CEN) EN 1948‐3 (1997), 

Determination of the Mass Concentration of PCDD'S/PCDF'S‐‐Part 3: 

Identification and Quantification 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

18. Government Unique Standard: EPA Method 24 – Surface Coatings, Volatile 

Matter Content (Incorporated: 1998) 

Voluntary Standard
E­18 

ISO 11890‐1 (2000) part 1, Paints and Varnishes‐‐Determination of Volatile 

Organic Compound (VOC) Content‐Difference Method

Rationale 

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 

Celsius 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. Voluntary Standard

ISO 11890‐2 (2000) Part 2, Paints and Varnishes‐‐Determination of Volatile 

Organic Compound (VOC) Content‐Gas Chromatographic Method

Rationale 

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. 

19. Government Unique Standard: EPA Method 25 – Gaseous Nonmethane

Organic Emissions (Incorporated: 2001) 

Voluntary Standard

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

Rationale 

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. 

Voluntary Standard
E­19 

ISO 14965:2000(E) Air Quality‐‐Determination of Total Nonmethane Organic 

Compounds‐‐Cryogenic Preconcentration and Direct Flame Ionization Method

Rationale 

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. 

20. Government Unique Standard: EPA Method 25A – Gaseous Organic 

Concentration, Flame Ionization (Incorporated: 2001) 

Voluntary Standard

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

Rationale 

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. 

Voluntary Standard

ISO 14965:2000(E) Air Quality‐‐Determination of Total Nonmethane Organic 

Compounds‐‐Cryogenic Preconcentration and Direct Flame Ionization Method

Rationale 

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. 

21. Government Unique Standard: EPA Method 26 – Hydrogen Chloride, Halides, Halogens Emissions (Incorporated: 1999) 

Voluntary Standard
E­20 

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 

Rationale 

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. 

22. Government Unique Standard: EPA Method 26A – Hydrogen Halide and 

Halogen, Isokinetic (Incorporated: 1999) 

Voluntary Standard

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 

Rationale 

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.
E­21 

23. Government Unique Standard: EPA Method 28 (Section 10.1) – Wood

Heaters, Certificate and Auditing (Incorporated: 2003) 

Voluntary Standard

ASME Power Test Codes, Supplement on Instruments and Apparatus, part 5, 

Measurement of Quantity of Materials, Chapter 1, Weighing Scales

Rationale 

It does not specify the number of initial calibration weights to be used nor a 

specific pretest weight procedure. Voluntary Standard

ASTM E319‐85 (Reapproved 1997), Standard Practice for the Evaluation of 

Single‐Pan Mechanical Balances

Rationale 

This standard is not a complete weighing procedure because it does not 

include a pretest procedure. 

24. Government Unique Standard: EPA Method 29 – Metals Emissions from 

Stationary Sources (Incorporated: 2001) 

Voluntary Standard

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

Rationale 

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.
E­22 

Voluntary Standard

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 

Rationale 

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. 

Voluntary Standard

ASTM E1979‐98 (1998), Standard Practice for Ultrasonic Extraction of Paint, 

Dust, Soil, and Air Samples for Subsequent Determination of Lead

Rationale 

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. 

Voluntary Standard

CAN/CSA Z223.26‐M1987, Measurement of Total Mercury in Air Cold Vapour 

Atomic Absorption Spectrophotometeric Method

Rationale 

It lacks sufficient quality assurance and quality control requirements

necessary for EPA compliance assurance requirements.
E­23 

25. Government Unique Standard: EPA Method 2C – Velocity and Flow Rate, 

Standard Pitot (Incorporated: 1999) 

Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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. 

26. Government Unique Standard: EPA Method 3 – Molecular Weight Carbon 

Dioxide, Oxygen (Incorporated: 1999) 

Voluntary Standard

ASME C00031 or PTC 19‐10‐1981‐‐part 10, "Flue and Exhaust Gas Analyses" 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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.
E­24 

2. They are too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

27. Government Unique Standard: EPA Method 306 ‐ Chromium Emissions, Electroplating and Anodizing (Incorporated: 2002) 

Voluntary Standard

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

Rationale 

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). 

28. Government Unique Standard: EPA Method 306a ‐ Chromium Emissions, Electroplating ‐‐ Mason Jar (Incorporated: 2002) 

Voluntary Standard

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

Rationale 

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
E­25 

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). 

29. Government Unique Standard: EPA Method 320 – Vapor Phase Organic and

Inorganic Emissions, FTIR (Incorporated: 1999) 

Voluntary Standard

ASTM D6348‐98, Determination of Gaseous Compounds by Extractive Direct 

Interface Fourier Transform (FTIR) Spectroscopy

Rationale 

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. 

30. Government Unique Standard: EPA Method 3A – Carbon Dioxide and Oxygen 

Concentrations, IAP (Incorporated: 1999) 

Voluntary Standard

ASTM D5835‐95, Standard Practice for Sampling Stationary Source Emissions

for Automated Determination of Gas Concentration 

Rationale
E­26 

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. Voluntary Standard

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

Rationale 

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. Voluntary Standard

ISO 10396:1993, Stationary Source Emissions: Sampling for the Automated

Determination of Gas Concentrations

Rationale 

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
E­27 

recording intervals (digital and analog recorders, only). 2. Is too general, too 

broad, or not sufficiently detailed to assure compliance with EPA regulatory

requirements. Voluntary Standard

ISO 12039:2001, Stationary Source Emissions‐‐ Determination of Carbon 

Monoxide, Carbon Dioxide, and Oxygen‐‐Automated Methods

Rationale 

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. 

31. Government Unique Standard: EPA Method 3B – Oxygen, Carbon Dioxide, 

Carbon Monoxide, Emission Rate Correction Factor (Incorporated: 1999) 

Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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. Voluntary Standard

ASTM D3154‐91 (1995), Standard Method for Average Velocity in a Duct (Pitot 

Tube Method)
E­28 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

32. Government Unique Standard: EPA Method 4 – Moisture Content in Stack 

Gases (Incorporated: 1999) 

Voluntary Standard

ASTM D3154‐00, Standard Method for Average Velocity in a Duct (Pitot Tube 

Method) 

Rationale 

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. Voluntary Standard

ASTM D3154‐91 (1995), Standard Method for Average Velocity in a Duct (Pitot 

Tube Method) 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. Voluntary Standard

ASTM E337‐84 (1996), Standard Test Method for Measuring Humidity with a 

Psychrometer (the Measurement of Wet‐ and Dry‐Bulb Temperatures) 

Rationale 

They are too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements.
E­29 

33. Government Unique Standard: EPA Method 5 – Particulate Matter, 

Stationary Sources (Incorporated: 1999) 

Voluntary Standard

ASME PTC‐38‐80 R85 or C00049, Determination of the Concentration of 

Particulate Matter in Gas Streams 

Rationale 

It lacks sufficient quality assurance and quality control requirements

necessary for EPA compliance assurance requirements. 

Voluntary Standard

ASTM D3685/D3685M‐98, Test Methods for Sampling and Determination of 

Particulate Matter in Stack Gases

Rationale 

It lacks sufficient quality assurance and quality control requirements

necessary for EPA compliance assurance requirements. 

