EXECUTIVE OFFICE OF THE PRESIDENT 

 OFFICE OF MANAGEMENT AND BUDGET 

WASHINGTON, D.C. 20503 

 

 ADMINISTRATOR 

 OFFICE OF 

 INFORMATION AND 

REGULATORY AFFAIR 

 

August 12, 2005 

The Honorable Vernon J. Ehlers 

Chairman, Subcommittee on Environment, 

 Technology and Standards 

Committee on Science 

U.S. House of Representatives 

Washington, DC 20515-2203 

Dear Mr. Chairman: 

 I am pleased to submit the Fiscal Year 2004 annual report on Federal participation in the 

development and use of voluntary consensus standards, in accordance with the Office of 

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

National Technology Transfer and Advancement Act Amendments of 1996 (NTTAA, Pub. L. 

No. 104-113). This report was prepared by the National Institute of Standards and Technology 

(NIST) at the Department of Commerce based on input from 26 agencies. NIST and OMB staffs 

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

availability, accuracy, and relevance of this report. 

The NTTAA directs Federal government agencies to achieve greater reliance on 

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

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

participate as appropriate in the activities of voluntary consensus standards developing 

organizations to help ensure that standards produced in the private sector are more likely to be 

appropriate for use by Federal agencies. 

 The FY 2004 report continues to demonstrate agencies’ compliance with the goals of the 

NTTAA; i.e., greater use of private sector standards and active, strategically focused 

participation in voluntary consensus standards developing activities. Federal agencies reported 

participation in 431 private sector standards developing organizations during FY 2004, although 

the individual employee participation was slightly less than the previous year, from 3,568 in FY 

2003 to 3,208 in FY 2004. Agencies have reported use of 4,559 voluntary consensus standards 

in their procurement and regulatory activities since FY 1997 and adoption of about 2,000 

voluntary consensus standards in place of government-unique standards. In FY 2004, 104 

voluntary consensus standards were substituted for government-unique standards in agencies’ 

procurement and regulatory activities. 
This report also demonstrates that agencies develop a minimal number of new standards 

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

replacement by commercial standards. 

Table 3.1 illustrates the cumulative use of 71 government-unique standards as well as the 

newly developed and discontinued standards reported per year from FY 1997 to present. 

Appendix C lists government-unique standards used in lieu of private sector standards as well as 

the associated explanations for such use reported from FY 1997 to FY 2004. 

Only one regulatory government-unique standard was reported to have been developed in 

FY 2004 by the Department of Labor; i.e., Fire Protection for Shipyards, 29 CFR Part 1915, 

Subpart P. 

Two government unique standards were discontinued in FY 2004. 

• The Centers for Medicare and Medicaid Services of the Department of Health and 

Human Services directed its contractors to discontinue use of the National 

Standards Format, which had become a de facto national standard across the 

health care payment industry. ANSI X12 837 will be used in its place. 

 

• The General Services Administration reported an administrative correction to its 

FY 2000 reporting of a Defense Logistics Agency (DLA) Commercial Item 

Description (CID) for Nail Anchors. The CID was thought to have replaced an 

ASTM test method. In fact the DLA CID incorporates the ASTM test method. 

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

voluntary consensus standards. 

Sincerely, 

 John D. Graham, Ph.D. 

Administrator 

Office of Information 

 and Regulatory Affairs 

Enclosure 

Identical Letter Sent to The Honorable David Wu; The Honorable Bart Gordon; 

The Honorable Sherwood L. Boehlert; The Honorable Ted Stevens; 

The Honorable Daniel Inouye; The Honorable John Ensign; The Honorable John Kerry; 

The Honorable Richard B. Cheney; and The Honorable J. Dennis Hastert 

2
THE SECRETARYOFCOMMERCE 

Wash~ngton,D.C 20230 

June 24,2005 

The Honorable Joshua B. Bolten 

Director, Office of Management and Budget 

Washington, D.C. 20503 

Dear Mr. Bolten: 

I enclose the Eighth Annual Report on Federal Agency Use of Voluntary Consensus 

Standards and Conformity Assessment. This document represents activities carried out by 

federal agencies during FY 2004, as required under Public Law 104- 1 13, the National 

Technology Transfer and Advancement Act, and the Office of Management and Budget (OMB) 

Circular A-1 19. I am pleased to submit this report to OMB for review and subsequent 

forwarding to Congress. 

