NBSIR 87-3573

Proceedings of Conference on

Standards and Trade

Walter G. Leight, Editor

U.S. DEPARTMENT OF COMMERCE

National Bureau of Standards

Office of Product Standards Policy

Gaithersburg, MD 20899

June 1987

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U.S. DEPARTMENT OF COMMERCE

NATIONAL BUREAU OF STANDARDS

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NBSIR 87-3573

Research Information Center

JSationai bureau of Standards

Gaithersburg, Maryland 20899

PROCEEDINGS OF CONFERENCE ON

STANDARDS AND TRADE

Walter G. height, Editor

U.S. DEPARTMENT OF COMMERCE

National Bureau of Standards

Office of Product Standards Policy

Gaithersburg, MD 20899

June 1987

U.S. DEPARTMENT OF COMMERCE, Malcolm Baldrige, Secretary

NATIONAL BUREAU OF STANDARDS, Ernest Ambler, Director
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TABLE OF CONTENTS

Abstract iii

Acknowledgements iv

Executive Summary 1

I. MORNING SESSION

A. Chairman's Welcome

Under Secretary for International Trade

Bruce Smart 5

B. Keynote Address

Deputy Secretary of Commerce

Clarence J. Brown 9

C. Government Officials

Introduction by Co-Chairman, Director, National

Bureau of Standards, Ernest Ambler 12

Deputy U.S. Trade Representative

Ambassador Michael Smith 13

Co-Chairman's Introduction 17

U.S. Coordinator, Bureau of International Communications

and Information Policy, Department of State

Ambassador Diana Lady Dougan 18

Questions and Answers 31

D. Corporate Officials

Co-Chairman's Introduction 36

Vice President of Corporate Technology, Norton Company

Peter Bell 37

Co-Chairman's Introduction 45

Vice President for Research and Development, Alcoa

Peter Bridenbaugh 46

Co-Chairman's Introduction 51

Chairman and CEO, Kulicke and Soffa Industries

C. Scott Kulicke 52

Questions and Answers 61

1
E. Standards Organizations

Co-Chairman's Introduction. ..... 62

Chairman, ASTM

Robert Baboian, 63

Co-Chairman's Introduction 66

Chairman, American National Standards Institute

George S. Wham. 67

Questions and Answers 82

F. Working Group Announcements

Director, Office of Product Standards Policy

Stanley I. Warshaw 84

II. AFTERNOON SESSION - WORKING GROUP REPORTS

Introduction by Dr. Warshaw 85

Chair, Working Group 1 Catherine Kachurik 86

Introduction by Dr. Warshaw ........... 89

Chair, Working Group 2

Gerald Ritterbusch 90

Introduction by Dr. Warshaw 92

Chair, Working Group 3

Barbara Boykin 93

Closing Remarks by Dr. Warshaw 99

III. LIST OF REGISTRANTS AND PARTICIPANTS. 100
ABSTRACT

The International Trade Administration and the National Bureau of Standards

sponsored a one-day Conference on Standards and Trade on May 5, 1987. These

Proceedings contain the texts of speeches by Government officials and

representatives of the business and standards communities; summaries of

question-and-answer periods; and reports of Working Groups that addressed

Participation in International Standardization Activities, Test Data

Acceptance, and Adoption of U.S. Standards.
ACKNOWLEDGEMENTS

The preparation of these Proceedings would not have been possible without the

generous cooperation of the speakers, Working Group Chairs, and their office

staffs. Administrative arrangements for the Conference were effectively

carried out through the efforts of Mrs. Sarah Torrence and Ms. Wanda Capino

at the National Bureau of Standards, with special thanks to Mrs. Judith Baker

of the NBS Office of Product Standards Policy for her meticulous attention to

details before, during, and after the Conference and in the transcription of

audio tapes.

TV
EXECUTIVE SUMMARY

The International Trade Administration and the National Bureau of Standards,

of the Department of Commerce, sponsored a one-day Conference on Standards

and Trade on May 5, 1987. The purpose of the Conference was to identify and

explore possible actions by the Government and the private sector to enhance

U.S. trade through promoting U.S. standards, and the technology they embody,

in foreign countries and international organizations.

The Conference was co-chaired by the Honorable Bruce Smart, Under Secretary

for International Trade, and Dr. Ernest Ambler, Director of the National

Bureau of Standards. The first of three segments was comprised of presentations by officials of the U.S. Government: the Honorable Clarence Brown,

Deputy Secretary of Commerce, the Honorable Michael Smith, Deputy U.S. Trade

Representative, and Ambassador Diana Lady Dougan, U.S. Coordinator, Bureau of

International Communications and Information Policy, U.S. Department of

State. They stressed the need to improve the national trade picture,

described ongoing efforts by the Government under the GATT Agreement on Technical Barriers to Trade (the "Standards Code"), bilateral negotiations on standards-related trade problems, participation in treaty organizations and

other government-to-government international committees, and the status of

the current Uruguay Round of Multinational Trade Negotiations (MTN) talks.

They expressed receptiveness to private sector views and their willingness to

apply available resources to strengthen our trade position, especially in the

international standards arena.

The second group of morning speakers addressed standards-related concerns of

the business community. Dr. Peter Bell, Vice President of Corporate

Technology, Norton Company, focused on export controls and expressed the

desire for a single Federal regulatory focus. Dr. Peter Bridenbaugh, Vice

President for Research and Development, Alcoa, emphasized the need for

U.S. leadership in technology and the development of the best technical

standards possible. Mr. C. Scott Kulicke, Chairman and Chief Executive

Officer, Kulicke and Soffa Industries, Inc., described the activities of the

Semi-conductor Equipment and Materials Institute (SEMI) and the necessity for

rapid development of new standards in a changing technological environment,

as well as participation by foreign nationals in standards-devel oping bodies,

both in the United States and elsewhere.

Private sector participation in international standardization was the subject

of the third part of the morning session. Dr. Robert Baboian, Chairman of

the ASTM Board, underscored the importance of using the best technical

standards available as ^ facto international standards, ASTM's role in

international standards committee work, and in cooperating with the standards

bodies of other countries. Dr. George S. Wham, Chairman, American National

Standards Institute, described the private sector standards system and how

ANSI functions as the member body to ISO and lEC.

1
Three Working Groups met in the early afternoon as follows:

WG-1 Participation in International Standardization Activities

Chair: Catherine Kachurik, Director, X-3 Secretariat

Secretariat: JoAnne Overman, NBS

WG-2 Test Data Acceptance

Chair: Gerald Ritterbusch, Caterpillar, Inc.

Secretariat: Patrick Cooke, NBS

WG-3 Adoption of U.S. Standards

Chair: Barbara Boykin, Aerospace Industries Association

Secretariat: Christopher Bates, ITA

Reports by the Chairs of the Working Groups at the closing plenary session of

the conference reiterated the view that the private sector should lead in

choosing and implementing courses of action. They all cited the importance

of outreach programs in educational institutions and public relations

campaigns in order to arouse greater public support for standardization

activities. They stressed the need to convince business management that

participating in international standards development and related activities

produces the "bottom line" of long-term profitability, and the belief that

industry will always demand the best standards for the international

marketplace.

WG-1 suggested that the private sector seek funding by collections under a budgeted, equitable system or by special assessment. Hosting meetings in the

United States would reduce costs to U.S. participants and benefit foreign

counterparts through favorable exchange rates. The Group proposed media and

educational campaigns to convince corporate executives and managers of the

long-term value of participating in international standardization activities

and to attract replacements for retiring "elder statesmen." The Government

should seek industry opinion, be responsive and reactive to standards needs,

and support positions in GATT talks and other negotiations.

WG-2 proposed that at all levels we promote acceptance of test data by other

countries, including the current Uruguay Round of Multinational Trade

Negotiations, bilateral negotiations, and the GATT Standards Code Committee.

Voluntary laboratory accreditation programs, self-certification, third-party

testing, and witnessed tests in the United States could reduce testing costs,

with treatments matched to products and markets. An industry program should

publicize certification programs, their costs, and significance.

The third Working Group advised that industry "think internationally" about

standards and trade, adapting to the needs of international markets and

abandoning nationalistic approaches; strengthen representation in ISO and lEC

to encourage adoption of U.S. standards; pursue harmonization efforts with

the European Community; promote awareness and availability of U.S. standards

to potential users abroad; educate U.S. Government officials overseas about

standards; preserve private sector leadership and enhance Governmentindustry cooperation.

2
The complete texts of speaker presentations, summaries of question-and-answer

periods, and the reports of the Working Groups are contained in the main body

of these Proceedings.

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ITA/NBS CONFERENCE ON STANDARDS AND TRADE

CHAIRMAN'S WELCOMING REMARKS

May 5, 1987

o I am pleased to welcome you to the Conference on Standards and

Trade, an event sponsored jointly by the National Bureau of

Standards and the International Trade Administration.

o Our primary objective for this Conference is to stimulate

discussion on how the United States can increase exports by

eliminating technical barriers to trade and promoting wider

international acceptance of standards based on American

technology.

o The conference program brings together experts from U.S.

business, the private standards development community, and

government to address this important issue.

o This morning we will hear from distinguished speakers from each

of these groups. We have asked them to focus their remarks on

what can and should be done by various members of the U.S.

standards community to promote trade through standards

activities

o In afternoon working group sessions we will have the chance to

discuss ideas presented by these speakers and to add our own

observations. At the end of the day each working group will

report back to the full conference on its findings and

recommendations

5
o We hope all participants will use this opportunity to raise new

ideas on how government and industry, individually and jointly,

can strengthen U,S. standards-related activities in ways that

will have a significant positive impact on our long-term trade

performance and international competitiveness.

o The importance of this effort should not be underestimated.

We face unprecedented challenges to our technological and

commercial leadership at home and abroad. We are struggling to

reduce huge trade and budget deficits and to avoid a further

worsening of our international debtor position.

o While U.S. business has taken major steps to meet increased

competition, much more must be done, particularly in coming to

grips with foreign market requirements. The U.S. standards

community has a critical role to play in helping American

industry meet these requirements.

o No single approach will work, because the problems we encounter

vary considerably by product and market. Flexibility in

standards-development activities is the key to future success,

and private sector bodies must continue to take the lead role.

Government has an important supporting role to play, which must

evolve to reflect the changing standards environment and needs

of U.S. business.

6
o As exporters, U.S businessmen often are faced with a difficult

choice between adapting their products at high cost to meet

existing foreign standards or accepting a more limited foreign

market share than they otherwise might achieve. We frequently

face a similar dilemma regarding foreign testing requirements.

o In too many cases, foreign mandatory standards or other

technical requirements cannot be justified on health or safety

grounds and serve as effective barriers to our exports. In

such cases, effective government and industry cooperation may

be the only means to achieve an acceptable solution.

o In other instances, however, we may be in a position to push

for international harmonization of standards based on existing

U.S. standards and/or the technology they embody. We may also

have the opportunity to encourage foreign standard development

bodies to move more quickly toward reliance on performancerather than design-based standards.

o In an environment of rapid technological change and growing

worldwide competition, we constantly must be on the lookout for

new opportunities to promote exports through standards-relat'ed

activities

7
o Deputy Secretary Brown, our keynote speaker, has a longstanding interest in the subject of standards and trade and a

full appreciation of the significance of the U.S. standard

community's work in international fora. I am confident that he

and our other speakers will give us an exciting morning

program.

8
Honorable Clarence J. Brown

Deputy Secretary of Commerce

Keynote Address before the

ITA/NBS Conference on Standards and Trade

Washington, D.C.

May 5, 1987

I am pleased to be with you this morning because of my strong

interest in trade and in worldwide acceptance of product and

material standards based on U.S. technology.

This conference is somewhat different from the conventional

recital in that representatives of Government will discuss the

overall trade picture and what we are trying to do about it,

then leaders of industry and the standards community will get

down to cases and offer suggestions for separate or joint

courses of action.

Our trade deficit is now at an all-time high. We have gone from

the world's major creditor nation to the most indebted, and our

merchandise trade deficit in 1986 was close to $170 billion.

To remedy these grim statistics, the President has enunciated a

Competitiveness Initiative: among other things, we seek to

promote science and technology; to protect intellectual property

rights; and to strengthen our position in the international

trading arena by emphasizing the advantages and resources that

America has at her command.

The Government has increased its efforts to transfer the

research output of Federal laboratories to the private sector.

Each major governmental R&D laboratory, including the Commerce

Department's National Bureau of Standards and its National

Oceanic and Atmospheric Administration, has under law

established an Office of Research and Technology Applications to

help nurture product and industrial development. The Department

of Energy, with advice from the Office of Energy-Related

Inventions at the National Bureau of Standards, supports the

development of promising processes and products.

Government agencies are increasing their emphasis on cooperative

research ventures with the private sector, such as the extensive

undertakings conducted at the Automated Manufacturing Research

Facility of the National Bureau of Standards.

The Department of Commerce has been active in efforts to reduce

or eliminate technical barriers to trade under the GATT

Standards Code, working with our colleagues at the Departments

of State and Agriculture and with the Office of the U.S. Trade

Representative. We regularly participate in multilateral

meetings and in bilateral consultations with other signatory

9
governments - including Japan, the European Community, Great

Britain, Canada, France, West Germany, and Spain. We are also

working actively to establish a Free Trade Agreement with

Canada.

The two key areas that have been and are expected to remain

quite important for the future concern mechanisms for resolution

of disputes and for mutual acceptance of valid test data. The

latter problem is the concern most frequently expressed by

U.S. manufacturers and exporters, namely the burdensome,

expensive, and time-consuming approval procedures and

certification practices imposed by some foreign governments.

Negotiating reciprocal acceptance agreements represents a new

mechanism for reducing barriers to testing and certification.

Through bilateral and multilateral consultation, the Government

has assisted private sector interests in gaining the right to

participate in foreign standards development activities; to have

U.S. -generated test data accepted in foreign countries; and to

work toward non-discriminatory treatment of U.S. suppliers by

foreign certification systems.

We usually work on a case-by-case basis, especially with respect

to single country issues that can be addressed in bilateral

discussions. Where appropriate, we are ready to seek general

solutions to more complex problems.

The major purpose of today’s conference is to obtain your inputs

and advice with respect to the standards and trade issues that

face us as a nation.

o What should the United States Government be doing more of,

less of, or differently?

o What courses of action should properly be adopted by the

private sector?

o What are your recommendations for tasks that should be

undertaken jointly by the Government and the private

sector?

We are fortunate to have with us today Michael Smith, Deputy

U.S. Trade Representative, who will discuss our multilateral

efforts to remove technical barriers to trade under the aegis

of the General Agreement on Tariffs and Trade, and

Ambassador Diana Lady Dougan, who will describe governmental

participation in telecommunications standards bodies.

I assure you that President Reagan, Secretary Baldrige, and I

have a strong commitment to rectify the worsening trade picture

10
and to strengthen the U.S. economy. I therefore welcome your

views and recommendations, which I intend to study carefully.

Thank you.

n
Co-Chairman Ernest Ambler

Director, National Bureau of Standards

INTRODUCTION OF AMBASSADOR MICHAEL B. SMITH

IT IS MY PLEASURE TO INTRODUCE THE HONORABLE MICHAEL B. SMITH, DEPUTY U.S.

TRADE REPRESENTATIVE.

AMBASSADOR SMITH JOINED THE FOREIGN SERVICE SOON AFTER HIS GRADUATION FROM

HARVARD COLLEGE IN 1958, SERVING IN TEHRAN; N'DJAMENA, CHAD; AND STRASBOURG AND

LYON, FRANCE.

FROM 1970-1973 HE SERVED AS CHIEF OF PRESIDENTIAL CORRESPONDENCE, THEN BECAME

CHIEF OF FIBERS AND TEXTILES DIVISION, DEPARTMENT OF STATE. HE WAS APPOINTED

CHIEF TEXTILE NEGOTIATOR OF THE UNITED STATES, IN USTR, WITH THE RANK OF

MINISTER, AND WAS ELEVATED TO THE RANK OF AMBASSADOR WHEN THE POSITION WAS IN

1978 REDESIGNATED AS CHIEF NEGOTIATOR FOR TEXTILE MATTERS.

AMBASSADOR SMITH WAS NAMED DEPUTY U.S. TRADE REPRESENTATIVE AND U.S.

REPRESENTATIVE TO GATT IN GENEVA IN 1979, RETURNING TO WASHINGTON AS DEPUTY

USTR IN 1983.

HE WILL SPEAK TO US TODAY ABOUT THE GATT STANDARDS CODE AND ITS BENEFITS TO

EXPORTERS, AND WILL DISCUSS PROGRESS IN THE ONGOING URUGUAY ROUND OF

NEGOTIATIONS. HE WILL ALSO DESCRIBE SOME OF THE ACTIVITIES IN OUR TRADE

RELATIONS WITH JAPAN AND OTHER COUNTRIES, WITH SPECIAL EMPHASIS ON

INTERNATIONAL STANDARDS AND THE ACCEPTANCE OF U.S. -GENERATED TEST DATA.

AMBASSADOR SMITH.

12
AMBASSADOR MICHAEL B SMITH

Deputy U.S. Trade Representative

Speech before the

"Conference on Standards and Trade"

Washington, D.C.

May 5, 1987

Introduction

Thank you Bud [Brown] and Bruce [Smart]

Good morning ladies and gentlemen. My name is Michael Smith — I

am the deputy U.S. trade representative.

In case you are not familiar with the Office of the U.S. Trade

Representative (called "USTR"),let me start by explaining that

USTR is responsible for coordinating U.S. trade policy.

We handle problems in a wide range of areas — from corn and

soybeans to microchips and supercomputers. Somewhere along the

way between those two extremes, we are also involved in standards

related trade issues.

USTR and St andards Community

For more than fifteen years, USTR has worked with the American

private standards community:

- we first starting working together on a 'code of conduct'

on standards, which eventually became the GATT "Agreement on

Technical Barriers to Trade" and is popularly called the

"Standards Code"; and,

- we continued to work together while obtaining Congressional

approval of the Code in 1979 and when we set out to make it

work, both at home and overseas.

I hope that this long history of cooperation will keep going on.

Standards Code: Benefits to Exporters

After the Standards Code was completed in 1979, the U.S. Congress

gave USTR the primary responsibility for its implementation in the

United States. Since then, we have worked with other sister

agencies in ensuring that U.S. exporters obtain maximum advantage

from the Code.

13
For example, now exporters have the ohance to comment on foreign

regulations before they are set in concrete. In this way, a

majority of standards problems are resolved before they can

become trade barriers. Before the Code, Americans did not have

the opportunity to comment on foreign rules while foreigners

enjoyed to right to provide their comments directly to U.S.

regulators

The Code also provides procedures for resolving disputes. These

procedures have been used against the Spanish approval system for

medical devices, the Japanese system for aluminum softball bats

and, currently, are being used against the EC's directive on

animal hormones.