Voluntary Standard

ISO 9096:1992, Determination of Concentration and Mass Flow Rate of 

Particulate Matter in Gas Carrying Ducts‐‐ Manual Gravimetric Method

Rationale 

It lacks sufficient quality assurance and quality control requirements

necessary for EPA compliance assurance requirements. 

34. Government Unique Standard: EPA Method 515.1 ‐ Chlorinated Acids in 

Water by CC/ECD (Incorporated: 1998) 

Voluntary Standard

Standard Methods 6640B 

Rationale 

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 contamination. EPA 

plans to offer to work with the Standard Methods committee to resolve this

issue prior to the next publication.
E­30 

35. Government Unique Standard: EPA Method 515.4 – Chlorinated Acids in DW

by LL Fast CG/ECD (Incorporated: 2003) 

Voluntary Standard

ASTM D5317‐98 ‐‐ Standard Test Method For Determination of Chlorinated

Organic Acid Compounds in Water by Gas Chromatography With an Electron 

Capture Detector 

Rationale 

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. Voluntary Standard

Standard Method 6640 B for the chlorinated acids

Rationale 

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. 

36. Government Unique Standard: EPA Method 531.2 – N‐ Methylcarbamoylozimes/ates, Aqueous In/HPLC (Incorporated: 2003) 

Voluntary Standard

Standard Method 6610, 20th Edition 

Rationale
E­31 

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. Voluntary Standard

Standard Method 6610, 20th Supplemental Edition 

Rationale 

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. 

37. Government Unique Standard: EPA Method 5i ‐ Low Level Particulate 

Matter, Stationary Sources (Incorporated: 2001) 

Voluntary Standard

ASTM D6331‐98
E­32 

Rationale 

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. 

38. Government Unique Standard: EPA Method 6 ‐ Sulphur Dioxide Emissions

(Incorporated: 1999) 

Voluntary Standard

ASME C00031 or PTC 19‐10‐1981 ‐ Part 10 Flue and Exhaust Gas Analyses

Rationale 

Too broad to be useful in regulatory sense. Covers Methods 3, 6, 7, and 15 

with variants. Voluntary Standard

ISO 11632:1998 ‐ Stationary Source Emissions ‐ Determination of the Mass

Concentration of Sulfur Dioxide ‐ Ion Chromatography

Rationale 

ISO 11632:1998 ‐ Stationary Source Emissions ‐ Determination of the Mass

Concentration of Sulfur Dioxide ‐ Ion Chromatography

Voluntary Standard

ISO 7934:1998 ‐ Stationary Source Emissions ‐ Determination of the Mass

Concentration of Sulfur Dioxide ‐ Hydrogen Peroxide/Barium Perchlorate/ 

Thorin Method

Rationale 

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 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. 

39. Government Unique Standard: EPA Method 6c ‐ Sulphur Dioxide Emissions

Stationary by IAP (Incorporated: 1999) 

Voluntary Standard
E­33 

ASTM D5835‐95 ‐ Standard Practice for Sampling Stationary Source Emissions

for Automated Determination of Gas Concentration 

Rationale 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance and quality control requirements. Very similar to ISO 

10396. 

Voluntary Standard

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 Streams

Rationale 

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. Voluntary Standard

ISO 10396:1993 ‐ Stationary Source Emissions: Sampling for the Automated

Determination of Gas Concentrations

Rationale 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance plus quality control requirements. Similar to ASTM D5835. 

40. Government Unique Standard: EPA Method 7 ‐ Nitrogen Oxide Emissions

Stationary Sources (Incorporated: 1999) 

Voluntary Standard

ASME C00031 or PTC 19‐10‐1981 ‐ Part 10 Flue and Exhaust Gas Analyses

Rationale 

Too broad to be useful in regulatory sense. Covers Methods 3, 6, 7, and 15 

with variants. 

41. Government Unique Standard: EPA Method 7e ‐ Nitrogen Oxide, 

Instrumental (Incorporated: 1999) 

Voluntary Standard
E­34 

ASTM D5835‐95 ‐ Standard Practice for Sampling Stationary Source Emissions

for Automated Determination of Gas Concentration 

Rationale 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance and quality control requirements. Very similar to ISO 

10396. 

Voluntary Standard

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 Streams

Rationale 

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. Voluntary Standard

ISO 10396:1993 ‐ Stationary Source Emissions: Sampling for the Automated

Determination of Gas Concentrations

Rationale 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance plus quality control requirements. Similar to ASTM D5835. 

42. Government Unique Standard: EPA Method ALT 004 (Incorporated: 2002) 

Voluntary Standard

ASTM D5835‐95 ‐ Standard Practice for Sampling Stationary Source Emissions

for Automated Determination of Gas Concentration 

Rationale 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance and quality control requirements. Very similar to ISO 

10396. 

Voluntary Standard

ISO 10396:1993 ‐ Stationary Source Emissions: Sampling for the Automated

Determination of Gas Concentrations

Rationale
E­35 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance plus quality control requirements. Similar to ASTM D5835. 

43. Government Unique Standard: EPA Method CTM 022 (Incorporated: 2002) 

Voluntary Standard

ASTM D5835‐95 ‐ Standard Practice for Sampling Stationary Source Emissions

for Automated Determination of Gas Concentration 

Rationale 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance and quality control requirements. Very similar to ISO 

10396. 

Voluntary Standard

ISO 10396:1993 ‐ Stationary Source Emissions: Sampling for the Automated

Determination of Gas Concentrations

Rationale 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, CTM 022. Lacks in detail and 

quality assurance plus quality control requirements. Similar to ASTM D5835. 

44. Government Unique Standard: EPA Method GG – (Title not found in index) 

(Incorporated: 2003) 

Voluntary Standard

ASTM D3031‐81 – Method of Test for Total Sulfur in Natural Gas 

(Hydrogenation), Withdrawn

Rationale 

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
E­36 

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. 

45. Government Unique Standard: EPA Performance Specification 2 (nitrogen 

oxide portion only) (Incorporated: 2001) 

Voluntary Standard

ISO 10849:1996, Determination of the Mass Concentration of Nitrogen Oxides‐ 

‐Performance 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

46. Government Unique Standard: EPA Performance Specification 2 (sulfur 

dioxide portion only) (Incorporated: 2001) 

Voluntary Standard

ISO 7935:1992, Stationary Source Emissions‐‐Determination of the Mass

Concentration of Sulfur Dioxide‐‐Performance Characteristics of Automated

Measuring Methods" 

Rationale 

Is too general, too broad, or not sufficiently detailed to assure compliance 

with EPA regulatory requirements. 

47. Government Unique Standard: EPA Performance Specifications 11 ‐ 

Particulate Matter Continuous Monitoring System (Incorporated: 1999) 

Voluntary Standard

ISO 10155:1995 ‐ Stationary source emissions. Automated monitoring of mass

concentration of particles ‐ Performance characteristics, test methods and 

specifications. Rationale
E­37 

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 

PM CEMS performance specification similar to EPA Performance Specification 

11, but does not contain detailed RATA procedures. Also, EPA doesn’t have a 

final performance specification to compare this to.

48. Government Unique Standard: GLI Method 2 (Incorporated: 1999) 

Voluntary Standard

ISO 7027 ‐ Water Quality Determination of Turbidity

Rationale 

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. 