This report demonstrates that federal agencies continue to make advances in refining and 

simplifying their standards-related activities. Agency use of government-unique standards in 

lieu of voluntary consensus standards continues to account for a very small percentage of overall 

use -between 1 and 4 percent, while use of voluntary consensus standards continues to increase. 

Federal agencies are also demonstrating a more complete understanding of the 

requirements set forth in the Act and the Circular resulting in better reporting of agency 

activities. This report contains the most accurate data compiled to date regarding federal 

agencies' use of government-unique standards in lieu of voluntary consensus standards. Federal 

agencies are exploring ways to more consistently report and categorize their standards activities. 

In the future, continually improving reporting and editing processes, as well as training 

for federal agency personnel, will help ensure these reports are compiled more efficiently. Our 

goal is to submit this information to OMB in compliance with the timeframe delineated by the 

Circular. 

If you require further information, please feel free to contact Mary Saunders, Division 

Chief, National Institute of Standards and Technology at 301-975-2396. 

Enclosure 
NISTIR 7227 

Eighth Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment 

Kevin L. McIntyre

Michael B. Moore

Standards Coordination and Conformity Group 

Standards Services Division 

Technology Services
NISTIR 7227

Eighth Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment

Kevin L. McIntyre

Michael B. Moore

Standards Coordination and Conformity Group 

Standards Services Division 

Technology Services 

May 2005

U.S. DEPARTMENT OF COMMERCE 

Carlos M. Gutierrez, Secretary 

TECHNOLOGY ADMINISTRATION 

Michelle O’Neill, Deputy Under Secretary of Commerce for Technology 

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY 

Hratch G. Semerjian, Acting Director
Table of Contents 

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

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

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

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

3.2 – Federal Agency Use of Private Sector Standards.................................................................... 5

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

3.4 – Summary Observations............................................................................................................. 6

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

4.1 – Federal Agency Participation in Private Sector Standards Development Bodies................ 7

4.2 – Federal Agency Employees Participating in Private Sector Standards Activities................ 7

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

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

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

7.0 – The Interagency Committee on Standards Policy......................................................... 9

8.0 – Challenges and Opportunities....................................................................................... 10

Appendix A – FY 2004 List of Reporting Federal Agencies ............................................. A-1

Appendix B – Federal Agency Use of Standards and Participation in Voluntary 

Consensus Standards Bodies................................................................................................ B-1

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

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

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

Standards Incorporated in FY 2004.............................................................................................. C-1

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

Consensus Standards Discontinued in FY 2004 ........................................................................... C-2

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

Standards from FY 1997 through FY 2004 .................................................................................. C-3

ii
Summary Report on Federal Agency Use of Voluntary Consensus Standards 

and Conformity Assessment Activities for FY 2004 

1.0 – Executive Summary 

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

U.S. Department of Commerce’s (DOC’s) National Institute of Standards and 

Technology (NIST) in compliance with OMB Circular A-119 and Pub. L. No. 104-113, 

the National Technology Transfer and Advancement Act (NTTAA). It describes 

activities related to the use of voluntary consensus standards and conformity assessment 

practices by agencies of the Federal government during FY 2004 as required by Section 9 

of the Circular. This report presents the standards and conformity assessment activities 

of 26 Federal agencies. 

The OMB Circular states that it does not establish a preference among standards 

developed in the private sector. Therefore, references in the NTTAA and the OMB 

Circular to voluntary consensus standards are interpreted throughout this report as private 

sector standards, a term that includes non-consensus as well as consensus standards. 

Consequently, the information contained in this report, as received from the agencies, 

includes the use of private sector standards, both consensus and non-consensus, as well as 

participation in standards development activities of both consensus and non-consensus 

standards developing organizations. 

Reported data show that, overall, Federal agencies continue to look overwhelmingly to 

the private sector to fulfill government needs rather than creating new governmentunique standards. Federal agencies reported using 4,559 private sector standards during 

FY 2004, while using only 71 government-unique standards during the same period. 

For FY 2004, Federal agencies reported 179 new uses of private sector standards. In 

addition, during the same period agencies substituted 104 private sector standards for 

government-unique standards. Agency reports on the number of government-unique 

standards used in lieu of voluntary consensus standards showed a net decrease of one 

(i.e., one new use and two discontinuations) reported in FY 2004. 