Standards Problems and Japan

Perhaps the most important standards case on which I have worked

involved Japanese procedures for approving softball bats. Before

1983, each shipment of American-made bats was checked by Japanese

inspectors

Japanese regulators would not accept U. S

. -generated test data nor

permit American producers to use "type approval" procedures.

While cracking the case -- as we did -- we also succeeded in

changing eighteen Japanese regulatory statutes that similarly

discriminated against non-Japanese producers.

Great efforts have been made in opening the Japanese market

further to U.S. products. Since 1979, USTR has led standards

related trade talks and, in 1985, we initiated the "marketoriented, sector-selective" (or M.O.S.S.) talks. U.S. industry

agrees that the M.O.S.S. talks on telecom equipment and medical

devices have assisted U.S. companies selling in Japan.

Standards Bilaterals in Europe

USTR has also focused its energies on resolving European standards

related trade problems. Talks have been held with all of our

significant European trading partners and particularly the Commission

of the European Communities — the EC.

The EC has a wide range of activities in the standards area aimed

at fostering industrial competitiveness and promoting European

industry and agriculture. As with Japan, American exporters also

report that these USTR-led talks have assisted in breaking down

European trade barriers.

The Europeans have ambitious plans aimed at establishing by 1992

a single market among the twelve member states. This effort

focuses on radical changes in EC standardization and certification

procedures

14
These changes are based on the Sta’^dards Code, but go further:

- they have set up an elaborate network for exchanging

information on draft rules and for calling a halt to rulemaking

that threatens to create trade barriers; and,

- they have agreed on the mutual acceptance of test data to

facilitate equipment approvals and have initially focused on

developing a model program for telecom terminal equipment.

For these reasons, I believe that we must pay careful attention

to the EC's standards activities, largely because the EC has

understood the connection between "standards" and "trade". They

now intend to manipulate this connection to their benefit.

Standards-Related Trade Problems

There are a number of practices that create problems in the standards

area; these include:

- the failure to use international standards,

- the reliance on unique national standards,

- the non-acceptance of foreign-generated test data, and

- the use of complicated approval procedures.

U.S.A. and International Standards

For a reason that has never been clear to me, Americans fear the

active use of international standards. There is an often repeated

sentiment that using international standards somehow violates the

American sovereignty. This view works against the interests of

U.S. exporters and, in the long term, of U.S. standards developers.

- We must strive to involve ourselves more deeply in international standardization and certification. This includes

making sure that each company and industry supports to the

American member body in the ISO [International Organization

for Standardization] and the lEC [ International Electrotechnical

Commission]

- We should be active members of international committees,

leading the work to ensure that it is based on American

technology. International trade relies heavily on standards

and, in the future, will increasingly use international

standards. If these standards have an American hue, then we

will benefit. Furthermore, as many other countries--

Germany, Sweden and Japan, to name three — have made this

realization, I believe that we can not allow ourselves to

fall behind.

15
Future Work: Testing and Appr oval

American exporters continue to complain about the lack of foreign

acceptance of U . S

. -generated test data. They also argue that

approval procedures around the world should be simplified and

depend more on manufacturers.

Indeed, an analysis of USTR's work since completion of the

Standards Code in 1979 reveals that testing and approval are the

two areas most often complained about by U.S. exporters.

Uruguay Round

I believe that these two issues can be solved in the new round of

trade talks that were inaugurated in 1986 -- called the "Uruguay

Round" . These talks are concentrating on draft new trade rules

to cover services, investment and intellectual property. The Uruguay

Round will also review current GATT arrangements and agreements

to see if they need improvement.

The United States has already identified the fact that the

Standards Code's coverage of testing and approval needs adjustment.

The work towards achieving this goal started years ago, within

the Standards Code Committee. In that group, the United States

has circulated proposals regarding the acceptance of test data

and the simplification of approval procedures.

The initial results of this effort are good. The Standards Code

Committee agrees that the single most important standards issue

for review in the Uruguay Round is that of "testing". Unanimity

of this kind is rare in the Committee. That being said, the

Committee does not agree on how to accomplish this goal. In

fact, the Committee continues to struggle to develop an agreed

approach. I am confident that this work will proceed as work

proceeds in other areas of the Uruguay Round.

Private Sector Assistance

Our expectations for the Uruguay Round are grand and will not be

accomplished over night. In order to finish the job before us,

we at USTR and in the U.S. Government need your help.

- We need the assistance of U.S. standards developers in

promoting the use of internationally agreed standards.

- We need help from U.S. testing and certification bodies in

supporting our effort to draft rules on the acceptance of

data and the simplification of approval procedures.

- We need the support of U.S. industry for our efforts and,

particularly, in the discussion with standards developers

and certification bodies.

16
Co-Chairman Ambler

INTRODUCTION OF AMBASSADOR DIANA LADY DOUGAN

I AM PLEASED TO INTRODUCE THE HONORABLE DIANA LADY DOUGAN, U.S. COORDINATOR FOR

INTERNATIONAL COMMUNICATIONS AND INFORMATION POLICY AT THE DEPARTMENT OF STATE.

AMBASSADOR DOUGAN WAS NAMED THE FIRST COORDINATOR FOR INTERNATIONAL

COMMUNICATIONS AND INFORMATION POLICY IN 1983 AND IN 1985 WAS ASKED BY

SECRETARY OF STATE GEORGE SCHULTZ TO ORGANIZE AND DIRECT A NEW BUREAU BY THE

SAME NAME IN THAT DEPARTMENT. FROM 1976 TO 1983, SHE SERVED AS THE DIRECTOR OF

THE CORPORATION FOR PUBLIC BROADCASTING. EARLIER IN HER CAREER, SHE WAS CATV

MARKETING AND PROMOTION DIRECTOR FOR TIME, INC. SHE ALSO HAS BEEN ACTIVE IN A

VARIETY OF PUBLIC SERVICE AND CULTURAL ACTIVITIES.

AMBASSADOR DOUGAN CURRENTLY WORKS WITH OVER 14 U.S. GOVERNMENT AGENCIES IN

DEVELOPING U.S. COMMUNICATIONS POLICIES ABROAD. IN ADDITION TO BILATERAL

RESPONSIBILITIES, SHE AND HER STAFF OVERSEE AND/OR REPRESENT U.S. INTERESTS IN

VARIOUS MULTILATERAL FORA. THESE INCLUDE THE INTERNATIONAL TELECOMMUNICATIONS

UNION (ITU), THE INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO), THE

WORLD INTELLECTUAL PROPERTY ORGANIZATION (WIPO), AND THE ORGANIZATION FOR

ECONOMIC COOPERATION AND DEVELOPMENT (OECD) AMONG OTHERS.

AMBASSADOR DOUGAN IS UNIQUELY QUALIFIED TO DISCUSS U.S. GOVERNMENT

PARTICIPATION IN INTERNATIONAL STANDARDS FORA AND TO SUGGEST WAYS IN WHICH THE

U.S. GOVERNMENT AND PRIVATE INDUSTRY CAN COOPERATE EFFECTIVELY IN PROMOTING

TRADE THROUGH STANDARDS ACTIVITIES.

17
Remarks of

Ambassador Diana Lady Dougan

U.S. Coordinator and Director

Bureau of International Communications

and Information Policy

Department of State

Delivered to

A Symposium on Standards

Sponsored by the National Bureau of Standards

at the Department of Commerce

on

May 5, 1987

18
Good morning. I'm delighted to be here, and I applaud the

Department of Commerce in hosting this symposium on standards

setting. With increased attention to U.S. competitiveness

abroad, it is ironic that so little attention has been given to

the role of standards in the international context. In the

past, because of our vast domestic market, we have often been

able to remain relatively unconcerned about different technical

standards in use abroad. With the increasing globalization of

the marketplace, we can no longer think in terms of foreign

influences gently lapping at our shores. Instead they are

invading them in all sorts of ways.

In telecommunications, the difference in standards has long

been evident to the American traveler abroad. For example,

when you turn on the television set in Europe, you may be

somewhat surprised that the picture is generally crisper than

in the United States. That's because the European standard of

625 lines of resolution, as opposed to our 525, gives more

refinement to the picture. But if you ever tried to negotiate

a pay telephone in Paris or get your electric razor or hair

dryer to work in most foreign hotels which are not part of an

international chain, the problems and complexities of international standards setting become very real.

Today I want to talk about telecommunications — the whole

world of common carrier services, broadcast media, and computers. They are important to you and your daily life, regardless of the industry you are in; they are the technological

arteries of international commerce. As a result, studying

telecommunications standards is going to be important to you

whether you are selling tractors or soft drinks.

This morning I would like to give you a brief outline of

how the international standards setting process is involved in

telecommunications. I would also like to outline a few of our

19
U.S. preparatory efforts, as well as some of the challenges I

see for us collectively.

First of all, let's establish that there are various kinds

of standards. The first standard is no standard at all. The

second, which many view as a

^ facto standard, is one which

evolves by history, a fluke of circumstances, good luck, or

just because it's excellent. The third type is voluntary

standards that meet most international requirements, and the

fourth type is treaty-based standards. It's these latter two

that I would like to focus on this morning.

There a number of international organizations that deal

with standards related to telecommunications. Two of them are

the International Standards Organization and the International

Electrotechnical Commission? both are basically voluntary

bodies. The third such organization is the International

Telecommunication Union (ITU) , an intergovernmental body

established by treaty. I would especially like to draw your

attention to the ITU, which is where we have the greatest

opportunities and the greatest challenges.

As others have pointed out, government bodies love acronyms. Telecommunications is the dessert tray of acronyms.

Within the International Telecommunication Union, two of the

most important acronyms are CCIR and CCITT. CCIR stands for

the Consultative Committee on International Radio. The United

States maintains a national public advisory body for the CCIR;

that body is headed by Richard Shrum, the Director of my

Bureau's Office of International Radio Communications. CCITT

stands for the Consultative Committee on International Telephone and Telegraph. The U.S. public body for the CCITT is

headed by Mr. Earl Barbely, the Director of my Bureau's Office

of Technical Standards and Development.

20
The CCIR addresses issues related to broadcasting, radio

spectrum allocation, the geostationary orbit, and questions

associated with signals transmitted over the air. Within the

United States, the Interdepartmental Radio Advisory Committee,

chaired by the Department of Commerce, manages the federal

government's use of the spectrum; and the Federal Communications Commission manages the private sector's use of the

spectrum. The State Department's national advisory committee

is the focal point for bringing the domestic considerations

into the international context. Increasingly, it is becoming

involved with standards setting.

Standards for high-definition television has been one of my

priorities in the CCIR this past year, and this effort is a

good example of the dynamics of international standards setting. High-definition television has enormous potential for

medical and scientific uses, as well as for broadcast purposes.

If it gets off the ground, it will launch a multi-billion dollar

industry. More importantly, if an international standard can

be adopted, much of the historic technical incompatibilities of

global television will be, for the first time, substantially

struck down.

Many of you may have read about high-definition television.

It's basically a technology that produces an extremely refined

television picture, just as the current television standards in

Europe provide a better picture than in the United States.

Current U.S. television consists of 525 lines of signal transmission; high-definition television would more than double that,

raising the number to 1125 lines.

Just envision a picture with twice as much clarity and

refinement. Anyone who has looked at a big-screen TV in a bar

or at a friend's house knows that most big-screen TVs in the

United States leave a lot to be desired. The graininess and

unsatisfactory resolution are all too evident.

21
In the case of high-definition television we had an interesting dilemma. The networks came to us and said they knew

that we needed an international standard for high-definition

television. If we don't get one, they said, we're going to

have the same problems as with standard television; North

American equipment and broadcast signals would once again be

incompatible with those of Europe and the rest of the world.

They added . that a standard for high-definition television is

not only important from the production standpoint, it is

imperative to achieving the broader economies necessary to get

the technology off the ground.

I agreed to host some "headbashing" under the auspices of

the U.S. Government's formal national advisory committee for

the CCIR. However, I set a very important condition on the

U.S. Government's involvement. We would not get involved in

deciding what the standards should be. If U.S. industry could

come to an agreement, we would go to bat for them in the CCIR

in Geneva. The process had to be voluntary. It had to be

based on industry consensus.

The irony was that the best standard that anyone could come

up with was one developed by the Japanese. I need not say to

this group that a few people were choking on their sake at the

idea of the U.S getting out front and supporting a Japanese

standard, but that's ultimately what we did — because it was

in fact the best standard.

After what I must say was a healthy amount of headbashing,

the U.S. television industry came up with a unanimous conclusion to support the Japanese standard. We kept out end of the

bargain and suited up to take the ball onto the international

playing field in Geneva. Some of the things that came out of

the locker rooms are instructive in the standards process

generally. The engineers in Europe concurred with the engineers in the United States and Japan that this high-definition

22
standard was by far the* best and the most workable from technical and manufacturing standpoints. But the Europeans not

only did not support the consensus, they mounted an aggressive

campaign opposing it. The reasons were economic. The European

companies weren't in a position to build the TV sets to receive

these high-definition television programs. They also had spent

millions of dollars in research and development, and were

reluctant to give up on their investments.

When we went to the CCIR meeting, we knew that we had a lot

more than political dust in the air while we were trying to

negotiate this. In the end, we got a marginal sort of "footnote" amounting to preliminary acceptance, but the standards

setting process was by no means over. On the other hand, the

real "footnote" to the process is that the technology which

underlies the proposed standard for high-definition television

is gaining wider and wider recognition, and I predict that this

technology will ultimately become a

^ facto standard.

The CCITT is the second, equally important dimension of the

ITU’s standards-setting arena. The CCITT deals with the

standards which relate to telecommunications equipment, interconnection, service definitions, and tariff principles. Thus

the CCITT figures out the rules of the road for international

common carriers. Increasingly, computers, data processing, and

the so-called "it" (information technology) have become the new

focal point of this traditionally telecommunications-or iented

forum.

Thus one of our priorities has been working with the CCITT

to minimize the amount of overlap with the International

Standards Organization, because many of the issues which

traditionally would have been looked at in the International

Standards Organization have now entered the realm of the ITU.

Collectively, we have been successful, mainly because the

international head of CCITT, a German gentleman by the name of

23
Mr. Irmer, has been wonderfully unbureaucratic in his approach

to working with the International Standards Organization. What

started out as a serious problem of overlap can now be put on

the back burner.

In contrast, the CCITT's front-burner items affect international commerce in many ways. For example, pay telephones

will undoubtedly continue to be bastions of frustration

throughout the world. But we've recently reduced the headache

level by a substantial degree. Building on months and months

of meetings, we have successfully negotiated a basic protocol

for international credit card calls. Without such a standard,

the morass of local procedures and regulations would forever

prevail

U.S. goals in the standards setting process are rather

simple. We want the standards setting process to be open; we

want it to be transparent; we want it on a consensus basis

whenever possible; and we want the content to be generated by

industry rather than by government. Now those sound like

pretty straightforward goals, and their efficiencies and

economies have enormous potential. So it shouldn't be much of

a problem to promote these goals. But as you will see, we have

run into quite a few problems in carrying these concepts

forward internationally.

First of all we're having difficulty in getting U.S.

industry to show sufficient commitment and be active enough in

the international standards setting process. It is almost an

irony that as other countries become more active and send more

representatives to Geneva, we seem to send fewer. Part of the

reason is the long history of deferring to a few U.S. companies, and sometimes a few individuals, to carry the day for

us. The breakup of AT&T had no small impact on our ability to

have a thorough approach to international standards setting.

24
But an equally important factor is the "third-quarter balance

sheet" mentality. This makes it hard for companies to justify

sending someone off to Geneva to negotiate for three or four

weeks when the outcome won't mean anything to the company for

four or five years. And as eveyone does a little belt tightening, it becomes harder and harder to pursue activities which

correspond to long-haul strategic interests rather than immediate advantages.

There is yet another irony to the shortsightedness of U.S.

industry. This stems from the fact that the international

standards setting environment is a great place to make contact,

a great place to nurture your own innovations and develop new

markets. It's also an excellent window on the developing world.

To a certain degree, the international standards setting

process involves technology transfer to the Third World.

Although a number of developing countries do not actively

participate in the CCITT and CCIR process, their representatives are there; they learn, and they are impressed with those

they meet — not those they don't meet.

Standards setting must necessarily tread a narrow line; a

standard must be specific enough so that an industry can

develop and technologies can grow, but not so detailed as to

thwart innovation or competition. The first problem with this

is that other countries more often emphasize specifics and

quality of service, rather than customer choice. The second

problem is that, at least in the telecommunications realm,

other countries' standards-setting processes are almost totally

controlled by government ministries of posts and telecommunications — organizations which have strong biases of their own,

and which are not easily swayed by U.S. championing of choice,

innovation, and flexibility.

25
There is of course some industry participation, but for the

most part it amounts to the involvement of a "local gorilla."

Siemens, Philips, Ericsson, and Compagnie G4n4rale d 'Electricity, for example, all cast long shadows over their governments' positions in the CCITT. As a result, the standardssetting process is weighted towards preserving the status quo

of a government monopoly or a government-favored manufacturer.

And that does not fit in with U.S. competitive goals which

emphasize the "discipline of the marketplace."

Another major issue has to do with the U.S. approach in

relation to "damage to the network" and how that applies to

international telecommunications. Many countries contend that

you must have very, very precise standards or else you will

damage the network. Lest we be too smug in our enlightenment

in the U.S., I harken back to the days when Charles Brown and

others from AT&T said that you couldn't possibly have a telephone that wasn’t an AT&T telephone, because it would damage

the whole network.

Now granted, many of those telephones that we have out

there that look like Mickey Mouse, or footballs, or beer cans,

or whatever, may not be the best quality telephones, and many

of you may have given them to your teenagers or discarded them

altogether. But, one, they didn't damage the network; and,

two, they were a choice that you could make yourself. Nevertheless, the issue of damage to the network is one that continues to plague us in international standards setting.

Foreign governments also look more towards interoperability

rather than just interconnectibility , and they want to be much

more detailed in the standards that are put forward. In

addition, we also find that some foreign governments are

attracted to the idea of using the ITU as a forum to resolve

national and regional differences and attempt to force more

restrictions into the process.

26
Another dimension which deserves more attention is the fact

that more and more countries are looking at standards setting

as part of a broader industrial policy. We in the U.S. have

long chuckled at the overly ambitious and rigid five-year plans

of certain countries, but these plans for industrial growth are

becoming more and more sophisticated, and they increasingly

encompass strategies on standards setting as well as research

and development.

European Community activities are an especially instructive

example. The European Community has been seized with the

problems of being a small, balkanized market. Needless to say,

many of its industrial policy goals are geared towards creating

a unified European market. We applaud a European market based

on the concepts of the Treaty of Rome, which opened things up.