49. Government Unique Standard: Standard Method 2130B (Incorporated: 1999) 

Voluntary Standard

ISO 7027 ‐ Water Quality Determination of Turbidity

Rationale 

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. 

50. Government Unique Standard: SW846‐6010b (Incorporated: 2002) 

Voluntary Standard

ASTM C1111‐98 (1998) ‐ Standard Test Method for Determining Elements in 

Waste Streams by Inductively Coupled Plasma‐Atomic Emission 

Spectrometers
E­38 

Rationale 

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. Voluntary Standard

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

Rationale 

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. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 1384

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 26
E­39 

Voluntary Consensus Standards Body Acronym

Acoustical Society of America ASA

American Architectural Manufacturers Association AAMA 

American Association of Motor Vehicle 

Administrators

AAMVA 

American College of Radiology ACR 

American Gas Association AGA

American National Standards Institute ANSI 

American Petroleum Institute API

American Society for Testing and Materials ASTM

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

American Society of Quality Control ASQC

American Water Works Association AWWA

Building Officials and Code Administrators

International

BOCA 

Electronic Industries Alliance EIA 

Illuminating Engineering Society of North America IES 

Institute of Electrical and Electronic Engineers IEEE

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

National Cooperation for Laboratory Accreditation NACLA

NSF International NSFI 

Organization for Economic Cooperation and 

Development 

OECD 

Society of Automotive Engineers SAE 

undefined ‐‐SELECT‐‐ Underwriters Laboratories UL 

United Nations Economic Commission for Europe WP 

.29/GRSP 

UNECE
E­40 

United States Pharmacopoeia USP

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 52

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

NACLA, INELA

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

We need feed‐back from the regulated community on use of VCSs since the 

NTTAA and OMB Circular A119: have they made any difference in facilitating

conformance to regulatory requirements? In the last five years there has been 

only two comments to EPA regulations, published in the Federal Register ‐‐ and 

keep in mind we publish nearly 1000 regulation announcements per year ‐‐ 

regarding the technical standards sections of regulations. Comments on our 

regulations focus on the intent and extent of the what is being regulated not on 

the test methods used. It is difficult to determine how important or significant

the OMB Circular is to the purpose of EPA regulations. This in turn makes it 

difficult to know how to evaluate the effectiveness of the Circular. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

We had 11 new uses of VCSs in regulations this year. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

The reporting system currently requires a numerical response to question 10‐5. 

Although the number is meaningless in terms of this Agency's policies and 

operations, we have included "0" here so that this report is not automatically
E­41 

rejected by the system as incomplete. 

EPA reviews standards when there is a regulatory issue or problem that requires 

such a review; in response to public comment on a proposed or final regulation; 

or in the event that some other reason causes the Agency to re‐open a final

regulation and there is then an opportunity to review referenced standards. In 

the broadest sense, EPA does not have a regular schedule for review but does

so on an as‐needed basis. 

NIST is working with EPA and other federal agencies to identify small system

glitches such as this and fix them. EPA greatly appreciates all the assistance 

and friendly help from NIST as we prepare and submit our annual report. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
E­42 

Federal Communications Commission 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

FCC standards are based on recommendations from IEEE, ANSI and NCRP. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 0

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 0

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005.
E­43 

N/A 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

N/A 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

FCC guidelines for RF safety are stated in 47 CFR 1.1307(b)(4) & (b)(5) 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; D

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 10
E­44 

Federal Trade Commission 

Title: Federal Trade Commission (FTC) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The Federal Trade Commission is an independent agency of the United States 

Government charged with enforcing competition and consumer protection laws. The Commission's only contact with voluntary consensus standards and the 

organizations that produce them is in connection with the enforcement of the 

Federal Trade Commission Act, which prohibits unfair methods of competition 

and unfair or deceptive acts and practices affecting commmerce. The Commision 

does not promulgate its own standards or engage in the other standards activities 

pertinent to OMB Circular A‐119. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale:
E­45 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 0

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 0

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

See response to question 1. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

See response to question 1. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

N/A 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; C

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; E
E­46 

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
E­47 

General Services Administration 

Title: General Services Administration (GSA) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Standards play a significant role in our program. They are used to establish 

baselines for product quality, performance and features; allow competitive 

procurement of functionally equivalent products and; when necessary, ensure 

interchangeability of products produced under different contracts and across

different contract periods. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 8

1. Government Unique Standard: Federal Specification A‐A‐1922 ‐ Shield, Expansion (Caulking Anchors, Single Lead) (Incorporated: 2004) 

Voluntary Standard

ASTM E488 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

This government‐unique standard is prepared & maintained by the Defense 

Logistics Agency (DLA). Both the GSA & DLA contract for products that

reference A‐A‐1922. In order to maintain product continuity in the Federal

marketplace, we must cite the standard as the DLA. 

2. Government Unique Standard: Federal Specification A‐A‐1923 ‐ Shield

Expansion (Lag, Machine and Externally Threaded Wedge Bolt Anchors) 

(Incorporated: 2004) 

Voluntary Standard
E­48 

ASTM E488 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

This government‐unique standard is prepared & maintained by the Defense 

Logistics Agency (DLA). Both the GSA & DLA contract for products that

reference A‐A‐1923. In order to maintain product continuity in the Federal

marketplace, we must cite the standard as the DLA. 

3. Government Unique Standard: Federal Specification A‐A‐1924 ‐ Shield, Expansion (Self Drilling Tubular Expansion Shell Bolt Anchors) (Incorporated: 

2004) 

Voluntary Standard

ASTM E488 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

This government‐unique standard is prepared & maintained by the Defense 

Logistics Agency (DLA). Both the GSA & DLA contract for products that

reference A‐A‐1924. In order to maintain product continuity in the Federal

marketplace, we must cite the standard as the DLA. 

4. Government Unique Standard: Federal Specification A‐A‐1925 ‐ Shield, Expansion (Nail Anchors) (Incorporated: 2000) 

Voluntary Standard

ASTM E488 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

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

marketplace, we must cite the standard as the DLA.
E­49 

5. Government Unique Standard: Federal Specification A‐A‐59486 ‐ Padlock 

Set (Individually Keyed or Keyed Alike) (Incorporated: 2004) 

Voluntary Standard

ASTM F883 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

Commercial Item Descriptions A‐A‐59486 contain military specific 

requirements that are not present in ASTM F883. Military agencies are a 

primary customer of our agency and they are mandated to use padlocks 

procured via conformance to the GUS. 

6. Government Unique Standard: Federal Specification A‐A‐59487 ‐ Padlock 

(Key Operated) (Incorporated: 2004) 

Voluntary Standard

ASTM F883 ‐ Standard Test Methods for Strength of Anchors in Concrete and

Masonry Elements

Rationale 

Commercial Item Descriptions A‐A‐59487 contain military specific 

requirements that are not present in ASTM F883. Military agencies are a 

primary customer of our agency and they are mandated to use padlocks 

procured via conformance to the GUS. 