Federal agencies reported participation in 431 private sector standards developing 

organizations during FY 2004. The number of agency staff participating in standards 

activities was 3,208, an 11% decline from the previous reporting period, but still 

substantially higher than the numbers reported in FY 1999 through FY 2001, when 

participation dropped by more than 15%. Private sector standards developers continue to 

recruit government participation to ensure input on key standards-related issues. 

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

participation in standards developing organizations is becoming increasingly difficult 

because of competing organizational and budgetary priorities. Federal agencies continue 

to make advances in their ability to assess their standards-related activities, thus 

permitting them to make accurate reports of their activities for incorporation into this 

1
annual report. NIST is focusing its efforts on improving information sharing among 

Federal agencies, as well as between the public and private sectors. Most recently, NIST 

launched standards.gov, a web portal offering background materials, useful links, and 

search tools for locating information about the use of standards in government. 

2.0 – Overview and Scope 

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

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

standards in regulation, procurement and conformity assessment during FY 2004. In 

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

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

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

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

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

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

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

participate in the activities of voluntary consensus standards developing organizations 

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

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

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

appropriate for use by Federal agencies. While these policies have been a part of the 

Circular for many years, the enactment of the NTTAA served to codify these policies into 

statute, thereby reinforcing them. 

This report presents the standards and conformity assessment activities of the 26 Federal 

agencies listed in Appendix A. For the first time, it includes data from the Department of 

Homeland Security (DHS). On March 1, 2003, the majority of 180,000 employees from 

22 agencies were merged into DHS to create the 15th cabinet level department in the 

Federal government. Many of the 22 agencies that now report as part of DHS previously 

reported their standards activities to NIST through their former parent Departments. 

In reporting the full measure of their efforts at minimizing reliance on governmentunique standards, Federal agencies have historically reported the use of private sector 

standards including other than voluntary consensus standards. The OMB Circular 

classifies these other private sector standards as non-consensus standards, industry 

standards, company standards, or de facto standards. The Circular also states that it does 

not establish a preference among standards developed in the private sector. 

Consequently, the information contained in this report, as received from the agencies, 

includes the use of standards by, and participation in standards development activities of, 

both consensus and non-consensus standards developing organizations. 

This report continues a shift, begun in FY 2003, in NIST’s reporting methodology. The 

new methodology reflects the constructive feedback received from the reporting agencies 

and the public about previous reports. It also reflects discussions held by the Interagency 

2
Committee on Standards Policy (ICSP). As with supporting data received for the FY 

2003 report, NIST will make individual agency reports available to interested parties at 

http://standards.gov. These reports are also available directly from NIST. 

3.0 – Federal Agency Use of Standards 

The NTTAA and OMB Circular require that Federal agencies use voluntary consensus 

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

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

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

either be inconsistent with applicable laws or otherwise impractical. 

According to Section 6 of the OMB Circular: 

 

"Use" means the incorporation of a standard in whole, in part, or 

by reference for procurement purposes, and the inclusion of a 

standard in whole, in part, or by reference in regulation(s). 

 

 "Impractical" includes circumstances in which such use would fail 

to serve the agency's program needs; would be infeasible; would 

be inadequate, ineffectual, inefficient, or inconsistent with agency 

mission; or would impose more burdens, or would be less useful, 

than the use of another standard. 

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

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

sector standards for government-unique standards wherever possible. 

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

Standards 

According to Section 6 of the Circular, the heads of agencies: 

 “...must transmit to OMB through NIST an explanation of the 

reason(s) for using government-unique standards in lieu of 

voluntary consensus standards.” 

Table 3.1 illustrates the cumulative use since FY 1997 of government-unique standards in 

lieu of private sector standards, as well as the number of government-unique standards 

introduced and withdrawn in each fiscal year. For FY 2004, the Department of Labor 

(DOL) added one, and the General Services Administration (GSA) and the Department of 

Health and Human Services (HHS) each discontinued use of one government-unique 

standard. These changes yield a net loss of one government-unique standard in use by all 

reporting agencies in FY 2004. As a result, a total of 71 government-unique standards 

were reported as being in use during the period from FY 1997 through FY 2004. This 

figure is approximately two percent of the total number of voluntary and government3
unique standards reported as used during the same period by all reporting agencies. 