But if the European market becomes more restrictive, more

inward looking, we're going to have real problems.

These difficulties are not made any easier by the fact that

in telecommunications the European Community defers, at least

at this point, to what they call the CEPT organization — which

is basically the European PTTs. We have two basic problems

with the CEPT. First, the CEPT process is PTT controlled.

Second, the CEPT makes little room for private-sector input,

and industry not based in Europe is totally out in the cold.

In contrast, our own CCIR and CCITT process in the United

States is open, and there is plenty of participation by foreign

governments and foreign corporations.

One of the initiatives that my office has been working on

recently is to push for industry involvement in CEPT activities

related to standards setting. To a limited extent, there has

been industry involvement for quite some time, but what we're

going to ask for next is the participation of U.S. industry in

the process. But that will only happen if U.S. industry takes

an activist approach.

27
In relation to standards setting overall, I cannot emphasize enough the importance of industry as the best promoters of

quality and openness. Both government and industry must

continually answer several major policy questions: At what

point do you need a standard? At what point do you need a

standard based on a treaty? At what point do you let the

marketplace decide for itself? How involved should governments

be as advocates?

I believe that our approach to high-definition television

was a good example of how we should deal with standards internationally. We in the government did not sell the standard;

instead, we let the technology speak for itself, engineer to

engineer. For that reason, I believe that the high-definition

TV standard will ultimately prevail — perhaps not as a treatybased standard, but the exposure it got in the ITU has already

gone a long way toward making it a commercial reality.

If possible, we must avoid pitting government against

government in the standards setting process. If we do, we're

all potential losers, because there are plenty out there who

look at standards setting as a potent non-tariff barrier. The

trend would then shift away from the technical merits to

political and economic trade games, adding yet another coal to

the flames of shortsighted protectionism.

I do not have time this morning to comment in depth on

other dimensions of standards setting, such as type approval,

certification, licensing, and industrial property. I do not

believe that those issues can be separated from the broader

issue of standards setting, and I hope that your symposium will

address these matters as well.

In closing, I suppose I'm like most Americans who grew up

somewhat complacently believing that America was the country

that set standards against which everyone else had to measure

28
themselves. We also tended to believe that the American

standard was automatically something to be proud of and that it

was synonymous with superiority, excellence, and innovation.

At our peril do we continue to take that for granted. Not only

are other countries increasingly sophisticated in their technological advances, they are also increasingly sophisticated in

playing the game of international standards setting.

There is a price we pay for our way of government, our

robust and increasingly unregulated economy. However, I believe that we can afford the price and can maintain our record

of innovation and excellence. Yet this will not be done by

government policies; U.S. industry must build on its tradition

of activism, of risk taking. International standards setting

doesn't show up on third-quarter balance sheets, but I assure

you it shows up in long-term trade deficits. Ultimately, it is

individuals and companies, not governments, who must prevail.

29
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Questions and Answers

While the world, including the Government of Japan, moves closer to adoption of

OSI/ISDN international standards, what signal is the U.S. Government sending

when it has not taken a formal policy position on the issues? (T. Manakas)

Ambassador Dougan:

For those of you who don't like being dazzled by yet another acronym, ISDN

stands for Integrated Services Digital Network. This concept basically turns

telecommunications into the ultimate faucet: all sorts of electronic services,

whether voice, data, or broadcast, can all be sent on one system. There are a number of reasons why we have not come to closure on this, not the least of

which is that the United States and much of the rest of the world seem to

diverge slightly in defining ISDN. For example, many European countries look

at ISDN as an opportunity to reclaim monopoly ground on all communications

services where private lines, especially for computer and data-based services,

have not necessarily gone on the PTT system. From our perspective, the issues

are not just technical, but are also economic and political. I think we must

exercise a great deal of caution when we define ISDN. Frankly, we're going in

that direction on an incremental basis in the United States, allowing more and

more add-on services and modem conversion approaches to expanding services.

Furthermore, who's going to pay for this ISDN? It's like deciding you want a washing machine that has not only wash and dry cycles, but also has wash for

combination polyester/rayon, combination rayon/cotton, and getting into

specifics that the basic service user may not want to, or shouldn't be asked

to, pay for. These are some of the questions. I'm not saying that they cannot

be resolved, but they are rather extensive in nature. Thank you.

You have discussed the importance of testing/certification/data acceptance.

How do your negotiations address self-certification by the manufacturer?

(R. Daniels)

Ambassador Dougan:

I can add one part on self-certification. The amount of equipment coming out

daily is deluging many countries, certainly including the United Kingdom with

which we have been working. Don Abelson, who's sitting very demurely in the

front row, is the American master at this. We're continually working on pragmatic arguments. It now costs too much money to go to centralized testing

and certification places. When they talk about the amount of delay and the

expense, we leap in and say: "Aha! we've got some very good solutions for

you." We've been working with both Canada and the United Kingdom to obtain

either point-of-manufacture or self-certification and are making some progress.

This is an area with problems and a gearing towards a European certification

process. We've got to get ourselves into that certification merry-go-round.

Some other governments partially support their representatives at voluntary

standards meetings. Should the U.S. Government develop a means to provide

similar partial support? (J. Tesk)

31
Ambassador Smith:

My own view is that's going to be difficult these days, however desirable.

Ambassador Dougan:

I would really like to put in a commercial for the strategic planning parts of

your corporations. It is in your own self-interests. For the long term, it's

worth the nickels and dimes and thousands of dollars that you spend there.

Unfortunately, a return on investment isn't in the third quarter balance sheet.

How does USTR feel about private efforts between certification bodies in

various countries to facilitate mutual acceptance of test data? (H. Kontje)

Ambassador Smith:

Generally speaking, we're in favor. For example, we were recently in Europe

meeting with the Commission. They had a number of industry reps from their

standards organizations dealing in telecommunications, and we had our reps from

similar or counterpart organizations. One of our successes was the ability at

the Government level to reach the notion that the private sector reps or organizations should get together. Obviously, we're in favor of that to the

greatest degree possible. From our point of view, it's efficient and saves us money, which therefore saves you money. By and large, you're more able, more

capable, more knowledgeable about the issues at hand than we are, so we

obviously encourage it.

Technology is moving faster than standards work. Any plans to streamline the

process? (J. Blair)

Ambassador Dougan:

First of all. I'm not sure that's all bad, especially in the international

environment. One of the reasons that television, VTRs, and de facto direct

broadcast satellite services have come into being is that no regulations or requirements of either standards or laws concerning reception have thwarted

this. If things are going well without a standard, I'm not sure that a standard must be set.

Ambassador Smith:

Let me add one thing. As far as the Standards Code, for example in the dispute

settlement process that is now prescribed or envisioned in the Code, a general

problem is the time involved. This clearly needs streamlining or you're dead

by the time you fix the damage and no recovery is possible. In reality, we are

in a different age than we were even 10 years ago. It is true that technology

is outstripping or outpacing the ability of government organizations to react.

We just have to accept that and learn to live with it, unless we want a massive, permanent world bureaucracy to try to address these issues or try to

fit the pegs into the holes. I think it's something we just have to live with.

32
Can we get more rationale (scientific) on technical regulations or standards of

other countries? (R. FI ink)

Ambler: Can we get more information about the rationalities of technical

regulations or standards of other countries? Is that the question?

FI ink: What I am interested in is when the GATT sends us regulations, would it

be possible for us to get a scientific rationale for that regulation?

Ambassador Smith:

That gets to the transparency issue. To be given the scientific rationale for

standards setting has been a fundamental goal, and standards should be set only

on the basis of scientific rationale. As a case in point, I referred earlier

to the animal hormones case. The standard proposed by the European Community

appears to have no scientific basis at all according to information from

experts, including the Europeans. Trying to get their rationale from the

Community is like pulling teeth from snails. Transparency is obviously an objective not only of the United States Government in its negotiating goals in

Geneva, but indeed should be a fundamental underlying tenet of all further work

in the Standards Code area or for testing.

Ambassador Oougan:

Again, speaking only in the telecommunications context, it's a littleremembered fact that most of the CCIR and CCITT standards are recommendations,

not requirements. Generally speaking, European countries choose to look at

these recommendations as requirements. We very jealously preserve our right to

view them as recommendations and, quite candidly, we are working with other

countries to take more of that approach as well. A number of European

countries — and I would say generally most of the world in the

telecommunications realm — look to the ITU to solve their problems rather than

coming up with domestic answers. This is one reason they want standards to be

inclusive. For those who deal with the telecommunications world, that is

something to put into your back pocket and pull out when you seek more

flexibility in getting into a market.

What role do you see for the nation's providers of education, particularly

secondary and higher education, in addressing the standards problems inherent

in the trade deficit issues? (L. Walser)

Ambassador Smith:

I'm not sure I see a direct linkage with the trade deficit. If we're Johnnyout-of-step and the rest of the people are marching to the band, it's going to

hurt us on the trade side, but I think that's pretty indirect. I'm not sure I could make the reach from secondary and university education levels directly to

the trade picture. Doubtless, everything ultimately affects everything else,

but I would be chary of making any direct linkage.

33
While U.S. negotiators pursue foreign administrations to convince them to drop

technical barriers to trade, what signals are we (United States) sending

overseas when the National Bureau of Standards continues to pursue testing inhouse, particularly for computer standards? (T. Manakas)

Ernest Ambler:

The person who asked the question is with the Corporation for Open Systems. He

therefore knows perfectly well that the Corporation for Open Systems was

created for the private sector to deal collectively with the question of

protocols for open systems interconnect, an area that the Bureau of Standards

had pioneered in and which we were very proud to have pioneered in. Our

effort, which we put behind the international standards aspect, is now very

small because our budget was reduced and because the private sector is taking

over. You may recall that Ambassador Dougan had three points at the end of -her

talk, one being a plea for more activity from the private sector. We all know

that participating in international standards is very expensive. The meetings

in the fleshpots of the world go on forever. You send your best people at high

costs, and the Bureau of Standards doesn't like to do it either. However, we

take full responsibility without flinching for treaty obligations, for example

in the International Committee of Weights and Measures. That is the

Government's responsibility. This whole question, though, of the private

sector participating more strongly is true in many areas, for example, in

generic technology and R&D. We wring our hands about Japan Incorporated and

what they do over there, but we don't want an industrial policy at all like

that. This is an area where the game belongs to the private sector. As

Ambassadors Dougan and Smith pointed out, the Government is here to facilitate.

The degree of cooperation and general participation is not high in this

country, in part because people are brought up to compete in the private

sector. We have our own market, and we're trained to compete against, not

cooperate with, other companies: they're competitors! I don't think that

particular argument holds in a world market. In this particular area, as Ambassador Dougan said, cooperation is vital. To be effective, it requires

more of your participation and cooperation.

Ambassador Smith:

I was interested in your comment that delegates meet in the fleshpots of the

world: I have never heard Geneva, Switzerland, described as a fleshpot!

Ernest Ambler:

If you are a taxpayer in Little Rock, Arkansas, Geneva is a fleshpot of the

world! Personally, I well understand your point of view and I would just as soon never get on another airplane in my life.

BREAK

34
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Co-Chairman Ambler

INTRODUCTION OF DR. PETER M. BELL

WE WILL NOW TURN TO THE INTERNATIONAL STANDARDS CONCERNS OF THE U.S. BUSINESS

COMMUNITY.

OUR FIRST SPEAKER FROM THE PRIVATE SECTOR IS DR. PETER M. BELL, VICE PRESIDENT

FOR CORPORATE TECHNOLOGY OF THE NORTON COMPANY.

DR. BELL RECEIVED HIS DOCTORATE FROM HARVARD UNIVERSITY IN GEOPHYSICS IN 1963,

BUT HE HAS BROAD SCIENTIFIC CREDENTIALS. HE IS ON THE GOVERNING BOARD OF THE

AMERICAN INSTITUTE OF PHYSICS; IS A FELLOW OF THE AMERICAN CHEMICAL SOCIETY;

IS GENERAL SECRETARY AND TREASURER OF THE AMERICAN GEOPHYSICAL UNION; AND

BELONGS TO SEVERAL OTHER PHYSICS, CHEMISTRY, GEOLOGY, AND GEOPHYSICAL

SOCIETIES.

DR. BELL HAS BEEN HONORED AS A GUGGENHEIM FELLOW AT THE UNIVERSITY OF UPPSALA;

AS A FELLOW OF THE CARNEGIE INSTITUTION; A VISITING SCHOLAR AT CAL TECH; AND

VISITING PROFESSOR AT JOHNS HOPKINS AND CUNY (BROOKLYN). HE HAS RECEIVED MANY

AWARDS FROM A HALF DOZEN OR MORE PRESTIGIOUS INSTITUTIONS.

DR. BELL WILL RAISE THE QUESTION OF CURRENT RULES CONCERNING TECHNICAL DATA

THAT DO NOT PROTECT THE NATIONAL INTEREST WHILE ENCOURAGING DEVELOPMENT OF

COMMERCIALLY VIABLE PROSPECTS (AS OPPOSED TO GOVERNMENTAL SALES). HE'LL TALK

ABOUT UNCERTAINTIES AND CONFUSION CREATED FOR INDUSTRY BY THE SEVERAL COGNIZANT

GOVERNMENT AGENCIES.

36
Commerce Regulations

A Barrier To U. S . Manufacturing Industry

Peter M. Bell

Vice President

Norton Company

ABSTRACT

Currently, rules for the regulation of technical data do not

achieve the goals of protecting the National Interest while encouraging developmental activities for commercially viable prospects (as

opposed to governmental sales) . Controls on the export of technical

data are complex and confusing, often resulting in the cessation of

U. S. Commerce development programs. Development of advanced, highperformance materials and products is being pushed offshore by the

procedures. In some instances, the DOD must acquire critical

components from foreign nations who hold their technology as

proprietary. Creation of a single government regulator could help to

alleviate the uncertainty and confusion that exists now between

industry, the Commerce Department, the Patent Office, and the DOD.

37
Opening Remarks

Our Industry is one of a spectrum of material manufacture - ceramics and abrasives, metals, and plastics.

My discussion is to focus on the high tech end of these

materials which we need to develop to advance our core

businesses

We start by working with the Department of Defense in

developing the most advanced and high-performance materials

and products for the military - these programs are classified and should be so.

The problems we are addressing today are related to the

eventual process of taking advantage of the technology

in the form of spin-offs for nonmilitary business.

Even if the secrecy orders on a given material are

obsolete - as evidenced by its global availability - we cannot disclose publicly the specific technology or

even the fact that the product involved has a

secrecy order affecting it in attempts to solve the

problems

Thus today, I have a difficult job in giving this talk.

33
Introduction

U. S. manufacturing is a highly competitive undertaking in

this decade. The markets that are served are global, and thus

competitors are, in part, foreign nationals. The efforts of the

United States government to protect the National Interest must be

made with the consideration that global competitors of U. S.

manufacturers have no such restrictions. Steps to control or

regulate technology transfer today extend even to imposition of

secrecy orders on patents. Filings of foreign patents are prohibited

in such cases (except for certain burdensome procedures that involve

secret filing processes with NATO Allies). Non-U. S. competitors are

free to obtain international patents and thus exclude U. S.

manufacturers. The issues of regulations, secrecy orders and

technology transfers in terms of the U. S. export position are

especially relevant to the development of advanced, high performance

materials. The high tech end of materials development is needed for

U. S. defense applications. Such development by U. S. industry

provides essential spin-offs for advancement and competitiveness in

core businesses. There would be less conflict of interest if

regulations were applied carefully and judiciously. Proposed

regulations should be tightly monitored and should not be imposed

without adequate review and demonstration of need. That such care is

not being taken currently is evidenced by the Military Critical

Technologies List (MCTL) . First of all, the list is classified and

not available to the public. Technologies placed on the list are

included for "national security" without explanation.

39
In many instances, competitive products are already available

outside of the United States. Once a restriction has been placed

there is no straightforward route to getting it removed. An apparent

need exists to clarify the authority for placing restrictions. Under

the present system one may have to deal with the Commerce Department,

the Patent Office and the Military to seek responsible action.

Usually, the process is frustrating, costly, and not successful.

Creation of a single government regulator could help to alleviate the

circumstances

Results Of Current Policy

That the rules now in place are anachronistic, that there are

too many regulators involved, that the results of the rules are

seriously impeding and damaging to U. S. manufacturing industry

should be evident. Unfortunately, most of the best examples have not

been publicized because secrecy orders prohibit disclosure. Even the

fact that a given product or material has a secrecy order affecting

it cannot be disclosed. Nonetheless, the effects of current policy

are severe and are being voiced.

A few examples:

1) Boston Globe , December 16 , 1964

"... federal officials have disrupted (scientific) meetings

by asserting that technical data on the program was subject to

export controls ..."

40
Scientific communications can thus be interrupted for the

wrong reasons.

2) Industry Magazine , March 1986

Article Titled "Export Controls and Foreign High Tech"

"Export controls imposed by the U. S. government often

defeat their purpose because . . . they encourage the

development of advanced technologies abroad . . . drawn out U. S. government export policies are contributing to the success of our European, Japanese and

Soviet competitors ..."

"The list of so-called critical technologies reflects

American naivete having been developed with no meaningful examination of foreign availability in the marketplace.

3) Worcester Evening Gazette. January 12 , 1987

"U. S. controls on exports of high technology items to Soviet

bloc nations not very effective while costing hundreds of jobs

and $9 billion a year."

41
4) Business Week, January 26 , 1987

"The government efforts to block the export of high technology

products and information . . . cost the nation $17 billion last

year - and did not significantly improve national security."

5) Business Week, February 16 , 1987

"... export controls cost U. S. businesses $9.3 billion in

1985 . . . we've only succeeded in losing our markets to our

allies ..."

6) The Wall Street Journal , March 13 , 1987

Secretary of Commerce, Malcolm Baldridge is quoted as saying

"For too long the bickering in Washington has been one more

unfair trade barrier interfering with the flow of

legitimate trade"

A Syndrome

The effects of the restrictions have followed a pattern or

syndrome. First, U. S. industry develops a technology in close

competition with developments abroad. Next the U. S. technology is

placed on the list (MCTC) and deemed secret. Foreign competitors

obtain patents abroad, develop global markets, and become more

advanced. U. S. development has slowed because of the restrictions,

and foreign competition has advanced.

42
A well-known example is the one about advanced materials for

high-tech bearings. The U. S. had leadership until slowed by

restrictions. The syndrome operated as follows. Japanese industry

was not restricted and developed markets at home and abroad, thereby

gaining leadership in the bearing material market. According to the

story, the bearings were used in the U. S. Cruise Missile - that is,

the Japanese bearings. Beyond the published international patent

information, the U. S. military faced a dilemma. The Japanese

refused to tell the U. S. government anything about the bearings.