7. Government Unique Standard: Federal Specification KKK‐A‐1822E ‐ Federal

Specification for Ambulances (Incorporated: 2003) 

Voluntary Standard

ASTM F2020 ‐ Standard Practice for Design, Construction, and Procurement

of Emergency Medical Services Ambulances

Rationale 

The ASTM Standard Practice for Design, Construction, and Procurement of 

Emergency Medical Services (EMSS) Ambulances (ASTM F2020) is not practical
E­50 

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 EMS Directors (NASEMSD) and the National Association of 

EMS Physicians universally accept and support the continued use of the
E­51 

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. 

8. Government Unique Standard: MIL‐G‐9954 ‐ Glass Beads for Cleaning and 

Peening (Incorporated: 2000) 

Voluntary Standard

SAE/AMS 2431 ‐ Peening Media, General Requirements 

Rationale 

This government‐unique standard contains specific size & performance 

required for Air Force critical applications that are not present in the

voluntary standards. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question.
E­52 

Voluntary Consensus Standards: 516

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 25 

Voluntary Consensus Standards Body Acronym

Aerospace Industries Association of America AIA 

Aerospace Material Standards AMS 

Ambulance Manufacturers Division AMD 

American Gas Association AGA

American National Standards Institute ANSI 

American Society for Testing and Materials ASTM

American Society of Heating, Refrigerating, and Air‐ 

Conditioning Engineers

ASHRAE

American Society of Mechanical Engineers ASME

Automotive Lift Institute ‐ ALOIM ALI 

Builders Hardware Manufacturers Association BHMA 

Composite Panel Association CPA 

Gas Applicance Manufacturers Association GAMA 

International Organization for Standardization ISO 

Kitchen Cabinet Manufacturers Association KCMA 

National Aerospace and Defence Contractors

Accreditation Program

NADCAP 

National Electrical Manufacturers Association NEMA 

National Fire Protection Association NFPA 

National Truck Equipment Association NTEA 

Performance Review Institute PRI

Society of Automotive Engineers SAE 

Technical Association of the Pulp and Paper Industry TAPPI
E­53 

The Business and Institutional Furniture 

Manufacturer's Association 

BIFMA 

The Manitenance Council of American Trucking 

Association 

TMC/ATA 

The Society for Protective Coatings SSPC

Underwriters Laboratories UL 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 22

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

A variety of conformity assessment activities were used including direct 

inspection and testing, supplier and third party testing, and product 

qualification and listing. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

Somewhat effective. Needs to be significantly simplified for ease of response. 

Needs to contain a more direct and simplified questions to the point. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No comments. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]
E­54 

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; C

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 1
E­55 

Government Printing Office

Title: Government Printing Office (GPO) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Standards are very important in our acquisition process as well as other 

services that are provided such as in IT and engineering. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 1

1. Government Unique Standard: "standard samples" for the procurement of 

printing paper (Incorporated: 2005) 

Voluntary Standard

None 

Rationale 

Physical samples are required for procurement of printing papers. There is

no consensus body to develop such a set. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0
E­56 

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 0

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 0

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

0 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The GPO is a Congressional agency and as such is not required to follow the 

circular to the letter. However, since the GPO provides services for executive 

agencies, the Agency acknowledges the definitions set out in the circular. The 

circular is important to us because of our use of standards in our acquisition 

programs. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

None 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

We have no set Agency‐wide program

10‐1. Removed [This question has been deprecated for 2005]
E­57 

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; C

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; E

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
E­58 

National Aeronautics and Space Administration 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

The NASA Technical Standards Program is one of the key elements in the

achievement of NASA’s Mission and serves all of the Agency's Programs, Projects, and Facilities. The Technical Standards Program's Website accessible 

at http://standards.nasa.gov provides direct access to standards from many 

sources to NASA personnel for use in research, development, testing, and

procurement. Standards not only provide the basis for ensuring the capability

and reliability of systems, but are also the basis of cooperative space activities 

with other organizations. Use of voluntary consensus standards does appear to 

result in savings in development time and costs, avoiding duplication of private 

sector activities, improved collaboration and cooperation with the private 

sector, and increased goodwill for the Federal government. Savings from use of 

VCS allow NASA to effectively apply resources to other internal activities and 

provide safe, quality systems and operations. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 

This agency reports voluntary consensus standards usage on a category basis

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 1 

Voluntary Standard Government Standard

AIAA Guide 095‐2004, Guide to Safety of Hydrogen 

and Hydrogen System

NASA Safety Standard (NSS) 

1740.15, Safety Standard

for Hydrogen and Hydrogen 

Systems
E­59 

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 195

Other Technical Standards: 0

Rationale: A total of 195 new VCS was added to the NASA Preferred Technical

Standards list. Note that NASA uses the “categorical” method of reporting and 

lists only the number of new standards added each year. NASA also downloaded

over 50,000 VCS's from the NASA Technical Standards System for use on 

Programs and Projects) 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 31 

Voluntary Consensus Standards Body Acronym

Acoustical Society of America ASA

Aerospace Industries Association of America AIA 

American Institute of Aeronautics and Astronautics AIAA 

American National Standards Institute ANSI 

American Society for Nondestructive Testing ASNT 

American Society For Quality ASQ

American Society for Testing and Materials ASTM

American Society of Agricultural Engineers ASAE

American Society of Mechanical Engineers ASME

American Society of Metals ASM 

American Welding Society AWS 

Consultative Committee for Space Data Systems CCSDS 

Electronic Industries Alliance EIA 

Illuminating Engineering Society of North America IES
E­60 

Institute for Interconnecting and Packaging

Electronic Circuits 

IPEC

Institute of Electrical and Electronic Engineers IEEE

Institute of Environmental Sciences & Technology IEST 

Interconnection Technology Research Institute ITRI

International Astronomical Union IAU 

International Electrotechnical Commission IEC

International Organization for Standardization ISO 

Internet Society ISOC

National Association of Corrosion Engineers

International

NACE

National Conference of Standards Laboratories NCSL

National Fire Protection Association NFPA 

National Hydrogen Association NHA 

Organization for the Advancement of Structured

Information Standards

OASIS 

Radio Technical Commission for Aeronautics RTCA 

Society of Automotive Engineers SAE 

Space Frequency Coordination Group SFCG 

Telecommunications Industry Association TIA 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 172

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

NASA's Office of Safety and Mission Assurance conducts conformity assessments 

internal to NASA at the Agency level via its audits, assessments, and reviews

processes according to NASA Procedural Requirements (NPR) 8705.6, “Safety

and Mission Assurance Audits, Assessments, and Reviews”. Conformity
E­61 

assessments of NASA contractors are based on requirements of NASA Policy

Directive (NPD) 8730.5 and the NASA Quality Policy. In addition, NASA routinely

utilizes other government agencies to assist with Contract Administration 

Services, including substantial conformity assessment activities. The Defense 

Contract and Audit Agency, Defense Contract Management Agency, Office of 

Naval Research, and other activities continue to provide conformity assessment 

services for NASA Programs. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

NASA's efforts to enhance the use of non‐government Standards Developing

Organizations’ Voluntary Consensus Standards continue to be stimulated by the 

guidance and directives provided in OMB Circular A‐119. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

None 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

The Agency reports its usage of non‐government Standards Developing

Organizations’ Voluntary Consensus Standards on a categorical basis. A listing 

of the 1,564 VCSs endorsed by the Agency as NASA Preferred Technical

Standards may be obtained from http://standards.nasa.gov. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes
E­62 

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; C

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 5
E­63 

National Archives and Records Administration 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

ISO 15489 is used as a framework for much of NARA's Federal Records

Management Training. As agencies develop requirements for record series and

systems, ISO 15489 provides a systematic strategy for capturing and

maintaining records, regardless of media or format. In addition, the standard

defines characteristics needed to support a trustworthy recordkeeping system. 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 1

1. Government Unique Standard: NARA data standard (Incorporated: 2000) 

Voluntary Standard

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)); 

Encoded Archival Description (EAD); 

Machine Readable Cataloging (MARC) 

Rationale 

These voluntary standards do not meet the precise needs of the agency. 