Table 3.1 Government-unique Standards Used in Lieu of 

Private Sector Standards 

Agency FY 

1997 

FY 

1998 

FY 

1999 

FY 

2000 

FY 

2001 

FY 

2002 

FY 

2003 

FY 

2004 

HHS 3 3 3 3 3 3 3 2 

HUD 2 2 2 2 2 

DOL 1 2 4 5 

DOT 1 2 2 2 2 3 3 3 

EPA 3 28 29 40 45 50 50 

GSA 3 2 2 3 2 

NARA 1 1 1 1 1 

CPSC 1 1 1 2 2 

GPO 4 4 4 4 4 

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

Discontinued 

Uses -1 -2 

Total in Use 4 8 33 45 56 63 72 71 

Note: DoD and NASA use the categorical reporting method allowed in Section 12 of OMB 

Circular A-119. Therefore, their use of government-unique standards is not quantified 

in this table. 

The OMB Circular permits Federal agencies to report their use of private sector standards 

on either a categorical or a transactional basis. For agencies that routinely make 

reference to standards in very large procurements or in very large numbers of 

procurement actions, Section 12 of OMB Circular A-119 states that those agencies may 

report their use of standards on a categorical basis. Therefore, agencies that make largescale procurements are not required to list each use of a government-unique standard in 

lieu of one or more private sector standards in procurement actions. However, an agency 

that reports categorically must meet certain requirements as outlined in the OMB 

Circular. For example, the agency must maintain a centralized standards management 

system that identifies how the agency uses both government-unique and voluntary 

consensus standards. The agency must also maintain records on the groups or categories 

in which the agency uses government-unique standards in lieu of voluntary consensus 

standards. Only two agencies, the Department of Defense (DoD) and the National 

Aeronautics and Space Administration (NASA), consistently report standards use in this 

manner. Agencies that report categorically are also required to have in place a system to 

ensure that government-unique standards are developed only when suitable voluntary 

consensus standards are not available for use. In those cases when government-unique 

standards are required because private-sector standards do not exist, use of the 

government-unique standard is not subject to reporting. 

Regulatory agencies must report on a transactional basis since they use far fewer 

standards in their rulemaking processes and must therefore count each instance of use. 

Table 3.1 indicates that Federal agencies develop only a small number of new 

government-unique standards each year for regulatory purposes. 

A complete listing of government-unique standards used in lieu of private sector 

4
standards from FY 1997 through FY 2004 is included in this report as Appendix C. The 

list includes rationales explaining the reason(s) why each listed private sector standard 

was not used. Agency justifications for new uses of government-unique standards tend to 

focus on the need for more detailed requirements, higher performance specifications and 

measurements, and/or the need to accommodate highly specialized technologies not 

adequately addressed by private sector standards. 

Since Federal agencies were not required to report the use of government-unique 

standards prior to the onset of the NTTAA and OMB reporting requirements (1997), 

there are no historical data available to determine the total number of government-unique 

standards currently in use by Federal agencies. As an alternative to a potentially 

burdensome process of surveying Federal agencies to gather this information, NIST is 

developing a baseline inventory of standards referenced in the Code of Federal 

Regulations (CFR). After completion in fiscal year 2005, this inventory will permit 

identification of currently used government-unique standards that were adopted prior to 

1997. Identification of these government-unique standards may well uncover 

opportunities for agencies to replace these standards through collaborative efforts with 

private-sector standards developers. This database, although still under development, is 

currently available at http://standards.gov. 

3.2 – Federal Agency Use of Private Sector Standards 

This measure provides a count of the total number of private sector standards used by the 

Federal government in a reporting period. Changes in this number from year to year 

generally reflect the regulatory or procurement priorities and policies of individual 

agencies during the reporting year. 

As illustrated by Figure 3.2, the total 

number of private sector standards in use 

by Federal agencies has grown rather 

steadily since the initiation of agency 

reporting under the NTTAA in 1997. In 

FY 2004, Federal agencies used a total of 

179 private sector standards for the first 

time. See Appendix B for detailed 

figures of standards use on an agency 

basis. It should be noted that, since these 

data include only standards used since t

onset of agency reporting under the 

NTTAA in 1997, the data do not include all nongovernmental standards currently in use 

by DoD, which started its efforts to minimize use of government-unique standards prior 

to enactment of the NTTAA. Consequently, with 9,156 total private sector standards in 

use as of the close of FY 2004, DoD continues to lead all other Federal agencies in the 

cumulative use of private sector standards. 