Meanwhile, U. S. industry suffered the loss of technology as the

military was in a sense being held "hostage" by a foreign government.

The circumstance today is that U. S. manufacturing often is not

far ahead of its foreign competitors. The competition is quite

close, in numerous materials and product lines. Thoughtless,

unilateral restrictions by the federal government are thus hindering

U. S. manufacturing industry greatly.

What the manufacturing industry needs is freedom to compete if

it is to survive, which it must if the national interest is to be

served. We must not ever be in a position where the DOD has to

acquire critical components from foreign nations, whose industries

hold their technology as proprietary.

Proposed Government Action

Currently, the U. S. government regulators include the State

43
Department, the Nuclear Regulatory Commission, the Treasury

Department, the Department of Defense and the Commerce Department.

It is proposed that before any regulations or restrictions be

applied, a given case be brought before a single body - one that can

evaluate foreign availability and the threat to national security.

Ideally, the body would require stringent demonstration that a given

material, product, or technology merits restriction. Regulations

would require annual renewal.

In such a system one would have to re-examine the terms

"technical data" and "export" in the light of the fact that most U.

S. manufacturing industries have been forced to follow their markets

offshore. There are many employees today of U. S. manufacturing

industries who are not U. S. citizens or legal residents either in

the U. S. or outside.

Until a single regulatory body can be fomed to facilitate the

regulatory process, and deal with the numerous problems faced by

U. S. global manufacturing industries, foreign competitors will have

a great advantage.

44
Co-Chairman Ambler

INTRODUCTION OF DR. PETER R. BRIDENBAUGH

OUR NEXT SPEAKER IS A DISTINGUISHED ENGINEER. DR. PETER BRIDENBAUGH, VICE

PRESIDENT FOR RESEARCH AND DEVELOPMENT OF THE ALCOA CORPORATION, RECEIVED HIS

B.S. IN MECHANICAL ENGINEERING AND M.S. IN METALLURGY FROM LEHIGH UNIVERSITY,

THEN A PH.D. IN METALLURGY FROM M.I.T.

IN 1968 HE JOINED ALCOA RESEARCH LABORATORIES AND ROSE THROUGH THE RANKS OF

SECTION HEAD AND MANAGER OF FABRICATING METALLURGY, QUALITY ASSURANCE MANAGER

FOR TENNESSEE OPERATIONS, AND DIRECTOR OF ALCOA LABORATORIES.

DR. BRIDENBAUGH SERVES ON THE ADVISORY BOARDS OF FIVE UNIVERSITIES AND ON

COMMITTEES OF THE NATIONAL SCIENCE FOUNDATION AND THE NATIONAL ACADEMY OF

SCIENCES. A MEMBER OF SIGMA XI, THE AMERICAN SOCIETY FOR METALS, AMERICAN

INSTITUTE OF MINING AND METALLURGICAL ENGINEERS, AMERICAN SOCIETY FOR

ENGINEERING EDUCATION, INDUSTRIAL RESEARCH INSTITUTE, AND DIRECTORS OF

INDUSTRIAL RESEARCH.

HE WILL FOCUS TODAY ON TECHNICAL PREEMINENCE AS THE ESSENTIAL INGREDIENT IN

INTERNATIONAL INDUSTRIAL COMPETITIVENESS, DISCUSSING ELEMENTS OF TRADE

STANDARDS AND - IN PARTICULAR - PROTECTION OF INTELLECTUAL PROPERTY RIGHTS,

NECESSARY TO FULLY LEVERAGE THE ADVANTAGES DERIVED FROM SCIENTIFIC AND

ENGINEERING LEADERSHIP. HE SEES A VITAL ROLE FOR STRATEGIC ALLIANCES BETWEEN

INDUSTRIAL, ACADEMIC, AND GOVERNMENT LABORATORIES.

45
"STANDARDS FOR TOMORROW'S MATERIALS INDUSTRY"

Remarks by

Dr. Peter R. Bridenbaugh

Vice President, Research & Development

Aluminum Company of America

Conference on Standards & Trade

U.S. Department of Commerce

Washington, DC

1987 May 05

Good morning, ladies and gentlemen. Normally, I begin my speeches by telling

the audience what a pleasure it is to share my thoughts with them on the

subject at hand. Those are usually ones that I'm fairly familiar with and

feel pretty confident about... the aluminum industry, new materials, managing a large research and development organization. But today, I must tell you my

comfort level isn't quite that high... a materials scientist up here talking

about nontariff barriers to foreign trade in front of an audience whom I'm

sure knows a great deal more about the subject than I.

I feel a bit like an old fellow I once heard about whose proudest experience

was surviving the famous St. Patrick's Day flood in Pittsburgh. Now, except

for his harmless compulsion to tell any listener his tale, he was a good sort

and eventually, when he died, found his way to heaven.

On arrival, he had the standard interview with St. Peter. "Your papers are in

order, so we welcome you to heaven. I'd like to ask if you have any special

request." "Yes," the old fellow replied, "I'd like to tell some of my fellow

angels about how I survived the great Pittsburgh flood of 1936." "We'll see,"

St. Peter replied and left. When he came back, he said "It's all set. You're

booked into Conference Room C on cloud 17 today at 3." "That's great," said

the old man. "Just one thing," St. Peter added, "you need to know that Noah

will be in the audience."

I can't think of a more appropriate time for a conference on standards and

trade. The subject has been on the front pages of our nation's newspapers and

magazines almost continuously in recent weeks. The topic has been widely

discussed and hotly debated.

As I prepared for my talk this morning, it became apparent to me that even the

smallest details of this issue cannot be considered without an appreciation

for the extremely complex and multidimensional aspects of international

cultures ... and the subsequent extensions of every nation's mores and folklore

that serve to form and focus their governmental policies and perspectives on everything from education to intellectual property rights. Only one thing

appears certain to me... the economic war we are engaged in with our military

allies is just as real as our political confrontation with the Soviets. A

loss on either front would be devastating. A free international marketplace,

governed by fair trade practices and policies, is a fundamental, strategic

necessity for our nation's industrial survival.

46
With a clearer perspective around the importance and complexity of this issue,

I don't envy those whose job it is to sort through the myriad of threads that

must be assembled and woven together to create a strategically and

tactically-sound national policy on trade. While I am no expert on this

subject, I do have some thoughts 'and information that I hope will be pertinent

to today's discussions. Perhaps the most important contribution I can make is

to brief you on the materials industry, its recent... and rather

tumultuous. . .history .. .and the scientific, engineering and manufacturing

forces that are shaping its future.

From a technological point of view, two on-going events are dramatically

impacting the materials marketplace today. First, and foremost, is a revolution in the field of materials science that has led to the development

of new materials and to the introduction of completely new materials systems.

These laminate and composite systems, which combine* diverse materials to

optimize the inherent properties of each, are extremely complex yet very

promising. And they are being developed with a rapidity unprecedented in our

industry's technical history.

Stemming from this revolution has been a corresponding, and dramatic, increase

in the stringency of the design criteria and product requirements coming from

our customers. We are experiencing a pull from the marketplace for a diversity of structural materials systems never before experienced by

materials manufacturers.

Today, what we accept as scientific fact in the materials industry, only

10 to 15 years ago might have been regarded as science fiction. Yesterday's

empirical methods are being replaced by quantitative, computer-based research

methods. We are beginning, not only to understand the structure - property - process - performance continuum, but also to translate this understanding into

mathematical equations to create process models. These models are in turn

giving us the ability to replace laboratory experiments with computer

simulations. The resulting quantity and quality of the experimental work has

been truly amazing.

Alcoa's commercial and technical agendas are founded in the heart of this

scientific revolution. We have broadened our materials thrusts by

establishing an internationally-recognized ceramics research program, building

an aggressive, fundamentally-deep research portfolio in polymers, and starting

an advanced manufacturing center for composites. At the same time, we have

continued to pursue our research in metals, primarily in aluminum, but also in

titanium, magnesium and other, more exotic metals.

In ceramics, we have used our fundamental knowledge of ceramic powders to

forward integrate into the production of new, value-added products ... such as multi-layered ceramic packages and armor systems.

In metals research, we are developing constitutive, tribological and field

equations that will permit us to create process models for traditional metal

manufacturing techniques, as well as for non-metallics and composites

manufacturing.

These and other technological building blocks, such as interface science and

microstructure control, are necessary for the successful combination of

metals, ceramics and polymers into the laminate and composite material systems

I mentioned a moment ago.

47
These kinds of sophisticated systems are being driven by our customers .. .whose

design specifications and demand for advanced structural materials are

increasing geometrically.

Several excellent examples of the rapidly growing demand for advanced

materials come from the aerospace industry. The transatmospheric vehicle and

manned space stations, for example, will require materials that are—in

reality highly-engineered systems.

Tomorrow's materials requirements are not confined to high-end materials and

applications. Next-generation food packages, for instance, will be dominated

by multi-layer, high-barrier polymer laminates .. .whether we will be dealing

with so-called "ytippie" food or we are trying to solve preservation problems

associated with underdeveloped nations.

The traditional role of the materials industry as the producer of

semi-fabricated, high-volume, products is being irreversibly altered. To

justify the cost of R&D and next-generation capital facilities, we will have

to forward integrate into the production of value-added products and systems.

We also must develop and implement highly-f lexible material and product

manufacturing facilities that will allow us to produce a multiplicity of

products from one capital base. We simply can no longer afford behemoth

facilities dedicated to just one product.

Yesterday's monolithic materials and their companion manufacturing facilities

are becoming modern dinosaurs. The rigid mind-sets that have built up around

these mass-produced products and their manufacturing mores also must become

extinct. Even though I am intrigued by the theory that it was a dust cloud

created by the impact of a meteor that did in the dinosaur, I am still

basically in the Darwinian camp that stresses adaptability as the ultimate

tool for survival. The materials industry must learn to embrace, adopt and

implement rapid change if it is going to transcend its own pre-history.

Remember the time when we only had one kind of Coke?... when our key decision

on a new car was either a two-door or four-door .. .and when our next pair of

tennis shoes was either going to be white or black? It wasn't that long ago.

But that time is gone. And with it have gone new opportunities for the huge

volumes of semi-fabricated materials required to make them. Today, a wing

designer starts with a final product in mind and tells us what materials are

necessary. But instead of one material, six may be required, all integrated

into a single materials system. The ability to make them is up to us. The challenge for those of us who supply these diverse, technically-rich

materials. . .and those of us who will remain successful in the materials

industry .. .will be to discover, design, characterize and manufacture

low-volume, highly-diverse product lines. Product performance will dominate

materials selection, not the properties of monolithic ingot. Quality and

customization are becoming the basis for competition and will rise to join

cost as key determinants of profit.

And, because of lower volumes and higher product diversity, flexible

manufacturing will be absolutely essential.

43
Flexible systems view materials synthesis, product manufacturing, materials

specification, and product design and testing as layered stages as opposed to

separate, serial steps. This kind of logic is vital in the conceptualization

and production of advanced materials.

At this juncture, major challenges and opportunities exist for those of you in

the standards arena. Destructive and non-destructive techniques for testing,

evaluating and characterizing new materials must be developed and implemented.

I've recently become aware of a new, ultrasonic inspection technique that

permits the detection of flaws in green ceramic parts still in the mold. This

NDE technique, may serve as a major stimulus for the advanced ceramic

industry, where product consistency has retarded market acceptance of ceramic

components.

A A similar need exists for graphite composites. Until a more cost-effective

method is discovered for finding subsurface flaws or damage in these parts,

they will never realize their commercial potential.

When you combine the pressing need we are experiencing today for a new and

extremely sophisticated set of design codes and specifications to support the

complex materials systems being developed. . .with windows of commercial

opportunity that are measured in months instead of years... the magnitude of

this issue then clearly into focus. The need for close cooperation,

communication and mutual understanding of commercial and technical

requirements between governmental standards experts and their counterparts in

academia and industry is greater today than it has ever been.

Through intense mutual efforts we must develop codes and specifications for

emerging materials systems with some degree of confidence before we can expect

our trade representatives at the GATT negotiating table to have our technical

information and resources included as international standards.

Inclusion of intellectual property rights in the Uruguay Round of GATT is very

encouraging. We feel it is very important to expand the scope of patent

coverage to accommodate new and developing product and processing technologies

in our industry. We also hope that an internationally harmonized intellectual

property system can be agreed upon that will prohibit product and process

patent infringement at the point of production, not at a nation's

borders. . .and one that will modify or eliminate compulsory licensing.

Harnessing the forces of today's scientific revolution. . .and combining this

technical understanding with some enlightened change in our industrial

behavior .. .are vital, not only for materials people, but for all of our country's basic industries.

All we can... and should. .. expect from our trade representatives is a level

playing field upon which to compete. It runs against the American spirit to

seek a head-start or unfair advantage. All we ask is a set of international

rules that guarantee both free and fair trade. Given those, we'll sink or swim based on our own ingenuity, innovativeness and willingness to do the work

it takes to win.

49
Sometime, I think I have to agree with the late, and great, Pogo. "I have

seen the enemy, and he is us." In recent years, I have begun to see what I perceive at times to be an almost adversarial relationship between some of the

vital elements in our nation's basic industrial inf rastructure. .. science,

engineering, manufacturing. .. our government and financial institutions.

For some reason, we've allowed barriers to exist in our organizations between

R&D, engineering, sales and marketing. They simply must come down. For most

of this century, our government's role has been to prohibit cooperation,

collective research and strategic alliances between this nation's business

community. ^This objective was well-intentioned and perhaps necessary for a time. But today, quite frankly, the effects are deleterious. Cooperative,

collective, strategic alliances between business, academia and our government

are absolutely essential and our legislators must 6e made to realize these

facts... our financial institutions need to dedicate much more of their time,

effort and expertise to advancing the interests of our nation's basic industry

through long-term investment strategies rather than being driven by short-term

financial gain.

Each player in this infrastructure has a complimentary role to play, one that

has too often become biased by mistrust and misunderstanding. That has to

change.

In conclusion, I would assert my belief in scientific knowledge as the

foundation for human progress and my complete confidence in America's ability

to continue to lead the world in the development of this most valuable

resource. But we must come to grips with the concept of an international

economy and do whatever is necessary to assure equal footing on the floor of

the economic arena. Our country cannot effectively maintain its standard of

living in the absence of a basic manufacturing capability. Somewhere,

somehow, someone must make a product and sell it at a profit. That's the only

way to create real wealth. And our government .. .you and I... must do whatever

is necessary to maintain America's manufacturing infrastructure. That's truly

the bottom line.

Thank you.

50
Co-Chairman Ambler

INTRODUCTION OF C. SCOTT KULICKE

SCOTT KULICKE BLENDS INDUSTRIAL AND STANDARDS LEADERSHIP. HE IS BOARD CHAIRMAN

AND CHIEF EXECUTIVE OFFICER OF KULICKE AND SOFFA INDUSTRIES, THE WORLD'S

LEADING SUPPLIER OF CAPITAL EQUIPMENT AND SYSTEMS FOR ASSEMBLING AND PRODUCING

SEMICONDUCTOR DEVICES.

MR. KULICKE ATTENDED LAFAYETTE COLLEGE AND THE WHARTON SCHOOL OF BUSINESS,

WHERE HE RECEIVED HIS DEGREE IN ECONOMICS. HE JOINED KULICKE AND SOFFA IN 1973

AS MANAGER, FAR EAST OPERATIONS, BASED IN HONG KONG. HE BECAME INTERNATIONAL

MARKETING MANAGER, THEN PROJECT MANAGER FOR THE AUTOMATIC WIRE BONDER, MARKING

THE TRANSITION FROM MECHANICAL MACHINES TO COMPUTERIZED SYSTEMS. HE IS ALSO A

DIRECTOR OF THE SEMICONDUCTOR EQUIPMENT AND MATERIALS INSTITUTE, KNOWN AS SEMI.

MR. KULICKE CONSIDERS STANDARDS A KEY TO OPENING UP MARKETS FOR U.S. COMPANIES

AND AN IMPORTANT OBJECTIVE FOR U.S. INDUSTRIES THAT WANT TO COMPETE IN

INTERNATIONAL MARKETS. THEY REDUCE COSTS AND ASSURE QUALITY. HE ASSERTS THE

NEED FOR USER INPUT, ESPECIALLY FOR TODAY'S COMPUTER-ASSISTED PRODUCTION

ENVIRONMENT.

MR. KULICKE BELIEVES THAT WE SHOULD AGGRESSIVELY SEEK ACCESS TO FOREIGN

NATIONAL STANDARDS BODIES, WHILE WELCOMING NON-DOMESTIC PARTICIPANTS INTO U.S.

STANDARDS ORGANIZATIONS.

51
Presentation by C. Scott Kulicke

Chairman and CEO, Kulicke and Sofia Industries, Inc.

For several years, I served as Chairman of the Standards

Program for the Semiconductor Equipment and Materials Institute,

Inc. or (SEMI). SEMI is an international trade organization

representing about 1,200 members worldwide, all of whom provide

equipment, materials or services used in the production of

semiconductor devices. We serve a rapidly changing industry,

where product life cycles are at best four or five years long and

in many cases as short as one or two. Our approach to standards

has been to modify some of the more traditional standards making

techniques, particularly those we borrowed from ASTM, but

modifying them so that we can respond to the dynamic nature of

our business.

In my standards capacity with SEMI, I had an opportunity to

look firsthand at how standards were developed and promulgated.

My remarks this morning will be drawn from that experience. I

will look at standards from three points of view —the benefits of

the standards making exercise, the benefits of participating in

the process of making standards, and finally some of the public

policy implications of standards, especially in international

trade

SEMI got started in the standards business about 12 years

ago. When the semiconductor industry was first starting to

automate its production equipment, that automation took the form

of presenting cassettes of wafers to process machinery, as opposed

to the traditional loading of wafers one at a time, by hand. It

52
turns out that if you took the then current 3 inch wafers from

several different wafer manufacturers and tried to put them in

the cassette of several different cassette manufacturers, one of

three things would occur. In some cases, the wafer would fall

straight out the bottom of the cassette. In other cases, the

wafers would not fit in at all. And in some cases, the wafer and

cassette would actually work together. Low and behold, we had

discovered that not everybody could agree on how big 3 inches

actually is. Some bright fellow concluded that what the

industry needed was some standard on how to specify the size of a wafer and its matching cassette.

From that fairly mundane and predictable start, SEMI*s

standards making activities today have evolved into an

organization staffed by over 2,000 volunteers representing

suppliers and users on three continents. The scope of the

standards we write today range from wafers and cassettes (only

today we are arguing about how big 8 inches really is), to

semiconductor grade gases, to semiconductor packaging materials,

to machine interface and communication standards so that today's

intelligent process stations can pass information among

themselves and to host computers.

The benefits to our industry of these standards are many.