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question.
E­64 

Voluntary Consensus Standards: 89

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 10 

Voluntary Consensus Standards Body Acronym

American Society for Testing and Materials ASTM

Association for Information and Image Management AIIM

Consultative Committee for Space Data Systems CCSDS 

Federal Geographic Data Committee FGDC

Institute of Electrical and Electronic Engineers IEEE

International Council on Archives ICA 

International Organization for Standardization ISO 

National Fire Protection Association NFPA 

National Information Standards Organization NISO 

Society of American Archivists SAA

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 16

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

NARA did not participate in any conformity assessment activities in FY 2005. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

We believe the Circular is working effectively and have no recommendations

for changes.
E­65 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

Rationale for the use of GUS (question 2): 

NARA has combined elements of these standards, because no one standard was 

designed to meet our descriptive needs, for example: 

1. Some of these standards are library standards, not archival standards, and

thus were not wholly suitable; 

2. Some of these standards dictate a physical design solution that NARA does

not find technically sound; 

3. Some of these standards focus on personal papers collections, not 

government records. 

It should also be understood that the archival description standard is a standard

that NARA is using for description of its own holdings, not a standard imposed

on the external world. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; No

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; A

10‐6. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; Yes

10‐7. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 3
E­66 

National Science Foundation 

Title: National Science Foundation (NSF) Fiscal Year 2005 Agency Report 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

NSF's involvement in standards‐related activities is primarily through staff 

participation in national and international organizations that set voluntary 

consensus standards for industry.

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 0

Other Technical Standards: 0

Rationale: We have not used any Voluntary Consensus Standards. 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 4 

Voluntary Consensus Standards Body Acronym

American Society for Testing and Materials ASTM

IEEE ‐ Bioinformatics Standards Committee BSC/IEEE
E­67 

International Telecommunication Union ITU 

National Spectrum Managers Association NSMA 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 4

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

None. 

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

Circular A‐119 is effective. We do not recommended any change. 

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No comments. 

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

No comment. 

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes
E­68 

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; E

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10‐5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
E­69 

Nuclear Regulatory Commission 

1. Please describe the importance of standards in the achievement of your agency's 

mission, how your agency uses standards to deliver its primary services in support of 

its mission, and provide any examples or case studies of standards success: 

Utilization of consensus codes and standards by the NRC provides effective 

replacements for NRC‐generated regulations. Within the framework of Public 

Law 104‐113, NRC performs reviews of its regulations and regulatory guidance 

to determine which regulations can be replaced by consensus standards. The 

NRC participates on many codes and standards development committees to 

provide staff input and guidance to help assure published codes and standards

can be endorsed in the regulatory process. Contributing to the technical bases

for national and international codes and standards is an important part of the 

regulatory process. The outcomes of these efforts significantly increase the

assurance that published codes and standards can be endorsed in lieu of using

NRC developed technical basis products, such as regulations, regulatory guides, or staff review guidance. 

An example of a standards success for NRC involves the endorsement of the 

Sections III (Construction of Nuclear Facility Components) and XI (In‐service 

Inspection of Nuclear Power Plant Components) of the American Society of 

Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and the ASME

Code for Operation and Maintenance of Nuclear Power Plants (In‐service 

Testing of Nuclear Facility Pumps and Valves) in our regulations and regulatory

guidance. These ASME Codes are developed through the consensus process, and

endorsement of the ASME Code by the NRC provides a method of incorporating 

rules into the regulatory process that are acceptable to the NRC and have 

received industry participation in their development. If the NRC did not take 

action to endorse the ASME Code, the NRC would either have to independently

develop standards for construction, in‐service inspection (ISI), and in‐service 

testing (IST) of Nuclear Power Plant Components or establish the acceptable 

standards and methods for construction, ISI, and IST on a case‐by‐case basis.
E­70 

2. Please list the government‐unique standards your agency used in lieu of voluntary

consensus standards during FY 2005: 0

3. Please list the Voluntary Consensus Standards (VCS) your agency substituted for 

Government Unique Standards (GUS) in FY 2005 as a result of review under Section 

15(b)(7) of OMB Circular A‐119: 0

4. Please provide the total number of Voluntary Consensus Standards your agency used

during FY 2005: Optional: If possible, also please provide the total number of Non‐ 

consensus Standards that are developed in the private sector your agency used during

FY 2005. In addition, please provide your agency's rationale for using the Non‐

consensus Standards that are developed in the private sector counted in this question. 

Voluntary Consensus Standards: 1

Other Technical Standards: 0

Rationale: 

5. Please enter the Voluntary Consensus Standards Bodies (VCSB) in which your agency

participated in during FY 2005: 15 

Voluntary Consensus Standards Body Acronym

American Concrete Institute ACI 

American Institute of Steel Construction AISC

American National Standards Institute ANSI 

American Nuclear Society ANS 

American Society for Testing and Materials ASTM

American Society of Civil Engineers ASCE

American Society of Mechanical Engineers ASME

Health Physics Society HPS 

Institute of Electrical and Electronic Engineers IEEE

Institute of Nuclear Materials Management INMM

Instrumentation Society of America ISA 

International Electrotechnical Commission IEC
E­71 

International Organization for Standardization ISO 

National Council of Radiation Protection and

Measurements

NCRPM

National Fire Protection Association NFPA 

6. Please provide the total number of your agency's representatives who participated

in voluntary consensus standards activities during FY 2005 and the total number of 

activities these agency representatives participated in: 153

7. Please provide any conformity assessment activities (as described in “Guidance on 

Federal Conformity Assessment Activities” found in the Federal Register, Volume 65, Number 155, dated August 10, 2000) in which your agency was involved in FY 2005. 

No Comment

8. Please provide an evaluation of the effectiveness of Circular A‐119 policy and 

recommendations for any changes: 

The NRC believes that the Circular provides appropriate direction and

encouragement for federal agencies to develop internal agency‐wide 

guidelines. The circular also provides sufficient and reasonable flexibility for

each agency to make an independent determination relative to participation on 

voluntary consensus bodies and use of developed standards

9. Please provide any other comments you would like to share on behalf of your 

agency. 