Figure 3.2 – Private Sector Standards 

Used by Federal Agencies

4559

4380 3984

3958

2803

1883

4061

3383

0

1000

2000

3000

4000

5000

6000

1997 1998 1999 2000 2001 2002 2003 2004

Fiscal Year he 

5
3.3 – Private Sector Standards Substituted for Government-Unique 

Standards 

As illustrated by Figure 3.3, Federal agencies continue to replace government-unique 

standards with private sector standards in fulfillment of Section 12 of the NTTAA. 

The cumulative trend of agency 

substitution of voluntary consensus 

standards for government-unique 

standards is represented in Figure 

3.3. The data in Appendix B show 

that, as in previous years, DoD 

continues to be responsible for the 

largest number of substitutions with 

97 in FY 2004. DoD’s standards 

substitutions address a diverse set of 

technologies, including metals and 

alloys, and manufactured parts. 

Figure 3.3 - Private Sector Standards 

Substituted for Government-unique 

Standards

150

459

1542

1647 1738

1923

2027

1006

0

500

1000

1500

2000

2500

1997 1998 1999 2000 2001 2002 2003 2004

Fiscal Year

3.4 – Summary Observations 

It is difficult to completely and accurately represent the full measure of standards use 

through this rather cursory review of reported figures. Even so, the overall trends 

continue to show that Federal agencies are making positive efforts to increase their use of 

private sector standards while minimizing their reliance upon standards developed 

specifically for government use. 

OMB, NIST, and the reporting agencies continue to review the data reported in current 

and previous years to improve the consistency of the reported data. All concerned parties 

agree that this improved communication and interaction will lead to a better, more 

consistent means of reporting data, which in turn will lead to a better means for 

evaluating the effectiveness of the Federal government’s efforts to satisfy the intent of the 

NTTAA. 

4.0 – Federal Participation in Private Sector Standards Activities 

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

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

in the development of voluntary consensus standards when consultation and participation 

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

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

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

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

resources.” 

6
4.1 – Federal Agency Participation in Private Sector Standards 

Development Bodies 

Most agencies reported little or no change in their participation in voluntary consensus 

standards bodies in FY 2004. Some agencies, including HHS and DoD, participated in 

significantly more standards developing organizations than in the previous year, while 

others, such as DOC and Department of Energy (DOE), participated in fewer. Overall, 

Federal agencies reported participation in 431 private sector standards developing 

organizations (SDOs) during FY 2004, compared to 433 reported for FY 2003. Agencies 

reported participation in activities of a wide array of standards developers, both domestic 

and international. The table in Appendix B shows SDO participation by agency. The list 

of organizations includes American National Standards Institute (ANSI)-accredited 

voluntary consensus standards developers, industry and trade associations, industry 

consortia, state-level organizations, and international organizations. 

Federal agency participation is often affected by current purchasing or regulatory 

priorities within the agencies as well as technology-based efforts in which agencies are 

engaged. Agencies also report that their participation is affected in large part by the 

availability of financial and human resources assigned to carrying out these 

responsibilities. 

A complete listing of the standards developing organizations in which Federal agencies 

participated can be viewed in the extended appendices to this report on 

http://standards.gov. 

4.2 – Federal Agency Employees Participating in Private Sector 

Standards Activities 

Figure 4.2 shows a decrease in employee participation in private sector standards bodies, 

although the level of participation in FY 

2004 is not far different from past levels 

of participation. Most agencies reported 

little or no change from FY 2003 in FY 

2004. DOE, GSA, and DOC increased 

their employee participation during this 

reporting period; however, HHS, 

Department of Interior (DOI), and U. S. 

Department of Agriculture (USDA) 

decreased their levels of employee 

participation. DOC and DOE participated 

in fewer standards bodies, but with more 

representation. Data detailing participation on an agency basis is provided in Appendix 

B. No specific reasons were reported for the decrease in individual employee 

participation; however, as with participation at the agency level, employee participation 

is affected by the availability of both human and financial resources. In some cases, 

resource constraints oblige an agency to focus attention on its highest priority activities 

Figure 4.2 - Number of Federal Agency 

Employees Participating in Private 

Sector Standards Activities

3208

3298

3568

3229

2723

2723

2662

3265

2000

2500

3000

3500

4000

1997 1998 1999 2000 2001 2002 2003 2004

Fiscal Year

7
and to strive to make its participation in those activities as effective as possible. Other 

factors affecting federal employee participation levels include competing organizational 

priorities as well as personnel changes, workplace attrition, and retirements, all of which 

present some difficulty for agencies to maintain constant levels of participation as well as 

accurate records of their activities. In one case, an agency participated in several hundred 

standards development activities of well over 100 private sector standards bodies. 