The economic advantages of standardized products are, I think,

fairly obvious. The manager of a standardized product is not

faced with having to build a multitude of slightly different

products, each conforming to a different customer's whim or

fancy. In this respect, inventory management and manufacturing

scheduling problems are minimized. The user also benefits in

knowing that products from different vendors can be used

53
interchangeably, without significant engineering evaluation.

These kinds of advantages were true 12 years ago when we started

with the wafer and cassettes as in the example given above. They

are even more true today with our most ambitious standard yet,

the Semiconductor Equipment Communications Standard or SECS for

short

Of our 1,200 different members, about one-third supply

pieces of manufacturing or process control equipment which are

now being integrated together to form automated factories.

Imagine if each of these companies, or alternately, if all of our

customers, each opted for a different communication protocol

between the different machines in their factories. The

semiconductor industry would be facing a software writing task

that could consume all the programmers in the country. The

obvious need was for a standard communication protocol. SEMI

stepped up to this challenge and has, over the last few years,

generated and published a communication protocol which allows

machinery of any manufacturer to communicate with machinery of

another manufacturer and/or a host computer. Each company*s

programming load has been reduced to simply making their

equipment perform to the SECS protocol and each users automation

goals have been nicely refined to that of bringing their

factories up to SECS standards. In short, everybody’s

programming costs have been slashed, and progress has been made

that is much more affordable.

54
The point to be drawn from all this is that the principle

benefit of standards is economic. The use of standards promotes

efficiency and progress, allows industries to move forward, and

causes companies to create both jobs and profits.

Besides the kinds of benefits described above, there is

another benefit to standards making activities, at least in the

semiconductor business. It is what I alluded to above when I

mentioned the benefits of the process of making standards. In

order to develop this thought, let me make the distinction

between the product of a standards making activity, and the

process of making standards. That is, the distinction between

the written standards that we publish in our books, and the

process whereby suppliers and users sit around a table and talk

about their technical problems and potential solutions. It seems

to me, that there is a great benefit to a supplier from

participating in standards discussions. In many respects,

standards making is marketing, in that you get a better

understanding of your customer’s problems and you get to shape

his thinking about potential solutions to those problems.

I realize that I am, at this point, treading on very thin

ice with a lot of standards specialists, who have rightfully

fought for years to keep commercials and commercialism out of the

standards arena. The compromises hammered out at the standards

meetings need to represent the best solutions to industry’s

problems. To accept the proposals of a dominant supplier runs

55
the risk of impeding progress and possibly anti-trust action.

Accepting least common denominator standards that suit everyone

will cause leading edge companies to move beyond the published

standards, creating exactly the kind of marketplace chaos that

standards are supposed to avoid.

At SEMI, our solution to these problems has been reliance on

the user. We believe that a standard that lacks user input is

going to be ineffective. SEMI aggressively recruits users,

knowing full well that users will keep all us suppliers honest,

and in line. That same user will continually challenge us to

improve our product and to stretch our capabilities, all of which

brings me back to the process benefit of making standards. By

having that user in the meeting room, talking about his technical

problems, and where his company would like to go, we have created

for our membership a tremendous marketing resource.

I continue to be amazed that a lot of our members

underestimate the importance of the information conveyed at

standards meetings, or the help that a standards meeting can give

to a company to position itself. This seems to me to be an

American blind spot. Our international trade competitors

understand much better than we the use of standards in protecting

and penetrating international markets. The best example is the

Japanese use of standards as a non-tariff barrier. Which brings

us to the international aspect of standards.

SEMI's standards making activity was originally a domestic

only affair since the semiconductor industry was an industry

dominated by Americans. Times have certainly changed, and many

of our members are confronted with strong foreign competition.

This confrontation has, in part, been played out through

56
standards. SEMI has always opened its standards meetings to any

interested participant, and very early on established

fruitful working relationships with DIN and SITELESC, in Germany

and France respectively. By and large, these organizations have

adopted some SEMI standards as their own and/or have recommended

people to SEMI when problems have arisen in our particular area

of expertise. Japan is a different story.

Japan was late in. starting standards making activities in

the semiconductor equipment and materials area. The Japanese

semiconductor industry was dominated by four big electronics

companies —NEC, Hitachi, Toshiba, Fujitsu —each of whom evolved

their own corporate standards in many areas. Second tier

electronics companies tended to come under the umbrellas of one

of the big four. Therefore, neither MITI or JEIDA knew exactly

how to react when SEMI first approached them, about five years

ago, to discuss cooperation in standards. Not only did they not

have a model for the kind cooperation we suggested, but it

appears in retrospect, that they were at the start of a long term

drive for Japanese dominance of the semiconductor equipment and

materials industry, in support of their goals in the

semiconductor industry. The idea of cooperation on standards was

not attractive to them. So after several years of "consensus

building" on the part of the Japanese, SEMI finally elevated the

issue within the U.S. government to the Trade Representatives

office. Only after direct prodding at a fairly high level has

there been significant movement on the part of the Japanese. And

57
let me say on behalf of the Japanese that we believe the movement

has been real, not the sham liberalization reported by other

industries.

The kinds of progress we are seeing in Japan include the

adoption of some of our standards by Japanese standards making

organizations, who are publishing them in Japanese along with

their own work. Even here though, the Japanese suggested a few ’’minor revisions,” something we rejected.

SEMI has consistently fought for adoption of worldwide

standards. Our feeling is that a standard is not really a standard unless its standard, and that unilateral revisions would

have a significant deleterious affect on non-Japanese suppliers.

We have also gotten remarkably supportive response from

attempts to organize our Japanese members into American style

standards making groups. The Japanese traditionally rely on the

’’panel of experts” approach to generate a standard, at least in

this industry. We, of course, adopt a more democratic approach

of having all the opinions argued out in a ’’let the best idea

win” fashion. The Japanese seem interested in trying our

approach, as well as attending our standards making meetings in

other places in the world.

What I have presented here in the public- policy part of my

talk is a story with a happy ending, at least so far. But it is

in contrast to many other international standards stories that

don’t have a happy ending; where either implicit or explicit

standards have been adopted in order to close foreign competition

out of a marketplace. In most cases, this is a problem bigger

than any one company or trade organization can tackle. Indeed,

its truly an issue of public policy which needs to be addressed

58
by the government.

SEMI has taken a big, and so far, successful step towards

the creation of truly international standards. Perhaps our

success comes from organizing more on industry than on geographic

lines. Unfortunately, I believe our story is unusual. Most

trade organizations or standards making groups have a decidedly

nationalistic flavor to them, causing standards that are rarely

portable across national boundaries, for reasons that range from

protectionism to parochialism. There is, of course, no easy fix

to this problem. Nonetheless, I would conclude my presentation

with a call for an explicit and active policy from the U.S.

government to first fight to harmonize incompatible standards

between ourselves and our trading partners, and second, and even

more important, to actively work towards a goal of having

emerging standards be adopted on an international scale, as

opposed to nation by nation. It is a lot easier to coordinate

new standards, then rewrite existing ones. I would suggest that

the first objective be spearheaded by Commerce’s International

Trade Department and the office of the Trade Representative.

And let me add about the problem of harmonizing, that we are our

own worst enemy. Too many Americans believe that all those

"foreigners” ought to be happy to accept our wisdom about how

things ought to be. The size of our domestic market makes us

unwilling to compromise. This is our problem, not theirs.

59
The second objective might best be served by the National

Bureau of Standards, coordinating many private standards making

bodies in the U.S. with their overseas counterparts. SEMI in

particular has a long and very successful history of partnerships

with NBS on just this kind of issue.

In both cases, please focus not just on the standard itself.

Work to get American com panies involved in the dialogue, or, as I have called it above, the process of making international

standards. The process is too valuable an experience to leave to

government bureaucrats or standards professionals. It*s part of

repositioning American companies for international trade.

60
Questions and Answers

Doesn't ANSI already coordinate international standards development?

C. Scott Kulicke:

We have not had particular success in following that traditional methodology

for international standards. That's not meant to be critical of ANSI, but

simply reflects the time realities of our business. If we go through the

normal generation of a standard, then coordination through the ANSI mechanism,

at least as we have experienced it, the standard is outdated by the time it

becomes accepted. We needed a streamlined approach, and the best way in our case was to bring international suppliers and users in to generate a single

industry standard as opposed to a national standard. We shouldn't create an American standard and a Common Market standard and a Japanese standard, then

attempt to rationalize them and harmonize them after the fact. We should try

to generate the standards in parallel, up front and eliminate that extra leg,

which takes market-destroying time.

Do you see standards as leading or restricting innovation? (L. Galowin)

C. Scott Kulicke:

That's a hard question. Inevitably, standards lag behind the state of the art.

We have to compromise absolutely best or potentially best solutions for near

term best solutions. Standards in this respect are a mixed bag.

61
Co-Chairman Ambler

INTRODUCTION OF DR. ROBERT BABOIAN

WE TURN NOW TO PRIVATE SECTOR PARTICIPATION IN INTERNATIONAL STANDARDIZATION

AND WELCOME THE FIRST OF TWO CHAIRMEN OF THE BOARD OF MAJOR U.S. STANDARDS

ORGANIZATIONS.

DR. ROBERT BABOIAN CHAIRS THE ASTM BOARD AND HEADS THE ELECTROCHEMICAL AND

CORROSION LABORATORY OF TEXAS INSTRUMENTS (TI). HE RECEIVED HIS B.S. IN

CHEMISTRY FROM SUFFOLK UNIV., AND PH.D. FROM RENSSELAER POLYTECHNIC INSTITUTE,

THEN A FORD FOUNDATION POST-DOCTORAL FELLOW AT THE UNIV. OF TORONTO AND A

SENIOR RESEARCH ASSOCIATE THERE BEFORE JOINING TI IN 1966. HE ESTABLISHED TI'S

CORROSION LABORATORY IN 1968 AND IS A TI SENIOR FELLOW.

DR. BABOIAN HAS BEEN ACTIVE ON ASTM AND ISO COMMITTEES ON CORROSION OF METALS

AND HAS HELD MANY ORGANIZATIONAL OFFICES IN ASTM, THE NATIONAL ASSOCIATION OF

CORROSION ENGINEERS, AND THE SOCIETY OF AUTOMOTIVE ENGINEERS. HE WAS A SPECIAL

CONSULTANT TO THE NATIONAL PARK SERVICE ON THE STATUE OF LIBERTY RESTORATION

PROJECT AND EDITED AN AMERICAN CHEMICAL SOCIETY BOOK ON ACID RAIN.

DR. BABOIAN WILL SPEAK TODAY ON THE "INTERNATIONALIZATION" OF ASTM, INCLUDING

PROMOTION OF WORLD-WIDE USE OF ITS STANDARDS, PARTICIPATION IN INTERNATIONAL

STANDARDS DEVELOPMENT, COOPERATIVE EFFORTS WITH THE STANDARDS BODIES OF OTHER

COUNTRIES, AND OPENNESS OF ITS MEMBERSHIP TO PARTICIPANTS FROM ALL OVER THE

WORLD.

62
ASTM PARTICIPATION IN INTERNATIONAL STANDARDIZATION

Robert Baboian

Chairman of the Board

ASTM

Philadelphia, PA 19103

I am pleased to be here as a representative of the 30,000 members of

ASTM who have a keen interest in international standardization. Today,

the ASTM voluntary consensus standardization system has stimulated work in

over 2000 technical committees responsible for 8000 standards as well as a wide range of publications including special technical publications on

selected areas of importance. Standards have become an essential part of

the socio-economic development of all nations. They open channels of

communications and commerce, they promote understanding of the products of

technology, and they form the basis for achieving a higher quality of

life.

It is a pleasure to be a part of this continuing dialogue between

the government and private sector with a primary objective of increasing

understanding of the complexities of the international marketplace.

Standards are important in a global economy where the users needs are

rapidly changing. Standardization provides a mechanism for the

stabilization of technology and the subsequent introduction of

international technology into the marketplace without forfeiting

innovation. ASTM is in the business of standardization and my remarks

today will be limited to that subject and not the issues outside of that

scope.

During this decade, many forces are at work to influence our need to

focus on the ’’real world" of standards used internationally. Expanded

public recognition of the significance of these standards, more efficient

international communication, the effects of international economics, and

the fact that governments can use standards as instruments of economic and

commercial policy, requires a new sophistication in developing our

international policy structure for the next decade. It is clear from our

experiences in ASTM that the products of the standards arena are related

to the stimulus of the marketplace. Users of standards throughout the

world place a greater importance on the quality and usefulness of those

standards rather than on their source. Therefore, national/domestic

standards that are truly "de facto" international standards, have gained

wide acceptance in international standardization circles.

The United States is the only country in the world where the

standardization process is, for the most part, the function of the private

sector. Participation of federal agency personnel in the development of

U.S. positions on standards wherever such activities are of interest to

the agencies, would strengthen the U.S. position as it is perceived by

foreign interests. This would make a statement on the importance the

United States as a whole attaches to international standards activities.

The reality is that standards are an increasingly important influence in

the international marketplace.

63
The importance of ASTM’s international involvement was recently

reemphasized by its Board of Directors. We continue to stimulate and

encourage participantion by nationals of other countries in the work of

our committees, we continue to be responsive to the needs of our

committees to insure proper representation in the participation of ASTM in

appropriate international standardization activities, and we have

increased communication with national, regional and international

standards bodies throughout the world.

ASTM does not limit access to its system to U.S. citizens, but

encourages participation by nationals of other countries. As a result of

this position, ASTM today has over 4000 international members,

representing 91 countries, who actively participant in the transfer of

international technology into standards used internationally.

Consider the term ”ASTM standards used internationally” as opposed

to the term "international standards”. In our discussions of

international standards, our thoughts are generally focused on such

outstanding organizations as ISO and lEC. In September, 1986, I had the

personal pleasure to visit these organizations to exchange views on

standardization issues, especially international issues, and to seek ways

to harmonize ASTM standards development with our international colleagues.

I believe that these types of exchanges provide an exciting opportunity

that can only lead to better understandings and improved cooperation

between our organizations. Exchainges of this type with international as

well as national standardization bodies, were initiated by ASTM in recent

years and will continue to play an important role in our international

involvement

Since ASTM*s international involvement is driven by the initative of

its individual committees, support of those committees plays an important

role. Working through ANSI, ASTM serves as the administrator of 63 U.S.

Technical Advisary Groups (TAGS) to ISO standards committees and 5 to lEC

committees. The degree of international involvement for any ASTM

Committee has depended on its ability to raise sufficient funds from

industry sources to cover travel and related expenses. For its part, ASTM

has committed substantial resources in terms of staff time and

administrative support to assist committees in reaching their particular

international standardization objectives. ASTM therefore plays a major

role in influencing the development of international standards.

ASTM will continue to stimulate the use of its standards throughout

the world by recognizing that it is the international marketplace which

decides which standards are used internationally. The goals for ASTM

standards can only be met by maintaining and upgrading their technical

quality, reliability, and responsiveness to the needs of new technology.

Standards developers will face these challenges through continued

modernization of its data generation, communication, and administrative

support procedures. Standards that meet the needs of the users from a content and availability standpoint will form the basis of international

trade.

64
One of my stated objectives as the 1987 Chairman of the Board of

ASTM is to promote the internationalization of ASTM. Our standards are,

by use in international trade, global, recognized, and accepted worldwide.

Our standards are also widely used as a starting point for international

standardization. To further enhance the international use of ASTM

standards, ASTM will continue to encourage the participation of foreign

nationals in the work of our committees and will continue to support our

committees in appropriate international standardization activities.

In summary, the United States is currently represented in many

international standards forums through the voluntary standards system.

The environment and complexity of international standards development

continues to change, and will require close coordination between

government and private sectors if the United States is to meet its

"industrial competitiveness" goals. ASTM through its voluntary consensus

system, will continue to support the international standards objectives of

its constituency, and will take appropriate steps to guarantee adequate

resources for data generation and administrative support. The ASTM system

will continue to be responsive to the stimulus received from the

marketplace. This will enhance the use of our standards, and the

technology they embody, in appropriate organizations worldwide. We recommend that this course of action be adopted by other organizations in the

United States involved in standardization.

Thank you for this opportunity to contribute to this conference on Standards and Trade.

65
Co-Chairman Ambler

INTRODUCTION OF DR. GEORGE $. WHAM

DR. GEORGE WHAM CHAIRS ANSI —THE AMERICAN NATIONAL STANDARDS INSTITUTE AND IS

ALSO VICE PRESIDENT OF GOOD HOUSEKEEPING MAGAZINE AND INSTITUTE.

HE RECEIVED A B.S. FROM CLEMSON UNIV., AN M.S. FROM THE UNIV. OF TENNESSEE,. AND

PH.D. FROM PENNSYLVANIA STATE UNIV. HE DIRECTED RESEARCH AND DEVELOPMENT AT

PHILIPS VAN HEUSEN PRIOR TO JOINING GOOD HOUSEKEEPING AFTER BEING A PROFESSOR

AT TEXAS WOMEN'S UNIVERSITY AND RESEARCH ASSOCIATE AT PENN STATE.

DR. WHAM CHAIRED THE ASTM COMMITTEE ON CONSUMER PRODUCT STANDARDS AND SERVES ON

ADVISORY COMMITTEES OF THE U.S. DEPT. OF AGRICULTURE AND NATIONAL ACADEMY OF

SCIENCES. HE'S BEEN A MEMBER OF ANSI FOR 30 YEARS AND ON ITS BOARD FOR TEN,

CHAIRING THE ANSI CONSUMER INTEREST COUNCIL AND A STANDARDS BOARD. HE WAS

PRESIDENT OF THE AMERICAN ASSOCIATION OF TEXTILE CHEMISTS AND COLORISTS AND IS

ACTIVE IN MANY ORGANIZATIONS AND SCIENTIFIC AND HONORARY SOCIETIES.

HE WILL DISCUSS TODAY THE IMPACT OF STANDARDIZATION PROGRAMS ON COMPETITIVENESS

IN WORLD TRADE, CARRIED OUT IN THE VOLUNTARY STANDARDS SYSTEM. ANSI MEMBERSHIP

IN THE MAJOR INTERNATIONAL, NON-GOVERNMENTAL STANDARDS GROUPS ISO AND lEC

PROVIDE ACCESS TO THE DEVELOPMENT OF INTERNATIONAL STANDARDS. TO MEET OUR

NEEDS, WE SHOULD BE ACTIVE IN ISO AND I EC AND URGE OUR TRADING PARTNERS TO DO

LIKEWISE.