No Comment

10. Please use this box to provide any additional comments on how your agency

currently reports its use of voluntary consensus standards: 

No Comment

10‐1. Removed [This question has been deprecated for 2005]

10‐2. Removed [This question has been deprecated for 2005]
E­72 

10‐3. Removed [This question has been deprecated for 2005]

10‐4. Does your agency report standards that it uses for guidance purposes (as opposed

compliance purposes)? (a) Yes; (b) No; (c) Not applicable; Yes

10‐5. Does your agency report use of standards from non‐ANSI accredited standards

developers, industry consortia groups, or both? (a) non‐ANSI Accredited; (b) Consortia; 

(c) Both; (d) Neither; or (e) Not applicable; D

10‐5. Does your agency have a schedule for periodically reviewing its use of standards

for purposes of updating such use? (a) Yes; (b) No; No

10­5. How often does your agency review its standards for purposes of updating such 

use? [enter the number of years]: 0
F­1

Appendix F – Federal Agency Activities Related to Use of Private Sector Standards

NOTE:  The following table lists the various standards organizations in which Federal 

agencies or their employees participated.  The organizations, their names, and their

acronyms are listed as they were reported to NIST by the agencies contributing to this

year’s report. There are 407 individual organizations identified by the agencies, some of

which may be duplicated due to differences in the names of the same organization caused 

by reporting errors of the agencies or by name changes made by the organizations

themselves.

FY 2005 Voluntary Consensus Standards Bodies in which Federal Agencies

Participated 

Voluntary Consensus Standards Body  Acronym

3­A Sanitary Standards, Inc 3­ASS

3rd Generation Partnership Project 3GPP

3rd Generation Partnership Project 2  3GPP2 

Accredited Standards Committee X12  X12 

Acoustical Society of America ASA

Adeno Associated Virus Reference Standard Working Group  AAVSWG

Advisory Committee for water Information  ACWI 

Aerospace Industries Association of America AIA

Aerospace Material Standards AMS

Air Conditioning & Refrigeration Institute ACRI 

Air Movement and Control Association International, Inc. AMCA

Air­Conditioning & Refrigeration Institute ARI 

Alliance for Telecommunications Industry Solutions ATIS

Aluminum Association  AA

Ambulance Manufacturers Division  AMD

American Academy of Pediatrics AACP

American Architectural Manufacturers Association  AAMA

American Association for Budget and Program Analysis AABPA

American Association for Clinical Chemistry  AACC 

American Association of Blood Banks AABB 

American Association of Motor Vehicle Administrators AAMVA

American Association of Physicists in Medicine AAPM

American Association of State Highway and Transportation Officials AASHTO

American Association of Textile Chemists and Colorists AATCC 

American Association of Tissue Banks AATB 

American Bearing Manufacturers Association  ABMA

American Boat and Yacht Council ABYC 

American Bureau of Shipping  ABS

American Chemical Society  ACS

American College of Radiology  ACR 

American College of Surgeons ACOS

American Concrete Institute ACI 

American Conference of Governmental Industrial Hygienists ACGIH

American Dental Association  ADA
F­2 

American Gas Association  AGA

American Gear Manufacturers Association  AGMA

American Hardboard Association  AHA

American Industrial Hygiene Association  AIHA

American Institute of Aeronautics and Astronautics AIAA

American Institute of Steel Construction  AISC 

American Institute of Timber Construction  AITC 

American Institute of Ultrasound Manufacturers AIUM

American Iron and Steel Institute AISI 

American Ladder Institute ALI 

American Medical Association  AMA

American National Metric Council ANMC 

American National Standards Institute ANSI 

American Nuclear Society  ANS

American Petroleum Institute API 

American Public Health Association  APHA

American Public Transportation Association  APTA

American Pyrotechnics Association  APA

American Railway Engineering & Maintenance­of­Way Association  AREMA

American Red Cross ARC 

American Society for Blood and Marrow Transplantation  ASBMTT

American Society for Nondestructive Testing  ASNT

American Society for Photogrammetry and Remote Sensing  ASPRS

American Society for Quality  ASQ

American Society for Reproductive Medicine ASRM

American Society for Testing and Materials ASTM

American Society of Agricultural and Biological Engineers ASABE

American Society of Agricultural Engineers ASAE

American Society of Cinematographers ASC 

American Society of Civil Engineers ASCE

American Society of Heating, Refrigerating, and Air­Conditioning Engineers ASHRAE

American Society of Mechanical Engineers ASME

American Society of Metals ASM

American Society of Naval Engineers ASNE

American Society of Quality Control ASQC 

American Society of Safety Engineers ASSE

American Society of Sanitary Engineering  ASSE

American Towing Tank Conference ATTC 

American Trucking Associations ATA

American Vacuum Society  AVS

American Water Works Association  AWWA

American Welding Society  AWS

American Wood Preservers Association  AWPA

APA The Engineering Wood Association  APA

Association for Assessment and Accreditation of Laboratory Animal Care

International AAALAC 

Association for Automatic Identification & Mobility  AIM

Association for Electronic Health Care Transactions AFEHCT

Association for Information and Image Management AIIM
F­3 

Association for Machine Technology  AMT

Association for the Advancement of Cost Engineering  AACE Int. Association for the Advancement of Medical Instrumentation  AAMI 

Association of American Railroads AAR 

Association of Biomolecular Research Facilities ABRF

Association of Diving Contractors International ADC 

Association of Food and Drug Officials AFDO

Association of Official Analytical Chemists International AOACI 

Association of Public Health Laboratories APHL

Automotive Lift Institute ­ ALOIM ALI 

Baking Industry Sanitary Standards Committee BISSC 

Basic Linear Algebra Subprograms Technical Forum BLAS

Biometrics Application Programming Interface BioAPI 

British Standards Institute BSI 

Builders Hardware Manufacturers Association  BHMA

Building Officials and Code Administrators International BOCA

Canadian General Standards Board  CGSB 

Canadian Standards Association  CSA

Cast Iron Soil Pipe Institute CISPI 

Ceilings and Interior Systems Construction Association  CISCA

Chlorine Institute CI 

Clinical and Laboratory Standards Institute CLSI 

Clinical Data Interchange Standards Consortium CDISC 

Codex  CODEX

Codex Alimentarius CODEX

College of American Pathologists CAP

Commercial Vehicle Safety Alliance CVSA

Committee on Data for Science and Technology  CODATA

Common Criteria Management Committee CCMC 

Composite Panel Association  CPA

Compressed Gas Association  CGA

Conference for Food Protection  CFP

Congress of International Organizations of Medical Sciences CIOMS

Consolidated Health Informatics CHI 

Construction Safety Association of Ontario  CSAO

Construction Specifications Institute CSI 

Consultative Committee for Space Data Systems CCSDS

Consumer Electronics Association  CEA

Convention on International Trade in Endangered Species of Wild Fauna and Flora CITES