However, the exact number of employee participants was not known since the agency 

lacks an established procedure to gather this information. 

4.3 – Summary Observations 

The reported data support the fact that Federal agencies continue to put forward earnest 

efforts to satisfy the requirements of the NTTAA and the OMB Circular. Over and above 

the applicable mandates, Federal agencies have demonstrated that they recognize the 

importance of participation in private sector standards activities. Participation levels still 

vary from agency to agency for a number of reasons, including different agency needs, 

competing organizational priorities, limited resources, and personnel losses. 

5.0 – Federal Agency Conformity Assessment Activities 

Section 12(b) of the NTTAA requires NIST to coordinate Federal, State, and local 

standards activities and conformity assessment activities with private sector standards 

activities and conformity assessment activities, with the goal of eliminating unnecessary 

duplication and complexity in the development and promulgation of conformity 

assessment requirements and measures. Federal conformity assessment activities are a 

means of providing assurance that the products and services regulated or procured by 

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

Agency conformity assessment procedures may include sampling and testing, inspection, 

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

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

conformity to agency requirements; mandatory labeling and advertising requirements; 

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

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

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

impact assessments. 

OMB Circular A-119 directed the Secretary of Commerce to issue guidance to the 

agencies to improve coordination on conformity assessment. That guidance was 

published by NIST in 2000 and can be found in Part 287 of Title 15 of the U.S. Code of 

Federal Regulations (15 C.F.R., pt. 287). The guidance applies to all agencies that set 

policy for, manage, operate, or use conformity assessment activities and results, both 

domestic and international, except for activities carried out pursuant to treaties. The 

guidance outlines Federal agencies' responsibility for evaluating the efficacy and 

efficiency of their conformity assessment activities. Each agency is responsible for 

coordinating its conformity assessment activities with those of other cognizant 

government agencies and with those of the private sector in order to make more 

8
productive use of the increasingly limited federal resources available for the conduct of 

conformity assessment activities and to reduce unnecessary duplication. 

The provisions are solely intended to be used as guidance for agencies in their conformity 

assessment activities; they do not preempt the agencies' authority and responsibility to 

make regulatory and procurement decisions authorized by statute or required to meet 

programmatic objectives and requirements. 

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

Many agencies believe that OMB Circular A-119 continues to be effective in guiding 

their efforts toward achieving the goals of the NTTAA and the intent of Congress. For a 

handful, the extent to which standards are incorporated into federal procurements and 

regulations is due largely to the ability of standards professionals in agencies to leverage 

the existence of the law and Circular to promote use of, and participation in the 

development of voluntary consensus standards. Some sample comments, as reported by 

Federal agencies, are summarized below: 

 DOI’s U. S. Geological Survey stated that, since its issuance, Circular A-119 has 

worked in a straightforward manner to encourage the use of voluntary consensus 

standards. 

 The Department of Housing and Urban Development (HUD) states that the policy 

continues to be effective in encouraging agencies to replace Federal standards 

with publicly developed standards. This has resulted in more up-to-date and 

technically accurate standards. 

 The Nuclear Regulatory Commission (NRC) believes that the Circular provides 

appropriate direction and encouragement for Federal agencies to develop internal 

agency-wide guidelines. The Circular also provides sufficient and reasonable 

flexibility for each agency to make an independent determination relative to 

participation on voluntary consensus bodies and use of developed standards. 

The Environmental Protection Agency (EPA) offered a number of recommendations for 

improvement. The recommendations suggest that changes in the reporting process are 

needed to bring about accurate reporting of standards activities and to eliminate 

unreasonable performance comparisons that could result from presenting regulatory 

agencies in side-by-side comparisons with procurement agencies. 

7.0 – The Interagency Committee on Standards Policy 

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

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

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

Secretary of Commerce through the Director of NIST. Section 14 of OMB Circular 

A-119 places a responsibility on those agencies with significant interest in the use of 

standards to "designate a senior level official as the Standards Executive who will be 

9
responsible for the agency's implementation of (the) Circular and who will represent the 

agency on the ICSP." 