66
PRESENTATION OF DR. GEORGE S. WHAM

CHAIRMAN, AMERICAN NATIONAL STANDARDS INSTITUTE

I WANT FIRST TO COMMEND THE U.S. DEPARTMENT OF COMMERCE FOR SPONSORING THIS

IMPORTANT AND TIMELY CONFERENCE ON STANDARDS AND TRADE. THE Ar^ERICAN NATIONAL

STANDARDS INSTITUTE, WHICH I SERVE AS CHAIRMAN OF THE BOARD OF DIRECTORS, WAS

ESTABLISHED BY THE U.S. DEPARTMENT OF COMMERCE, WAR AND NAVY, AND FIVE LEADING

PRIVATE SECTOR TECHNICAL ORGANIZATIONS IN 1918. WE HAVE ENJOYED EXCELLENT

RELATIONS WITH THE DEPARTMENT AND ITS NATIONAL BUREAU OF STANDARDS THROUGHOUT

OUR HISTORY. NBS INCIDENTALLY CONTRIBUTES EXTENSIVELY TO U.S. PARTICIPATION

IN INTERNATIONAL STANDARDS THROUGH TECHNICAL INPUT, COMMITTEE PARTICIPATION

AND IN FURNISHING DELEGATES TO BOTH TECHNICAL AND POLICY FORUMS OF

INTERNATIONAL ORGANIZATIONS WITH WHICH ANSI IS AFFILIATED.

THE INTRODUCTION TO THIS CONFERENCE CALLED ATTENTION TO THE IMPORTANCE OF

INTERNATIONAL TRADE AND TO THE NEGATIVE TRADE BALANCE WHICH THE U.S. HAS

SUFFERED. I AM PLEASED TO REPORT THAT IN THE STANDARDS FIELD THE OPPOSITE IS

TRUE. UNITED STATES' STANDARDS HAVE A STRONG, POSITIVE TRADE BALANCE IN THE

MARKETPLACE. WE KNOW THIS BECAUSE WE MARKET U.S. (AMERICAN NATIONAL)

STANDARDS THROUGHOUT THE WORLD AND AT THE SAME TIME WE MARKET THE NATIONAL

STANDARDS OF OUR TRADING PARTNERS (FOREIGN STANDARDS) IN THE UNITED STATES.

YOU MAY BE SURPRISED TO LEARN THAT FOR 1986 INTERNATIONAL SALE OF AMERICAN

NATIONAL STANDARDS TOTALED $1,450,000. FOREIGN STANDARDS SOLD IN THE UNITED

STATES CAME TO $116,000. THAT IS A 12.5:1 POSITIVE RATIO. STUDIES CONDUCTED

BY MAJOR U.S. STANDARDS DEVELOPERS SHOWED THAT THERE IS OVERWHELMING

ACCEPTANCE OF U.S. STANDARDS IN INTERNATIONAL USAGE, INCLUDING TRADE AND

COMMERCE.

67
BEFORE WE BREAK INTO WORKING GROUPS TO DISCUSS POSSIBLE ACTIONS TO IMPROVE

U.S. COMPETITIVENESS IN WORLD MARKETS AND THE ROLE OF STANDARDS IT WOULD BE

WELL TO TAKE A FEW MINUTES TO REVIEW:

0 WHO WE ARE — WHERE WE ARE

0 THE BASIS FOR PARTICIPATION IN INTERNATIONAL STANDARDS

0 POSITIVE ASPECTS OF INTERNATIONAL STANDARDS

0 WHAT CAN BE DONE TO IMPROVE INTERNATIONAL STANDARDS AND THEIR

USEFULNESS IN TRADE AND COMMERCE

IN THE TIME ALLOTTED WE MUST CONFINE OURSELVES TO AN OVERVIEW OF THE SUBJECT

BUT, PERHAPS BY DOING SO, WE CAN LAY THE GROUNDWORK FOR FURTHER DISCUSSION.

IN MY REMARKS I WILL TRY TO AVOID THE ALL BUT ESSENTIAL ACRONYMS. SINCE FOUR

ORGANIZATIONS WILL BE MENTIONED THROUGHOUT, IT WOULD BE WELL TO IDENTIFY THEM

AT THE START:

( ANSI ) AMERICAN NATIONAL STANDARDS INSTITUTE

( ISO ) INTERNATIONAL ORGANIZATION FOR STANDARDIZATION

( lEC ) INTERNATIONAL ELECTROTECHNICAL COMMISSION

(CCITT) INTERNATIONAL TELEGRAPH & TELEPHONE CONSULTATIVE COMMITTEE

68
THE AMERICAN NATIONAL STANDARDS INSTITUTE IS THE "UNITED STATES" MEMBER OF

THE Tl/^0 LEADING NONGOVERNMENTAL INTERNATIONAL STANDARDS ORGANIZATIONS —

ISO and lEC . ANSI ALSO TAKES AN ACTIVE ROLE IN CCITT THROUGH THE U.S.

GOVERNMENT'S ADVISORY GROUP AND BY VIRTUE OF THE INPUT FROM ISO AND lEC.

IT'S IMPORTANT TO REALIZE AND ACCEPT THE FACT THAT ANSI IS UNIQUE AMONG THE

NATIONAL STANDARDS GROUPS THAT MAKE UP ISO AND lEC. IT DOES NOT DEVELOP

STANDARDS. IT HAS NO PROPRIETARY POSITION ON STANDARDS. ITS REPRESENTATION

IS BY THOSE WHO ARE INTERESTED IN AND AFFECTED BY POTENTIAL INTERNATIONAL

STANDARDS. IT IS FREE FROM COERCION OR CONTROL BY ANY COMMERCIAL, POLITICAL

OR PAROCHIAL GROUP. ANSI OPERATES ON THE BASIC PRINCIPLE OF CONSENSUS WITH A

STRONG COMPETITIVE MARKET ORIENTATION.

ANSI IS THE VOLUNTARY NATIONAL STANDARDS COORDINATOR. IT IS A FEDERATION OF

STANDARDS COMPETENCE COMPOSED OF INDUSTRIAL AND COMMERCIAL COMPANIES, TRADE , SCIENTIFIC, TECHNICAL, PROFESSIONAL, LABOR, CONSUMER AND GOVERNMENTAL MEMBERS.

WE HAVE OVER 1000 COMPANY MEMBERS AND 250 ORGANIZATIONAL MEMBERS.

MORE THAN 200 ORGANIZATIONS—TECHNICAL AND PROFESSIONAL SOCIETIES,

TRADE ASSOCIATIONS, AND OTHER GROUPS SEND THEIR STANDARDS TO ANSI FOR

CONSENSUS VERIFICATION AND APPROVAL.

69
THE ROLE(S) OF ANSI ARE:

0 NEW PROGRAM DEVELOPMENT

0 COORDINATION OF NATIONAL STANDARDS SYSTEM

0 APPROVAL OF STANDARDS AS AMERICAN NATIONAL STANDARDS

0 INTERNATIONAL REPRESENTATION

0 GOVERNMENT INTERFACE

0 INFORMATION CLEARINGHOUSE

YOU MIGHT ASK WHY ANSI IS THE MEMBER OF ISO AND lEC. THIS DERIVES FIRST FROM

THE FACT THAT ANSI’S PREDECESSOR ORGANIZATIONS WERE AMONG THE FOUNDERS OF BOTH

ISO AND U.S. ELECTROTECHNICAL INTERESTS (BEFORE NATIONAL STANDARDIZATION)

AGREED TO DEVELOPMENT OF AN INTERNATIONAL ELECTROTECHNICAL COMMISSION IN

1906. TWENTY YEARS LATER (1926) THE AMERICAN STANDARDS ASSOCIATION (ASA)

JOINED WITH OTHER NATIONAL ORGANIZATIONS IN FORMING A FEDERATION OF NATIONAL

STANDARDS BODIES KNOWN AS THE INTERNATIONAL FEDERATION OF NATIONAL

STANDARDIZING ASSOCIATIONS OR ISA. ISA WENT OUT OF BUSINESS DURING WORLD WAR

II. IN 1946 ASA MET WITH THE NATIONAL STANDARDS ORGANIZATIONS OF ALLIED

NATIONS, AMONG THEM CHINA, UNITED KINGDOM, FRANCE AND RUSSIA, AND BEGAN A

SERIES OF MEETINGS WHICH RESULTED IN THE FORMATION OF ISO IN 1946.

70
AS A CHARTER MEMBER, ANSI IS THE ONLY U.S. MEMBER OF ISO. THROUGH ITS U.S.

NATIONAL COMMITTEE TO lEC, ANSI ENJOYS SIMILAR MEMBERSHIP RESPONSIBILITY IN

lEC. IN ADDITION TO ISO AND lEC, ANSI HOLDS MEMBERSHIP IN AN IMPORTANT FORUM

OF PACIFIC RIM COUNTRIES KNOWN AS THE PACIFIC AREA STANDARDS CONGRESS (PASO.

PASC DOES NOT DEVELOP STANDARDS BUT HAS PROVED USEFUL IN COORDINATING THE

VIEWS OF, FOR EXAMPLE, U.S., JAPAN, CANADA, CHINA AND OTHER PACIFIC COUNTRIES.

IN ISO, lEC AND PASC, ANSI DOES THE FOLLOWING:

0 COORDINATES U.S. VIEWPOINTS

0 PROVIDES MANAGEMENT LEADERSHIP AND TECHNICAL SUPPORT

0 PAYS TOTAL U.S. DUES (IN EXCESS OF $1 MILLION IN 1987)

o SERVES ON GOVERNING BODIES

THERE IS REMARKABLE SIMILARITY IN THE OPERATING MODES OF ANSI AND ISO. WHERE

IN THE UNITED STATES ANSI DEPENDS UPON THE STANDARDS DEVELOPING ORGANIZATIONS

SUCH AS SAE, CBEMA, ASME, ASTM, NEMA, NFPA, IEEE AND UL (TO NAME SOME OF THE

LARGER) TO COME UP WITH STANDARDS ISO IS DEPENDENT UPON NATIONAL STANDARDS

ORGANIZATIONS SUCH AS ANSI, 3SI, AFNOR, DIN, JISC AND GOST (RUSSIA) FOR

ADMINISTRATION OF TECHNICAL COMMITTEES WHICH SUBMIT DOCUMENTS FOR APPROVAL.

THE END RESULT OF ISO’S WORK IS INTERNATIONAL STANDARDS.

71
THERE IS AN INTERGOVERNMENTAL ORGANIZATION, THE INTERNATIONAL TELEGRAPH AND

TELEPHONE CONSULTATIVE COMMITTEE OR CCITT WHICH IS VITAL TO DEVELOPMENT AND

IMPL0CNTATION OF TELECOMMUNICATION STANDARDS. ANSI HAS ACCESS TO CCITT

THROUGH THE U.S. STATE DEPARTMENT'S ADVISORY GROUPS. HOWEVER, BOTH ISO AND

lEC ALSO FEED INTO CCITT. CONVERSELY MANY CCITT RECOMMENDATIONS BECOME THE

BASIS FOR ISO AND lEC INTERNATIONAL STANDARDS.

THE KEY QUESTION BEFORE US IS -

WHAT CAN INTERNATIONAL STANDARDS DO FOR COMPETITIVENESS? JOHN RANKINE, FORMER

ANSI CHAIRMAN OF THE BOARD, ANSWERED THIS QUESTION IN A RECENT SPEECH.

SIMPLY, THEY CAN UNIFY DEFINITIONS OF USER NEEDS FOR WHICH A WIDE SPECTRUM OF

MANUFACTURERS CAN COMPETE TO FULFILL. BUT, IN ORDER TO DO SO, THE

INTERNATIONAL STANDARDS MUST MEET THE FOLLOWING CRITERIA.

FIRST , THEY MUST BE TRULY CONSENSUS STANDARDS DEVELOPED ON A VOLUNTARY BASIS

BY ALL AFFECTED INTERESTS - GOVERNMENT, USERS, PRODUCERS AND OTHERS.

72
SECOND, THEY MUST BE RELEVANT AND MEET USER NEEDS

THIRD , THE INTERNATIONAL STANDARDS MUST BE TIMELY. THIS IS PARTICULARLY TRUE

IN THE AREA OF FAST MOVING TECHNOLOGY. IF THEY ARE NOT, THEY DO NOT MEET USER

NEEDS AND THEY DO NOTHING TO FOSTER COMPETITIVENESS. TO THE CONTRARY, THEY

BOG IT DOWN.

FOURTH , THE STANDARDS MUST BE NONDISCRIMINATORY. THEY SHOULD NOT PRECLUDE

ANYONE WHO HAS A VALID ANSWER TO A USER'S NEED FROM COMING FORWARD AND FILLING

THAT NEED.

FIFTH , THEY SHOULD PERMIT INNOVATION AND CREATIVITY BECAUSE IT IS IN THESE

QUALITIES - INNOVATION AND CREATIVITY - THAT TRUE COMPETITIVENESS AND THE

GREATEST SERVICE TO USERS LIE.

NOW WHAT IS THE BEST WAY TO PRODUCE SUCH STANDARDS?

73
THAT WAY HAS EXISTED FOR A LONG TIME, AND IT CONTINUES TO EXIST TODAY. IT IS

THE VOLUNTARY CONSENSUS STANDARDS SYSTEM AT THE NATIONAL AND INTERNATIONAL

LEVELS. AFNOR, ANSI, BSI, DIN, ETC - THE NATIONAL BODIES ENSURING CONSENSUS

AT THEIR NATIONAL LEVELS AND INTERACTING WITH ISO AND lEC TO PRODUCE THE

NEEDED INTERNATIONAL STANDARDS. IT HAS WORKED WELL IN THE PAST. IT MUST NOT

ONLY WORK WELL IN THE FUTURE BUT EVEN BETTER THAN IT EVER HAS IN THE PAST.

‘

AND LET ME EMPHASIZE HERE THAT WE HAVE THE MOST PRODUCTIVE VOLUNTARY STANDARDS

SYSTEM IN THE WORLD AND IT PROVIDES THE UNITED STATES WITH OUTSTANDING

OPPORTUNITIES FOR EFFECTIVE LEADERSHIP IN INTERNATIONAL STANDARDIZATION.

THIS TRIED AND PROVEN SYSTEM OF BRINGING TOGETHER ALL INTERESTS - GOVERNMENTS,

USERS, PRODUCERS AND OTHERS - SO ALL CAN PARTICIPATE BUT NONE CAN DOMINATE IS

STILL THE BEST WAY, WHEN IT IS DEVOID OF POLITICS IN DEVELOPING, ADOPTING AND

IMPLEMENTING WORLD STANDARDS THAT SET THE STAGE FOR COMPETITIVENESS.

SOME CONTEND THAT THE SYSTEM IS NOT WORKING SO WELL. LET ME MENTION SOME OF

THE REASONS. FIRST, THOSE THAT ARISE WITHIN THE SYSTEM. FUNDING IS A KEY

PROBLEM ON SEVERAL COUNTS. MANY INDUSTRIAL SUPPORTERS OF THE VOLUNTARY

STANDARDS SYSTEM ARE CURRENTLY CUTTING EXPENSES TO STAY COMPETITIVE. ALSO,

FROM A U.S. POINT OF VIEW, IS THE DEVALUATION OF THE U.S. DOLLAR VERSUS THE

SWISS FRANC, FOR IT IS IN SWISS FRANCS THAT WE, ANSI, MUST PAY OUR DUES TO ISO

AND lEC. THE ANSI 1987 BUDGET FOR ISO/IEC DUES AND ADMINISTRATION IS

$2,108,000.

74
SLOWNESS OF THE SYSTEM IS A FREQUENT CRITICISM EASILY MADE. A CONSENSUS

SYSTEM, WHERE EVERYONE HAS TO BE HEARD, BY ITS NATURE CANNOT PRODUCE

INSTANTANEOUS RESULTS. SO MUCH OF THAT CRITICISM MAY BE UNFAIR, BUT NOT ALL

OF IT. FOR EXAMPLE, CAN ANYONE AFFORD TO WAIT AN AVERAGE OF 3 YEARS TO REACH

TECHNICAL AGREBCNT ON A STANDARD? OR 4 TO 5 YEARS TO SEE IT PUBLISHED AND

AVAILABLE FOR USE?

NOW LET ME TURN TO THE EXTERNAL INFLUENCES AFFECTING ISO AND lEC. PROBABLY

THE MOST SIGNIFICANT ONE IS THE INCREASE IN POLITICAL PRESSURES THAT ARE BEING

BROUGHT TO BEAR ON THESE TRADITIONALLY NONGOVERNMENTAL AND APOLITICAL

INTERNATIONAL BODIES.

FOR EXAMPLE, THE PROGRAM OF THE EUROPEAN ECONOMIC COMMUNITY WILL STRENGTHEN

THE INFLUENCE OF THE EEC IN THE FINAL STANDARDS ADOPTED BY ISO AND lEC. THIS

WILL RESULT FROM THE ACTIVITIES OF EUROPEAN REGIONAL STANDARDS BODIES IN

RESPONSE TO EEC REQUIREMENTS AND DEADLINES. WE SEE THE EMERGENCE OF STRONG

REGIONAL INFLUENCES IN WHAT HAS BEEN AN ARENA OF NATIONAL STANDARDS BODIES

INTERACTING WITH THEIR INTERNATIONAL ORGANIZATIONS. IF THESE REGIONAL INPUTS

ARE ARRIVED AT ON A TRULY CONSENSUS BASIS FOR ADVANCING INTERNATIONAL

75
STANDARDS, THEY CAN BE USEFUL. HOWEVER, IF THEY ARE DISCRIMINATORY OR EXCLUDE

OUTSIDE INTERESTS FROM BEING HEARD, THEN THEY WILL UNDERMINE THE INTEGRITY AND

UTILITY OF BOTH ISO AND lEC. BOTH ORGANIZATIONS AND THEIR MEMBER BODIES MUST

RESIST SUCH INFLUENCES AND SCRUPULOUSLY ADHERE TO THEIR PROCEDURES FOR

OPENNESS AND DUE PROCESS IN THE DEVELOPMENT OF STANDARDS NATIONALLY,

REGIONALLY AND INTERNATIONALLY.

ANOTHER RELATIVELY NEW FACTOR ON THE SCENE IS THAT CERTAIN LARGE STANDARDS

USER AND IMPLEMENTER GROUPS ARE STARTING COLLECTIVELY TO DEVELOP LIMITED

SELECTIONS OF OPTIONS FROM lEC AND ISO STANDARDS THAT WILL THEMSELVES PROBABLY

BECOME INTERNATIONAL STANDARDS. THESE ACTIVITIES ARE ALSO COMPETING FOR

RESOURCES AND TO A CERTAIN DEGREE CHALLENGING THE POSITION OF ISO AND lEC.