Cooling Technology Institute CTI 

Cooling Tower Institute CTI 

Cordage Institute CI 

Cosmetic Ingredient Review CIR 

Cosmetic Toiletry and Fragrance Association  CTFA

Council on Ionizing Radiation Measurements and Standards CIRMS

Council on Optical Radiation Measurements CORM

Crane Manufacturing Association of America CMAA

Cultural Resources Standards with State Historic Preservation Offices SHPO
F­4 

Data Interchange Standards Association, Inc. DISAI 

Deep Foundations Institute DFI 

Designated Standards Maintenance Organizations Board  DSMO

Deutsches Institut fur Nomung ­ German Institute for Standardization  DIN

Electronic Commerce Code Management Association  ECCMA

Electronic Components Assemblies & Materials Association  ECAMA

Electronic Industries Alliance EIA

Electrostatic Discharge Association  EDA

Engineering Sciences Data Unit International ESDU

European Directorate for Quality of Medicines EDQM

External RNA Controls Consortium ERCC 

Eye Bank Association of America EBAA

Federal Facilities Council FFC 

Federal Geographic Data Committee FGDC 

FM Global FMG

Foundation for Accreditation of Cellular Therapies FACS

Fresh Produce Association of America FPA

Gas Appliance Manufacturers Association  GAMA

Gas Technology Institute GTI 

Government Electronics & Information Technology Association  GEITA

Graphic Communications Association  GCA

Ground Water Protection Council GWPC 

Gypsum Association  GYP

Hardwood Plywood & Veneer Association  HPVA

Health Level Seven  HL7 

Health Physics Society  HPS

Healthcare Information and Management Systems Society  HIMSS

High Frequency Industry Association  HFIA

Human Factors and Ergonomics Society, Inc. HFESI 

Human Factors Society  HFS

IEEE ­ Bioinformatics Standards Committee BSC/IEEE

Illuminating Engineering Society of North America IES

Independent Cosmetic Manufacturers and Distributors ICMAD

Industrial Safety and Equipment Association  ISEA

Industrial Truck Association  ITA

Industry­wide Cooperative Meat Identification Standards Committee ICMISC 

Information Technology Industry Council ITI 

Institute for Interconnecting and Packaging Electronic Circuits IPEC 

Institute of Clean Air Companies ICAC 

Institute of Electrical and Electronic Engineers IEEE

Institute of Environmental Sciences & Technology  IEST

Institute of Makers of Explosives IME

Institute of Nuclear Materials Management INMM

Institute of Transportation Engineers ITE

Instrumentation Society of America ISA

Instrumentation, Systems, and Automation Society  ISA

Insulated Cable Engineers Association  ICEA

Insulated Steel Door Systems Institute ISDSI
F­5 

Intelligent Transportation Society of America ITS America

Inter­American Accreditation Cooperation  IAAC 

Inter­American Metrology System SIM

Interconnection Technology Research Institute ITRI 

International 2­Up ATV Manufacturers Association  I2AMA

International Air Transport Association  IATA

International Association for Food Protection  IAFP

International Association for the Properties of Water and Steam IAPWS

International Association of Cancer Registrars IACR 

International Association of Drilling Contractors IADC 

International Association of Lighthouse Authorities IALA

International Association of Plumbing and Mechanical Officials IAPMO

International Astronomical Union  IAU

International Atomic Energy Agency  IAEA

International Blood Group Reference Laboratory  IBRGL

International Bureau of Weights and Measures BIPM

International Cartographic Association  ICA

International Civil Aviation Organization  ICAO

International Code Council ICC 

International Commission for Illumination  CIE

International Commission on Harmonization of Technical Requirements for 

Registration of Pharmaceuticals for Veterinary Use VICH

International Commission on Occupational Health  ICOH

International Commission on Radiation Protection  ICRP

International Commission on Radiation Units and Measurements, Inc. ICRU

International Committee for Cosmetic Harmonization and International Cooperation  CHIC 

International Committee for Information Technology Standards INCITS

International Committee for Weights and Measures CIPM

International Conference of Building Officials ICBO

International Conference on the Harmonization of Technical Requirements for 

Registration of Pharmaceuticals for Human Use ICH

International Coordinating Committee on the Validation of Alternative Methods ICCVAM