There were 52 members on the ICSP during FY 2004. The membership included agency 

Standards Executives, their alternate representatives, NIST support staff, and 

representation from OMB. Four agencies had vacant Standards Executive positions; 

there were six vacancies in FY 2003. The newly-formed Department of Homeland 

Security (DHS) appointed representatives to the committee for the first time. The 

committee anticipates an additional appointment to represent the Access Board. The 

Access Board, formerly the Architectural and Transportation Barrier Compliance Board, 

is an independent Federal board created by Congress in 1973 to address public access for 

persons with disabilities. Both the Access Board and DHS make extensive use of private 

sector standards and have conformity assessment programs. 

The ICSP met four times in FY 2004. Meetings were held in November 2003, February 

2004, June 2004, and September 2004 at various locations in the Washington 

metropolitan area. Of note, the June meeting was the first joint meeting with ANSI’s 

Government Member Forum to discuss issues of mutual interest. Future joint meetings 

with organizations having interests related to the Committee’s role will be explored. 

The following examples illustrate some of the issues discussed during FY 2004: 

1. A NIST-sponsored study: Measuring the Benefits of the National Technology 

Transfer and Advancement Act. This report attempted to quantify economic benefits 

realized by Federal agencies through NTTAA compliance. 

2. Continued dialogue on the Leadership in Energy and Environmental Design (LEED) 

Green Building Rating System and its use by Federal agencies. 

3. A discussion of joint ANSI and EPA efforts on an Environmentally Preferable 

Purchasing program. 

4. DOE’s information system for managing standards development and participation; 

i.e., RevCom. 

8.0 – Challenges and Opportunities 

As in past years, Federal agencies continue to experience significant personnel turnover 

at all organizational levels due to reorganizations, accelerated or early retirements, and 

normal attrition. These changes make it very difficult for Federal agencies to retain highlevel managers who appreciate the importance of standards and who visibly support 

standards-related activities. Likewise, due to staff turnover, Federal agencies also 

continue to struggle to retain “institutional memory” of past standards policies, 

responsibilities, and practices. Also, competing organizational and budgetary priorities 

cause agencies to make difficult choices that may lead to reduced participation in 

standards development activities. 

During FY 2004, representatives from several ICSP member agencies participated in 

strategy meetings along with several voluntary consensus standards developers and 

10
representatives from ANSI and OMB. The purpose of these meetings was to gather input 

from key organizations having a stake in the success of the NTTAA. This input would 

then serve as the basis for NIST strategic plans designed to advance the principles of the 

NTTAA and the OMB Circular. As a result of these meetings, the stakeholder group 

identified certain outcomes that, if achieved, would lead to substantially increased use of 

voluntary consensus standards and participation by Federal agencies in the activities of 

standards developing bodies. For example, high-level Federal agency leadership was 

identified as the primary driver of successful NTTAA implementation because of agency 

ability to direct policy and resources in ways that bring about other desirable outcomes 

such as increased Federal participation and collaboration with the private sector. 

Ultimately, this cooperative stakeholder effort represents an opportunity to redirect and 

focus the efforts of key players in ways that can maximize the benefits of NTTAA 

implementation for both public and private sector organizations. To enhance this effort, 

it was decided that future meetings of the NTTAA stakeholders group would involve 

participants from private industry so that interests and perspectives of that very important 

stakeholder group can be incorporated into future strategy and action plans. 

Sound economic analysis that demonstrates the benefits of greater use of private sector 

standards and conformity assessment activities is essential in making the case for Federal 

agency leaders to intensify their agencies’ activities in these areas. However, capturing 

this important information has thus far proven to be extremely difficult. The NISTsponsored study, Measuring the Benefits of the National Technology Transfer and 

Advancement Act, which was conducted by Research Triangle Institute, points to (1) a 

lack of useful data necessary to support economic analysis, and (2) the difficulties 

Federal agencies face in gathering data that can be used to estimate economic benefits 

broadly across the Federal government. Consequently, there are real opportunities for 

advances in methods and techniques that can be employed to demonstrate real economic 

benefits of NTTAA implementation. 

However, in some cases, agencies are able to demonstrate clear economic benefits as well 

as qualitative benefits on a case-by-case basis. DoD has created several case studies1

 that 

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

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

 Reduced labor costs to operate and maintain equipment 

 Lower inventory costs 

 Improved safety 

 Improved equipment readiness 

 Enhanced interchangeability, reliability, and availability of equipment and parts 

and better equipment performance 

Federal agencies are able to point to specific instances where they have benefited from 

NTTAA implementation in ways that cannot be measured in dollars. For example, one 

indicator that the NTTAA is receiving more widespread consideration within the EPA is 

 

1

 DoD case studies can be obtained from the Defense Standardization Program website at 

http://www.dsp.dla.mil/. 