THIS IS NOT TO ARGUE AGAINST THE NEED FOR SUCH ACTIVITIES BUT TO RECOGNIZE

THAT THEY DO SPREAD AVAILABLE AND OFTEN SCARCE RESOURCES EVER MORE THINLY. IT

WOULD BE PREFERABLE TO HAVE THESE GROUPS WORKING IN THE JOINT ISO-IEC SYSTEM

TO ACHIEVE OPTIMUM COORDINATION AND AVOID WASTE AND DUPLICATION.

76
IN SUMMARY, IF THE INTERNATIONAL STANDARDS BODIES ARE GOING TO CONTINUE TO BE

THE SOURCE OF INTERNATIONAL STANDARDS THAT WILL DEFINE TRUE USER NEEDS AND

PROMOTE COMPETITIVENESS, THEY ARE GOING TO HAVE TO DO IT IN AN ENVIRONMENT OF

GREATER COMPETITION FOR RESOURCES AND INCREASING POLITICAL PRESSURES. THIS

MEANS THAT ISO AND lEC HAVE TO WORK EFFICIENTLY BETWEEN THEMSELVES AND WITH

OTHERS SUCH AS THE CCITT. THEY HAVE TO FOCUS THEIR RESOURCES ON THE EFFICIENT

AND TIMELY PRODUCTION OF NEEDED STANDARDS, AND THEY HAVE TO RESIST THE

POLITICAL AND PROTECTIONIST PRESSURES THAT THREATEN THEIR RAISON D'ETRE.

THE FUTURE

WHAT IS THE OUTLOOK FOR INTERNATIONAL STANDARDS DEVELOPMENT BY ISO-IEC? WILL

THEY MEET FUTURE NEEDS? IN THE TIME THAT I HAVE BEEN ASSOCIATED WITH IT I

HAVE SEEN SOME REMARKABLE PROGRESS.

TWO YEARS AGO FEW THOUGHT THERE WAS ANY REAL HOPE OF MERGING ISO/IEC

ACTIVITY. WE NOW HAVE IN PLACE A JOINT ISO/IEC TECHNICAL COMMITTEE ON

INFORMATION TECHNOLOGY (JTC 1). EVERYONE CONCERNED IS WORKING OVERTIME TO

BRING ABOUT AN ORDERLY MIGRATION FROH TECHNICAL COMMITTEES OF TWO

ORGANIZATIONS TO A JOINT EFFORT OPERATING UNDER HARMONIZED PROCEDURES AND

HOPEFULLY CAPABLE OF BRINGING INTO THE FOLD LIAISON ORGANIZATIONS OUTSIDE

ISO/IEC TO PRODUCE NEEDED STANDARDS ON A TIMELY BASIS.

77
WE HAVE AN IMPROVED MANAGEMENT TEAM IN THE ISO AND I UNDERSTAND CHANGES ARE IN

THE OFFING IN lEC. THE PRESIDENTS OF ISO AND lEC ARE COMMITTED TO

STRENGTHENING THE ABILITY OF THE JOINT VENTURE TO MEET INTERNATIONAL DEMANDS

AND EXPECTATIONS.

AT THE MOMENT THERE IS STILL REGIONALIZATION OF STANDARDS AND CERTIFICATION

REQUIREMENTS. THESE APPEAR TO BE UNDER CONSIDERATION BY THREE SEPARATE,

UNCOORDINATED GROUPS, EACH WITH A FEELING THAT SOMEHOW THEY CAN GAIN A

COMPETITIVE EDGE. THIS IS FOOLHARDY IN INFORMATION TECHNOLOGY AND

TELECOMMUNICATIONS. THESE ARE MULTINATIONAL INDUSTRIES. THEIR SERVICES KNOW

FEW NATIONAL BOUNDARIES. THE NEED FOR THEIR SERVICES IS UNIVERSAL, NOT

REGIONAL. IT IS DIFFICULT IF NOT IMPOSSIBLE TO PUT BARRIERS AROUND

KNOWLEDGE. IN TIME ALL WILL KNOW — AND ALL COULD BENEFIT FROM COORDINATED

INTERNATIONAL DEVELOPMENT OF STANDARDS, TESTING PROTOCOLS, AND, WHERE

NECESSARY, REGULATIONS.

AS HAS BEEN STATED EARLIER, THE BEST FORUM FOR INTERNATIONAL STANDARDS IS

ISO/IEC/CCITT. THE WAY TO SEE THAT THE SYSTEM DOES PRODUCE IS FOR ALL OF US,

ESPECIALLY IN THE UNITED STATES, TO PARTICIPATE IN AND SUPPORT ISO/IEC. THIS

WILL MOTIVATE OUR TRADING PARTNERS TO DO LIKEWISE. WE CAN SUCCEED, PROVIDED

WE ALL USE THE SYSTEM PROPERLY AND DO NOT ABUSE IT.

78
IN THE UNITED STATES, INDUSTRY, BUSINESS, GOVERNMENT, AND OTHER INTERESTS HAVE

INCREASED THEIR INVOLVEMENT IN INTERNATIONAL STANDARDIZATION IN RECENT YEARS.

ONE MOTIVE HAS BEEN ECONOMIC--A RESPONSE TO CHANGING WORLD CONDITIONS. THE

PRESSING NEED TO FIND INTERNATIONALLY ACCEPTABLE SOLUTIONS TO STANDARDS

PROBLEMS INVOLVED IN THE WORLDWIDE APPLICATION OF ADVANCED SCIENCE AND

TECHNOLOGY IS ANOTHER REASON FOR THE INCREASE.

THE MESSAGE IS CLEAR. U.S. INDUSTRY, BUSINESS, AND GOVERNMENT ARE AS

PRAGMATIC AS ANY IN THE WORLD. WITH ANSI LEADERSHIP AND COORDINATION THEY

HAVE INCREASED PARTICIPATION IN INTERNATIONAL STANDARDS ACTIVITIES TO

INFLUENCE THE CONTENT OF STANDARDS THAT AFFECT TRADE; AND ALSO TO CONTRIBUTE

TO SOLUTION OF PROBLEMS THAT CANNOT BE SOLVED AT THE NATIONAL LEVEL.

EFFECTIVE U.S INVOLVEMENT IN INTERNATIONAL STANDARDIZATION MUST BE MAINTAINED

AND EXPANDED. THE LEADERSHIP AND RESPONSIBILITY THAT ARE THE BASIS OF U.S.

CONTRIBUTIONS TO GLOBAL STANDARDIZATION MUST BE SUSTAINED. THE U.S. MUST

CONTINUE TO SELECT THE BEST TECHNICAL TALENT TO INTERFACE WITH INTERNATIONAL

STANDARDS ORGANIZATIONS. CONTINUITY, RESPONSIBILITY, AND LEADERSHIP ARE

79
ESSENTIAL TO THE CREDIBILITY THAT MAKES IT POSSIBLE FOR U.S. INTERESTS TO

ACHIEVE ACCEPTANCE OF THEIR VIEWS IN THE TECHNICAL WORK OF THE INTERNATIONAL

ORGANIZATION FOR STANDARDIZATION (ISO), THE INTERNATIONAL ELECTROTECHNICAL

COMMISSION (lEC), AND OTHER INTERNATIONAL GROUPS. THESE QUALITIES ARE ALSO

ESSENTIAL TO ENABLE ANSI, THE U.S. MEMBER OF ISO AND lEC, TO COORDINATE AND

MANAGE U.S. PARTICIPATION AND INFLUENCE THE POLICIES, PROGRAMS, FINANCING, 'AND

FUTURE PLANNING OF THESE ORGANIZATIONS.

THE OFFICERS AND DIRECTORS

SUBSTANTIAL PORTION OF THE

YOUR INTEREST. WE WELCOME

OF ANSI SUPPORT INTERNATIONAL PARTICIPATION. A

INSTITUTE’S RESOURCES ARE COMMITTED. WE WELCOME

YOUR INVOLVEMENT.

80
BIBLIOGRAPHY

Peyton, Donald L. Meeting user demands for high technology standards.

Presented at 1986 General Assembly of Association Francaise de Normalisation

(AFNOR); 1986, April 24; Paris, France. ANSI Reporter. 20(11): 1986 May.

Peyton, Donald L. X3 and ANSI—Partners in progress. Presented at 25th

Anniversary Celebration of Accredited Standards Committee X3; 1986,

February 12; Dallas, TX.

Rankine, L. John. International standards and competitiveness. Presented at

Public Conference of the American National Standards Institute; 1986, March

18; Alexandria, VA.

Rankine, L. John. Leadership and responsibility in international

standardization. ASTM Standardization News. 12(12): 21-24; 1984 December.

Travaglini, Vincent D. ANSI’s role in international standardization.

Proceedings of Conference on International Standards; 1985, April 2;

Gaithersburg, MD. Gaithersburg: U.S. Department of Commerce, National Bureau

of Standards; 1985, 41-47.

81
Questions and Answers

With foreign nationals on your U.S. comnittees, how do you develop

U.S. positions on draft international standards?

Robert Baboian:

The participation of foreign nationals injects international technology into

ASTM standards. These standards become more attractive in the international

marketplace, and are more likely be used as the basis for international

standards, such as ISO or I EC standards, or as ^ facto standards.

It seems that the ANSI system, more or less, acts as a barrier to the

United States adopting I EC or ISO standards. Is the international standards

effort a one-way street?

George Wham:

I don't believe so. I have participated in TAG groups and have found that many

European nations can't make a decision on the spot, but go back to their

governments to get a position because they are quasi -governmental bodies.

Americans can often make decisions on the spot. I don't believe that the ISO

system or the ANSI system is a deterrent to promoting and promulgating

international standards. On the contrary, since we operate on the democratic

principle of consensus, we can rarely avoid this perhaps long route in order to

achieve standards universally acceptable to all parties in this country.

A criticism often raised internationally is the inability of ASTM to police

manufacturers for compliance to ASTM standards. Are there any plans to take a more active policing role to strengthen your international position?

Robert Baboian:

Our international position is strengthened by the fact that industry, academia,

and government work together in our standardization process. The resulting

product is a mix of the best technology, and this is injected into the

international marketplace.

Don't foreign sales of U.S. standards precede U.S. imports of foreign goods?

Doesn't a positive trade balance in standards mean a negative trade balance in

goods? (D. Hack)

George Wham:

The answer is no. It is very difficult for us to hide our lights, our standards, under the bushel and not trade information with our trading

partners. Information is very difficult to conceal, I can't see any way to

prevent the sale of U.S. standards abroad. The point is well taken, but I

82
don't believe that selling our standards necessarily influences in any

overwhelming sense the trade balance in this country.

Please comnent on the role of academia in the ASTT1 process.

Robert Baboian:

The participation of academia in the ASTM standardization process is very

important because they bring in the latest technology. We encourage that and

have an academic affairs subcommittee, a successful Board committee, that has

to maximize increased participation by academia in our standardization process.

The European Economic Community will adopt voluntary ISO standards as

regulatory, while they (the standards) remain voluntary to the United States.

They have several votes vs. the one for the United States (one vote per

country). Hence, there is a one-way level of control regarding trade. What

should or can we do about this? What is the answer? (J. Tesk)

George Wham:

We've always had the problem of standards being adopted as regulations in

foreign countries, whereas in this country the voluntary standards system has

been predominant. I hope we continue to maintain that position. I don't know

the answer to that question beyond that. Dr. Ambler.

83
Stanley I. Warshaw

Director, Office of Product Standards Policy

National Bureau of Standards

Working Group Announcements

We are distributing an announcement sheet for three Working Groups which will

deal with major issues raised by today's presentations, namely, participation

in international standardization activities, acceptance of test and

certification data, and adoption of U.S. standards. Room locations are shown

on the back of this sheet. The Working Groups will convene promptly at

2:00 o'clock, so I suggest that you peruse this during the lunch hour, select

the topic that most appeals to you, then go to the appropriate room. We will

reconvene at 3:30 this afternoon and the Working Group Chairpersons will

summarize the findings of their Working Groups. These reports will be

incorporated in the proceedings, along with the presentations that you heard

this morning. They are indeed important since these deliberations will help

set the agenda for the future both within the Department of Commerce and in

some private sector organizations. I urge you to voice your thoughts in the

working group sessions and have them reported.

We will now adjourn for lunch. Let me again thank all those who participated

this morning, as well as our co-chairman. Dr. Ambler, who happens to be my

boss, too.

84
Dr. Warshaw

Introduction of Work Group 1 Chair

The first Working Group, on participation in international standardization

activities, was chaired by Cathy Kachurik. Cathy is on the staff of the

Computer and Business Equipment Manufacturers Association (C.B.E.M.A.) and has

had considerable international standards experience as director of the X-3

Secretariat.

05
CONFERENCE ON STANDARDS AND TRADE

Minutes of Working Group 1 Participation in International Standardization

Chairperson: Catherine Kachurik

C.B.E.M.A.

Twenty-two individuals from industry, Government, and standards developing

organizations participated in Working Group 1 . The experience levels of the

participants covered a wide range, most having been in the standards community

for several years or more.

After introductions and general comments, issues were selected for furtherdiscussion:

Dollar factors

Manpower issues

Changing of the guard

Education of the U.S. participants and preparation of delegations

Reduction in industry participation

The discussions resulted in the following brief definitions of problem areas

and possible solutions:

DOLLAR FACTORS

The dollar factors included the funding necessary to support capable delegates

and establish continuity, whether those dollars were contributed by the

standards developing organization or the volunteer delegates themselves. Most

participants felt that serious problems with exchange rates are creating an ongoing impact greatly affecting U.S. representation.

Possible solutions are:

0 Funds could be collected to support delegates, although most

participants stated that few delegates are currently supported by the

parent body. Some do, however, support officer-level volunteers.

0 Other felt that, unless funding for international standards activities

were built into an equitable system and budgeted on an annual basis,

the only other way to provide such funding would be by special

assessment.

0 In addressing the problems related to exchange rates, it was proposed

that U.S. participants host more meetings, creating savings for their

sponsoring organizations and offering their international counterparts

the "bargain" of coming to the United States.

86
CHANGING OF THE GUARD

Most participants felt that the days of individuals devoted solely to standards

activities and allowed the "luxury" of becoming well-versed generalists had

long passed. Most participants face the turn-over of their "elder statesmen,"

with little hope to replacing these people, or of bringing others up to speed

to replace the losses with wide experience.

Possible solutions are:

0 As a short-term fix, hire consultants. However, many participants

pointed out that, in most technologies, the participants' ability to

keep up with the dynamics of their particular industry would soon

diminish, and that consultants could not solve the long-term problem.

0 Others suggested the need for a media program to influence Chief

Executive Officers and ensure that the United States does not lose its

leadership capabilities. Perhaps a coherent package on the impact of

the current trend should be placed in leading trade magazines.

0 Mr. William Rockwell, ANSI Vice President, reported that ANSI has hired

a media consultant to develop projects such as these. ANSI will

support such efforts and is forming a communications council so that

members may assist with the particular expertise necessary.

EDUCATION OF U.S. PARTICIPANTS AND PREPARATION OF DELEGATIONS

REDUCTION IN INDUSTRY PARTICIPATION

The basic problem is that CEOs do not recognize the importance of standards

efforts; management must be taught on a case-by-case basis. As a result, when

organizations start running "lean and mean," the most likely impacts come in

the standards arena first.

Possible solutions are:

0 Some members felt that the education problem can best be handled on a fundamental basis, i.e., development of standards awareness levels of

CEOs and marketing personnel during their college level education.

0 As part of their basic business management curriculum, both groups

should be taught the importance of standards and the business impacts

which standards create. Several participants indicated that they sit

on academic advisory boards and assist in the creation of course

material dealing with standards at the college level.

0 Other members suggested that the standards community use the

advertising media to the fullest to create those messages and better

articulate the value of standards in order to convince corporate

America. Others felt that the onus is on the standards developing

bodies to better identify the bottom line impacts that standards can make.

87
The participants were unable, in the short time available, to further explore

solutions. However, the group's consensus was that the role for Government

should be to:

seek the opinion of industry;

remain responsive and reactive to standards needs; and

support such positions during the GATT talks.

88
Dr. Warshaw

Introduction of WG 2 Chair

I now call upon Gerry Ritterbusch of Caterpillar, Inc. Gerry is Caterpillar's

manager of product safety and environmental testing. More important is the

fact that he is responsible for all of Caterpillar's standards activities, both

domestically and internationally, and all product-related litigation in that

regard. Gerry will report on Working Group 2, dealing with test data

acceptance.

89
CONFERENCE ON STANDARDS AND TRADE

Minutes of Working Group 2

Test Data Acceptance

Chairperson: Gerald Ritterbusch

Caterpillar, Inc.

U.S. industry often faces the problem of making a product for export to a foreign country available for test and evaluation by the approved authority in

that country to obtain certification under their rules and regulations. Some

foreign countries allow their personnel to make such inspections or evaluations

in the United States but considerable scheduling and travel costs are entailed

(and assessed to U.S. industry). When the tests must be conducted within the

foreign country, the costs are considerably higher than testing in the

United States due to the shipping cost of the test product. When the tests are

destructive, the costs end up being quite significant. In the event of initial

failure to meet the requirements, retests must be scheduled and much time is

lost.

To enhance the ability to export products, industry needs a less burdensome

method at low cost to obtain certification to the importing country's

requirements. Testing in the United States could result in certification with

the least disruption to the manufacturer's operation under a system that

assures the importing country that the product meets its requirements. Various

means can be used to assure that test data is properly obtained and is valid.

U.S. manufacturers prefer self-certification as the least burdensome method.

Product liability consequences provide adequate incentive for selfcertification even if customer acceptance isn't the determining factor for the

manufacturer.

The next most appropriate approach to certification is based on the witnessed

test, where an impartial observer reviews the test, the measurement method and

instrumentation and audits the recorded information. A third approach but more

costly is the method where the product is removed to a specific third party

laboratory where the staff conducts and reports on the test. If this latter

method is used in the United States, it is still less costly than if such

testing is required in the foreign country.

The choice between the witnessed test and test in a specific third party

laboratory is really a question of cost. With some types of machinery, it is

much more practical to test at the manufacturer's laboratory or development

facility than to relocate the product to an independent laboratory for the

test. Some specialized products require test setups which have to be built

only for the certification test instead of using existing setups at the

manufacturer's site. Also, disposal of spent test components is much better

handled at the manufacturer's site.

By agreeing to a consensus test procedure which includes adequate allowance for

test variability, a witnessed test should be acceptable in terms of producing

valid and accurate data. A key aspect is that the requirement utilize a consensus standard, such as an ISO standard. ISO also has procedures which

90
cover the aspects of certification to be followed to provide adequate assurance

that the test method meets acceptable engineering standards of performance.