International Council for Science ICSU

International Council on Archives ICA

International Dairy Federation  IDF

International Dairy Foods Association  IDFA

International Earth Rotation and Reference Systems Service IERS

International Electrotechnical Commission  IEC 

International Federation on Information Processing  IFIP

International Hydrographic Organization  IHO

International Imaging Industry Association  IIIA 

International Maritime Organization  IMO

International Organization for Legal Metrology  OIML

International Organization for Standardization  ISO

International Organization for Standardization in Microbiology  ISOB 

International Organization for Standardization/International Electrotechnical

Commission  ISO/IEC 

International Radio Consultative Committee IRCC 

International Regulatory Alternatives Group  IRAG
F­6 

International Seed Testing Association  ISTA

International Ship and Offshore Structures Congress ISOSC 

International Society for Analytical Cytology  ISAC 

International Society for Blood Transfusion  ISBT

International Society for Cardiovascular Surgery  ISCVS

International Society for Cell Therapy  ISCT

International Society for Measurement and Control ISA

International Society of Oncology Pharmacy Practitioners ISOPP

International Society on Thrombosis and Homeostasis ISTH

International Telecommunication Union  ITU

International Telecommunication Union ­ Telecommunication Standardization 

Sector  ITU­T

International Union Against Cancer  UICC 

International Union of Laboratories and Experts in Materials, System and 

Structures/International Council for Research and Innovation in Building and 

Construction  RILEM/CIB 

International Union of Laboratories and Experts in Materials, Systems and 

Structures RILEM

International Union of Pure and Applied Chemistry  IUPAC 

Internet Engineering Task Force IETF

Internet Society  ISOC 

Internet Software Consortium ISC 

Interstate Shellfish Sanitation Conference ISSC 

JANNAF ­ Interagency Propulsion Committee JANNF

Java Grande Forum JGF

Joint Aeronautical Commander's Group  JACG

Joint Commission on Accreditation of Healthcare Organizations JCAHO

Joint Electron Device Engineering Council JEDEC 

Joint FAO/WHO Expert Committee on Food Additives JECFA

Kitchen Cabinet Manufacturers Association  KCMA

Logical Observation Identifier Names and Codes LOINC 

Machinery Information Management Open Systems MIMOSA

Magnetic Materials Producers Association  MMPA

Manufacturers Standardization Society of the Valve and Fittings Industry  MSSVFI 

Marine Technology Society  MTS

Master Painters Institute MPI 

Metal Lath/Steel Framing Association, A Division of NAAMM MLSFA

NAFTA Land Transportation Standards Subcommittee NAFTA

National Academy of Sciences NAS

National Aerospace and Defense Contractors Accreditation Program NADCAP

National Association of Architectural Metal Manufacturers NAAMM

National Association of Corrosion Engineers NACE

National Association of Relay Manufacturers NARM

National Board of Boiler and Pressure Vessel Inspectors NBBPVI 

National Cancer Registrar Association  NCRA

National Cargo Bureau, Inc NCB 

National Center for Vital and Health Statistics NCVHS

National Committee for Information Technology Standards NCITS

National Committee on Uniform Traffic Control Devices NCUTCD
F­7 

National Committee on Vital and Health Statistics NCVHS

National Conference for Interstate Milk Shipments NCIMS

National Conference of Standards Laboratories NCSL

National Conference on Weights and Measures NCWM

National Cooperation for Laboratory Accreditation  NACLA

National Coordinating Council for Cancer Surveillance NCCCS

National Council for Prescription Drug Program NCPDP

National Council of Radiation Protection and Measurements NCRPM

National Defense Industrial Association  NDIA

National Dialog on Cancer  NDC 

National Electrical Manufacturers Association  NEMA

National Electrical Safety Code NESC 

National Environmental Health Association  NEHA

National Environmental Methods Index  NEMI 

National Fire Protection Association  NFPA

National Fluid Power Association  NFPA

National Forum on Education Statistics NCES Forum

National Hydrogen Association  NHA

National Information Standards Organization  NISO

National Institute for Biological Sciences and Controls NIBSC 

National Institute for Occupational Safety and Health  NIOSH

National Institute of Building Sciences NIBS

National Marine Electronics Association  NMEA

National Marine Manufacturers Association  NMMA

National Marrow Donor Program NMDP

National Petroleum Management Association  NPMA

National Safety Council NSC 

National Sanitation Foundation  NSF

National Skill Standards Board  NSSB 

National Spectrum Managers Association  NSMA

National Truck Equipment Association  NTEA

National Uniform Billing Committee NUBC 

National Uniform Claim Committee NUCC 

National Water­Quality Monitoring Council NWQMC 

National Window and Door Association  NWDA

North American Association of Central Cancer Registries NAACCR 

North American Open Math Initiative NAOMI 

North American Transport of Dangerous Goods Standards NATDGS

North American Weeds Management Association  NAWMA

NSF International NSFI 

Open Applications Group  OAGi

Open Device Net Vendor Association  ODVA

Open Geospatial Consortium OGC 

Open Management Group  OMG

Optical Internetworking Forum OIF

Optical Society of America OSA

Optical Storage Technology Association  OSTA

Optics and Electro­Optics Standards Council OEOSC
F­8 

Organization for Economic Cooperation and Development OECD

Organization for the Advancement of Structured Information Systems OASIS

Pan American Health Organization  PAHO

Pan­American Standards Commission  COPANT

Parachute Industry Association  PIA

Pasteurized Milk Ordinance PMO

Performance Review Institute PRI 

Petrotechnical Open Standards Consortium, Inc. POSC 

Pipe Fabrication Institute PFI 

Plastic Pipe Institute PPI 

Plumbing and Draining Institute PDI 

Plumbing­Heating­Cooling Contractors Association  PHCCA

Portable Sanitation Association International PSIA

Post Secondary Electronic Standards Organization  PESC 

Post­Tensioning Institute PTI 

Precast/Prestressed Concrete Institute PCI 

Produce Marketing Association  PMA

Project Management Institute PMI 

Quarter­Inch Cartridge Drive Standards, Inc. QCDS

Rack Manufacturers Institute RMI 

Radio Technical Commission for Aeronautics RTCA

Radio Technical Commission for Maritime Services RTCM

Recreation Vehicle Industry Association  RVIA

Rehabilitation Engineering and Assistive Technology Society of North America RESNA

Research Institute for Fragrance Materials RIFM

Resilient Floor Covering Institute RFCI 

Resistance Welders Manufacturers Association  RWMA

Robotics Industry Association  RIA

Rubber Manufacturers Association  RMA

Scaffolding, Shoring, and Forming Institute, Inc. SSFI 

School Interoperability Framework Association  SIFA

Scientific Apparatus Makers Association  SAMA

Screen Manufacturers Association  SMA

Semantic Interoperability Community of Practice SICOP

Semiconductor Equipment and Materials International SEMI 

Sheet Metal and Air Conditioning Contractors' National Association  SMACNA

Simulation Interoperability Standards Organization  SISO

Single Ply Roofing Institute SPRI 

Society for Protective Coatings SPC 

Society of Allied Weight Engineers SAWE

Society of American Archivists SAA

Society of Automotive Engineers SAE

Society of Cosmetic Chemists SCC 

Society of Fire Protection Engineers SFPE

Society of Motion Picture and Television Engineers SMPTE

Society of Naval Architects and Marine Engineers SNAME

Society of Toxicological Pathologists STP

Southern Building Code Congress International, Inc. SBCCI
F­9 

Space Frequency Coordination Group  SFCG

Specialty Vehicle Institute of America SVIA

Standard for Exchange of Nonclinical Data SEND

Standards Engineering Society  SES

Steel Door Institute SDI 

Steel Founders Society of America SFSA

Steel Joist Institute SJI 

Steel Window Institute SWI 

Strategic National Implementation Process SNIP

Technical Association of the Pulp and Paper Industry  TAPPI 

Telecommunications Industry Association  TIA

Telemanagement Forum TMF

The Business and Institutional Furniture Manufacturer's Association  BIFMA

The Instrumentation, Systems, and Automation Society  ISAS

The Maintenance Council of American Trucking Association  TMC/ATA

The National Digital Orthophoto Program NDOP

The Open Group  TOG

The Soap and Detergent Association  SDA

The Society for Protective Coatings SSPC 

The Tire and Rim Association, Inc. TRAI 

Transportation Research Board  TRB 

Truck Trailer Manufacturers Association  TTMA

U.S. Adopted Names Council USANC 

U.S. Product Data Association  US PRO

UN Centre for Trade Facilitation & Electronic Business UCTFEB 

Underwriters Laboratories UL

United Fresh Furit and Vegetable Association  UFFVA

United Nations Committee on the Transport of Dangerous Goods UNTDG

United Nations Economic Commission for Europe WP .29/GRSP UNECE

United States Adopted Names USAN

United States Pharmacopoeia USP

Urban and Regional Information Systems Association  URISA

Versailles Project on Advanced Materials and Standards VAMAS

Video Electronics Standards Association  VESA

Water Environment Federation  WEF

Window and Door Manufacturers Association  WDMA

Workgroup for Electronic Data Interchange WEDI 

World Health Organization  WHO

World Intellectual Property Organization  WIPO

World Meteorological Organization  WMO

World Wide Web Consortium W3C 

XML Community of Practice xmlCOP

There were 407 total Voluntary Consensus Standards Bodies in which Federal Agencies Participated during fiscal year 2005.
G­1

Appendix G – The Interagency Committee on Standards Policy (ICSP)

The Interagency Committee on Standards Policy, also known as the ICSP, is the primary 

body responsible for coordinating standards use among agencies of the Federal 

government. The ICSP seeks to promote effective and consistent standards policies plus

foster cooperation between government, industry, and other private organizations

involved in standards activities. The Committee reports to the Secretary of the 

Department of Commerce (DOC) through the Director of the National Institute of

Standards and Technology (NIST).

To review the current charter of the ICSP, click here: 

http://standards.gov/icsp/query/index.cfm?do=Home.ICSPCharter 

To see a list of the current ICSP membership, click here: 

http://standards.gov/icsp/query/index.cfm?do=Home.ICSPExecutives
H­1

Appendix H – Publications Related to the National Technology Transfer and

Advancement Act (NTTAA) and Office of Management and Budget (OMB)

Circular A­119

To review a list of publications and reference documents related to Federal agency 

implementation of the NTTAA as well as OMB Circular A­119, visit the NTTAA 

Library online at http://ts.nist.gov/ts/htdocs/210/nttaa/pubs.htm.

These documents can be obtained in hardcopy form by sending a written request to: 

Standards Coordination and Conformity Group (SCCG) 

Standards Services Division (SSD) 

National Institute of Standards and Technology (NIST)

Gaithersburg, Maryland 20899­2150 

301­975­2490 

When making requests, please identify specific documents by title, author, and date 

wherever possible.