The working group came to the following conclusions:

0 Initiatives to further adoption of measures that provide for acceptance

of valid test data by importing countries should be initiated or continued at all levels including:

- GATT Multilateral Trade Negotiations (The Uruguay Round)

- Bilateral negotiations

- Standards Code Committee deliberations

0 Testing in the United States is significantly more advantageous to

U.S. producers than shipping products overseas for certification

testing. Self-certification, witnessed tests and utilizing third-party

test agencies are reasonable methods to accomplish certification in the

United States. All three approaches have merit depending on the

specific industry and customer base. As a general rule, costs and

complexity increase as the method of certification moves from selfcertification to witnessed tests to third-party testing and

certification.

0 A recognized and competent laboratory accreditation program should be

considered as a component of the three methods recommended for

attaining certification. A voluntary approach to laboratory

accreditation was favored over any mandatory program.

0 Certain manufacturers perceive certification as an additional cost item

with no added value to the product.

0 An agreement that facilitates acceptance of U.S. generated test data

may further facilitate access by foreign producers to U.S. markets.

Some current U.S. regulations on acceptance of foreign test data may

require modification.

0 Industry should undertake a program to better inform the general public

about certification programs on a broad basis so the consumer has a better understanding about them, what they mean, and what they may

cost.

0 Different types of products and their markets should be treated

differently (e.g., the inherent differences ascribed to "capital goods"

as contrasted to "consumer goods").

91
Dr. Warshaw

Introduction of WG 3 Chair

Next we'll hear from Barbara Boykin, manager of the standards of the Aerospace

Industries Association, one of the larger standards-devel oping bodies in the

United States. Their standards are appreciated and used in many nations and,

in fact, are

^ facto international standards. Barbara, who is also Vice Chair

of the Industry Functional Advisory Committee on Standards, will report on Working Group 3 on adoption of U.S. standards.

92
CONFERENCE ON STANDARDS AND TRADE

Minutes of Working Group 3

Adoption of U.S. Standards

Chairperson: Barbara Boykin

Aerospace Industries Association

The working group's objective was to explore how the United States can better

promote international acceptance of U.S. standards as a means to improved

trade performance.

The chairperson opened the meeting with a statement that many of our key

trading partners, particularly the European nations, seem to do a better job

of promoting international acceptance of standards developed by their domestic

industries as a tool for trade promotion. She highlighted the many

standards-related programs which national standards organizations in France,

Germany, and the United Kingdom operate — such as centralized databases,

translation of standards, training programs and technical exchanges, technical

help for exporters, certification programs, etc. — and their active

involvement in international standards activities. In these and most other

industrialized countries, government plays a strong role in national and

international standardization through participation and funding. This

contrasts with the U.S. approach, which depends on private sector

participation, funding, and leadership.

Members of the working group emphasized the importance of strong U.S.

participation in international standardization efforts and in negotiations to

harmonize testing and certification requirements and procedures. As U.S.

industry seeks to serve a growing number of markets internationally, progress

in these areas becomes essential.

93
Working group members discussed their companies' experience in international

standardization activities. Several participants noted that U.S. success in

the International Organization for Standardization (ISO), International

Electrotechnical Commission (lEC), and other international standards fora

depends on the active participation of a relatively small number of

multinational companies. Such firms are most able to commit the necessary

resources and to make use of international industry contacts. Broader

participation, however, would be beneficial.

The work group discussed the reasons for past successes in ISO/IEC and agreed

that results achieved generally were proportional to the quality of U.S.

input. In cases where U.S. industry fielded a knowledgeable team and could

draw upon a strong U.S. standard, ISO/IEC frequently accepted this standard as

the basis for its own. The group concluded that the United States could

improve its performance in international standards fora by preparing more

effectively for meetings and maintaining the quality of U.S. standards.

The chairperson raised the issue of whether ISO recognition was necessary to

promote international adoption of U.S. standards. Some industries — such as aerospace and construction equipment — work directly with their European

counterparts to achieve standards harmonization. Working group participants

held differing opinions on this subject, but most agreed that a harmonized ISO

standard often provided the best long-term response. Several stressed the

importance of allowing the market to determine which, if any, standards should

be adopted internationally in a given case. The best available standard -

whatever its origin - will receive marketplace recognition. Many U.S.

national standards fall into this category. To be successful in international

standardization activities, the United States must be prepared to support the

"best" standard available, whether of U.S. origin or not.

94
The working group also considered the question of how widely ISO/IEC standards

are used. Governments may draw upon ISO/IEC standards as a basis for

mandatory regulations. The U.S. needs to do more to implement international

standards, and to encourage its trading partners to do so as well, to promote

harmonization. Harmonization of testing, certification and laboratory

accreditation is even more essential.

There was a consensus that more could be done to promote better awareness of

U.S. standards internationally. Although some leading standards developers

are addressing this matter through various channels, such as providing

standards to U.S. embassies, greater sustained effort and follow up are necessary to achieve desire results. Efforts to provide information and

education to potential users of U.S. standards are complicated by the large

number of U.S. standards and the decentralized U.S. system. NBS, which has a computerized data base of over 28,000 U.S. standards, is in a good position to

help expand recognition and use of these standards at home and abroad. The

greatest opportunities for promoting U.S. standards appear to be in developing

countries, where information on foreign standards frequently is inadequate.

The U.S. Government may be able to play an increasing role in assisting U.S.

industry achieve these goals. NBS representatives outlined several standards

outreach programs in which they are now involved, including an effort to help

Saudi Arabia and other developing countries establish or modernize their

national standards programs. The U.S. Agency for International Development

has provided (and may still provide) funding for similar purposes. A few

years ago, NBS established a training program on standards for U.S. State

Department, Foreign Commercial Service, and U.S. AID officials assigned to

overseas duty stations. Such efforts contribute to long-term recognition and

acceptance of U.S. standards.

95
Members of the working group noted that governments in other industrialized

nations work more closely with private industry in the standards area. In

contrast to the U.S. Government, which often imposes regulatory roadblocks,

these governments have one primary mission: to help their industry compete

internationally. Standards are recognized and utilized as a tool to promote

exports

Nevertheless, there was consensus in the working group that the U.S. voluntary

system should be retained, because it produces the best quality standards. It

was recognized that such activities as funding, promotion and education are

the joint responsibilities of private sector and government. The issue of

standardization needs to gain greater visibility and momentum in the United

States through linkage with the trade and competitiveness debate. The private

sector must raise the issue of standardization to get it onto government's

agenda.

In conclusion, the group agreed that U.S. industry needs to "think

internationally" in both the standards and trade arenas, abandoning

nationalistic approaches and adapting to international market needs. Based on

its discussion, the working group developed the following recommendations,

which were reported to the full conference:

® Strengthen U.S. representation in ISO and lEC to increase recognition

and adoption of U.S. standards;

° Foster international adoption of "best" standards available, based on

test of market competition;

96
® Pursue harmonization efforts with the European Community, and encourage

implementation of with international standards by U.S. and its trading

partners

® Increase awareness and availability of U.S. standards to potential

users abroad through outreach programs;

® Expand efforts to educate U.S. Government officials assigned overseas

on standards-related issues and their effect on trade; provide

information and copies of standards to embassies;

® Target developing countries as potential new markets for U.S. standards

and develop appropriate government and private sector outreach

approaches

® Increase awareness and access of U.S. and foreign firms to centralized

sources of information on U.S. standards, such as NBS;

° Continue to negotiate with other governments regarding acceptance of

foreign-generated test data and simplification of certification

requirements, encouraging movement toward third-party and reciprocal

acceptance arrangements;

® Expand current U.S. laboratory accreditation programs;

® Preserve U.S. voluntary standards system under private sector

leadership;

97
® Enhance U.S. industry-government cooperation on standards issues;

° Increase private and/or government funding of programs to expand

international awareness and adoption of U.S. standards;

° Encourage private sector to take greater initiative in raising the

visibility of standards issues with U.S. Government officials; and

° Encourage U.S. business community to adapt to changing world rather,

than just domestic market needs, using appropriate international

standards

98
Dr. Warshaw

Closing Remarks

In my opinion, our Working Group Chairpersons and everybody who participated in

the sessions they summarized deserve a round of applause for their excellent

contributions.

I hope that today's conference will have proved to be useful to you.

It would be remiss of me to neglect to mention those who contributed to putting

this conference together, especially Walter Leight of the National Bureau of

Standards and Chris Bates of the International Trade Administration. They

worked diligently with the speakers, and will continue those efforts to publish

proceedings within the next two months. I want to thank a number of Bureau

staff, in particular, Sara Torrence, Judy Baker, Wanda Capino. There were

others who helped, and we are very much appreciative.

It's our hope, at least in the Department of Commerce, that this day's

conference and the subsequent proceedings will provoke further thought amongst

us all, both in the Government and in the private sector, as to what we can do

to improve the trade situation for the United States through standards and

standards-related activities, such as certification and testing. We hope that

some of the seeds sown at this conference will mature into something

productive. I assure you that the Department, including the Bureau of

Standards and the International Trade Administration, will work with the

private sector to achieve the needed results.

I thank you for being here. We look forward to sending you a copy of the

proceedings in the next two months and to your further comments and

suggestions. We stand adjourned. Thank you.

99
List of Registrants and Participants

Conference on Standards and Trade

May 5, 1987

Donald Ableson

Office of the U.S. Trade

Representative

Wendy Allen

American Gear Manufacturing

Association

Rita Allen

National Bureau of Standards

Ernest Ambler

Director

National Bureau of Standards

Kenneth C. Appel 1 Colgate-Palmolive Company

William Atkinson, Jr.

National Machine Tool Builders'

Association

Robert Baboian

Chairman, ASTM

Judith Baker

National Bureau of Standards

Karen Barkley

National Bureau of Standards

Christopher M. Bates

International Trade Administration

Peter Bell

Vice President

Norton Company

Harvey Berger

National Bureau of Standards

Robert Bowles

PPG Industries

Barbara Boykin

Aerospace Industries Association

Edward Brady

National Bureau of Standards

Les Breden

Department of Housing and Urban

Devel opment

Maureen Breitenberg

National Bureau of Standards

James Briar

NEC America, Inc.

Carroll Brickenkamp

National Bureau of Standards

Peter Bridenbaugh

Vice President

A1 coa Clarence Brown

Deputy Secretary of Commerce

Crawford Brubaker

Deputy Assistant Secretary for

Aerospace, ITA

John F. Bruce

Howrey & Simon

Steven Butcher

Rubber Manufacturers Association

Donald C. Calvert

Aerospace Industries Association

Wanda Capino

National Bureau of Standards

Carl Cargill

Digital Equipment Corporation

Thomas J. Carr

Motor Vehicle Manufacturers

Association

100
Alan Chappie

Engineering Times

Patrick Cooke

National Bureau of Standards

Lisa Cooper

National Bureau of Standards

Donald Corrigan

National Bureau of Standards

Tony Costanzo

International Trade Administration

A. R. Daniels

NCR Corporation

Helen Davis

ASTM

Eugene DeMichele

Water Pollution Control Federation

Jill Derderian

International Trade Administration

Carvin Di Giovanni

National Machine Tool Builders'

Association

John L. Donaldson

American Society for

Engineering Education

Marge Donnely

International Trade Administration

Ambassador Diana Lady Dougan

Department of State

Dale Dunlop

International Brotherhood of

Electrical Workers

Dan Duvall

International Trade Administration

Jewell Duvall

Office of Consumer Affairs, DOC

C. Edward Eckert

VME Americas Inc.

Rainer U. Faust

AT&T International

Andrew Fee

Wilson Instrument Division

Thomas Feindel

Digital Equipment Corporation

Henry Fernandez

Department of Education

Timothy Finton

Department of State

Sidney Fischler

National Bureau of Standards

Donald C. Fleckenstein

General Electric Company

Robert C. FI ink

Medtronic, Inc.

Mark E. Foster

Lindsay, Hart, Neil & Weigler

Tom Gallogley

International Trade Administration

Lawrence Galowin

National Bureau of Standards

Patricia Garfinkel

Staff, U.S. House of

Representatives

Carol Gassaway

National Bureau of Standards

Robert Gladhill

National Bureau of Standards

Scott Goddin

International Trade Administration

Lars Granholm

National Marine Manufacturers

Association

107
Terry Grimes

National Bureau of Standards

Daniel Gross

National Bureau of Standards

Bruce Guile

National Academy of Engineering

David Hack

Library of Congress

Wiley Hall

National Bureau of Standards

Brian Hannon

International Trade Administration

William F. Hanrahan

CBEMA

Bennett Harman

International Trade Administration

Stephen Hasko

National Bureau of Standards

Marie Haugen

International Trade Administration

Ann Heffernan

National Bureau of Standards

John Henry

International Trade Administration

Bill Holroyd

International Trade Administration

Jeffrey Horlick

National Bureau of Standards

Gregory Hovendon

Department of Justice

George C. Hsu

Reynolds Metals Company

Laurie Hurtado

International Trade Administration

Dominick lacova

Department of State

Richard Jackson

International Trade Administration

Michael Jezbera

International Trade Administration

J. E. Jones

Internatinal Data Corporation

Catherine A. Kachurik

CBEMA

Vicky Kader

International Trade Administration

Linda Keyes

National Bureau of Standards

Frank K. Kitzantides

National Electrical Manufacturers

Association

Joan Koenig

National Bureau of Standards

Howard Kontje

Underwriters Laboratories Inc.

Paul Krupenie

National Bureau of Standards

C. Scott Kulicke

Chairman and CEO

Kulicke and Soffa Industries, Inc.

Jean-Pierre Laclau

Norex, U.S.A.

John J. Lainson

Dutton-Lainson Company

Debbie Lamb

International Trade Administration

Louis F. Laun

Asst. Secretary for International

Economic Policy, ITA

102
Walter G. Leight

National Bureau of Standards

Ethel ene Lewis

National Bureau of Standards

Donald R. Mackay

National Bureau of Standards

Ted Manakas

Corporation for Open Systems

Paul Marrangoni

Federal Communications Commission

Edward Marsh

Ameritech

Dorothy Mazaka

Department of the Treasury

Edward J, McCarthy

Rubber Manufacturers Association

Barbara Meigs

National Bureau of Standards

John Meserve

International Trade Administration

John Mooney

Federal Trade Commission

Beverly Murray

National Medical Care, Inc.

William S. Murray

National Electrical Manufacturers

Association

Reinhold Nelissen

John Deere & Co.

Karl Newell

National Bureau of Standards

George Nichols

Consumer Product Safety Commission

Jean Nichols

National Bureau of Standards

Nancy Niero

C. W. Communications

Joseph G. O' Grady

President, ASTM

JoAnne Overman

National Bureau of Standards

Joan Pauley

National Medical Care, Inc.

John C. Peirce

Howrey & Simon

Ellen Perlman

Design Graphics World

Herbert Phillips

Air-Conditioning and

Refrigeration Institute

Charles Pitcher

International Trade Administration

Ronald Powell

National Bureau of Standards

Raymond Pratt

International Trade Administration

Anthony Radspieler

Bureau of the Census

John Rasmussen

International Trade Administration

Karl Reiner

International Trade Administration

Brian S. Reiser

Bureau of the Census

Gerald H. Ritterbusch

Caterpillar Inc.

William Rockwell

American National Standards

Institute

Frank Rose

Federal Communications Commission

103
Andrew G. Salem

Society of Automotive Engineers

Karen Sasahara

International Trade Administration

Gary T. Saterfield

Anti-Friction Bearing Manufacturers

Association

Jane Schweiker

ASTM

Lyle Schwartz

National Bureau of Standards

Thomas D. Searles

American Lumber Standards Committee

R. E. Segabache

Wilson Instrument Division

Deborah Semb

International Trade Administration

Edwin Shykind

International Trade Administration

Keith Si dwell

Canadian Standards Association

Linda Simon

Automation News

Marcia Slarskey

Digital Equipment Corporation

Christine Sloop

International Trade Administration

Bruce Smart

Under Secretary for

International Trade

Daniel W. Smith

American National Standards

Institute

Michael Smith

Deputy U.S. Trade Representative

H. Brooke Stauffer

National Electrical Manufacturers

Association

Ron Stone

National Marine Manufacturers

Association

M. Leroy Stoner

American Institute of Aero and

Astronautics

Sheryl Swed

Small Business Administration •

John Tascher

Department of Defense

Gregory Tassey

National Bureau of Standards

Nan Taylor

International Data Corporation

John Tesk

National Bureau of Standards

Diane Thompson

Standards Council of Canada

Sara Torrence

National Bureau of Standards

Suzanne Troje

International Trade Administration

Terrance Troy

National Bureau of Standards

James W. Tucker

ETL Testing Laboratories, Inc.

Joan Tyler

National Bureau of Standards

Brenda Umberger

National Bureau of Standards

Gerald Underwood

Office of Metric Programs, DOC

104
George Uriano

National Bureau of Standards

Eric Vadelund

National Bureau of Standards

Li 1 iane Vol cy

Federal Communications Commission

Josephine Walkowicz

National Bureau of Standards

William Walmsley

International Trade Administration

LeRoy Walser

Department of Education

J. K. Walters

American Petroleum Institute

Otto Warnlof

National Bureau of Standards

Stanley I. Warshaw

National Bureau of Standards

Monica Welch

Electronic Data Systems

Corporation

George S. Wham

Chairman, American National

Standards Institute

Alan Whelihan

Office of Metric Programs, DOC

Mitch White

Intergraph Inc.

Richard White

Richard White Wood Products, Inc.

Karen Wilde

International Trade Administration

Eric A. Williams

Digital Equipment Corporation

Merrill A. Yohe, Jr.

AMP Incorporated
U.S. DEPT. OF COMM. 1. PUBLICATION OR 2. Performing Organ. Report No. 3. Publication Date

BIBLIOGRAPHIC DATA

SHEET (See instructions)

REPORT NO.

NBSIR 87-3573 JUNE 1987

4. TITLE AND SUBTITLE

Proceedings of

Conference on Standards and Trade

5. AUTHOR(S)

Walter G. Leight, Editor

6. PERFORMING ORGANIZATION (If joint or other than NBS, see instructions) 7. Contract/Grant No. NATIONAL BUREAU OF STANDARDS

U.S. DEPARTMENT OF COMMERCE

GAITHERSBURG, MD 20899

S. Type of Report & Period Covered

9. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, State, ZIP)

10. SUPPLEMENTARY NOTES

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

11. ABSTRACT (A 200-word or less factual sumnnary of most significant information. If document includes a significant

bibliography or literature survey, mention it here)

The International Trade Administration and the National Bureau of Standards

sponsored a one-day Conference on Standards and Trade on May 5, 1987. These

Proceedings contain the texts of speeches by Government officials and

representatives of the business and standards communities; summaries of questionand-answer periods; and reports of Working Groups that addressed Participation in

International Standardization Activities, Test Data Acceptance, and Adoption of

U.S. Standards.

12. KEY WORDS (S/x to twelve entries; alphabetical order; capitalize only proper names; and separate key words by semicolon s)

Standards; trade,

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