11
the "beyond-regulation" use that EPA is making of voluntary consensus bodies and of 

ANSI in particular. EPA leaders in environmentally preferable procurement 

acknowledged the important role of voluntary consensus organizations for the 

development and promulgation of standards for environmentally conscientious products. 

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

such environmental products. Together, they provided organizations with criteria that can 

serve as a guideline for use in committee work where standards and/or testing procedures 

for these products are developed. ANSI conducted several workshops and training 

sessions in cooperation with EPA and posted information on ANSI’s website. 

Federal agencies are reaping significant benefits from their current use of private sector 

standards and participation in private sector standards and conformity assessment 

activities. There is evidence to suggest that enhanced activities in these areas will lead to 

even more positive results, both economic and otherwise, for Federal agencies that 

comply with the NTTAA and OMB Circular A-119. Greater efforts to document these 

positive results could prove to be the key to full realization of the potential benefits of 

NTTAA compliance. 

12
Appendix A – FY 2004 List of Reporting Federal Agencies 

Agency Acronym

Department of Agriculture USDA 

Department of Commerce DOC 

Department of Defense DoD 

Department of Energy DOE 

Department of Education ED 

Department of Health and Human 

Services 

HHS 

Department of Homeland Security DHS 

Department of Housing and Urban 

Development 

HUD 

Department of the Interior DOI 

Department of Justice DOJ 

Department of Labor DOL 

Department of State DOS 

Department of Transportation DOT 

Department of the Treasury TRES 

Department of Veterans Affairs VA 

Environmental Protection Agency EPA 

Agency for International Development USAID 

General Services Administration GSA 

National Archives and Records 

Administration 

NARA 

National Aeronautics and Space 

Administration 

NASA 

National Science Foundation NSF 

Consumer Product Safety Commission CPSC 

Federal Communications Commission FCC 

Federal Trade Commission FTC 

Nuclear Regulatory Commission NRC 

Government Printing Office GPO 

A-1
Appendix B – Federal Agency Use of Standards and Participation in Voluntary Consensus 

Standards Bodies 

I II III IV V VI VII VIII 

Agency Governmentunique 

Standards in 

Use in lieu of 

Voluntary 

Consensus 

Standards 

FY 1997-2004 

Voluntary 

Consensus 

Standards 

Substituted for 

Governmentunique 

Standards in 

FY 2004 

Voluntary 

Consensus 

Standards in 

Use in FY 

2004 

Employee 

Participation in 

Voluntary 

Consensus 

Standards 

Bodies in 

FY 2004

Change 

from 

Previous 

Year 

Voluntary 

Consensus 

Standards 

Bodies with 

Agency 

Participation in 

FY 2004

Change 

from 

Previous 

Year

USDA 0 5 145 82 -24 35 -7 

DOC 0 0 0 438 23 94 -24 

DoD * 97 97 436 -14 123 68 

ED 0 0 0 0 -2 0 -1 

DOE 0 0 1325 729 55 65 -20 

HHS 2 0 711 503 -120 182 17 

DHS 0 0 13 10 10 7 7 

HUD 2 0 300 10 0 5 0 

DOI 0 0 788 269 -376 19 -6 

DOJ 0 0 1 5 0 1 0 

DOL 5 0 165 54 -7 19 3 

DOS 0 0 0 7 7 1 1 

DOT 3 0 343 167 0 41 11 

TRES 0 0 5 5 2 5 2 

VA 0 0 0 4 0 18 1 

EPA 50 0 67 45 1 23 2 

USAID 0 0 0 0 0 0 0 

GSA 2 0 305 91 66 26 0 

NARA 1 2 52 19 6 10 0 

NASA * 0 39 147 3 30 -3 

NSF 0 0 0 5 2 5 -2 

CPSC 2 0 0 30 -1 8 1 

FCC 0 0 0 5 0 7 0 

FTC 0 0 0 0 0 0 0 

NRC 0 0 77 145 9 13 -2 

GPO 4 0 126 2 0 6 2 

Totals 71 104 4559 3208 -360 ** ** 

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

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

participation from two or more Federal agencies.) 

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

Standards 

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

Consensus Standards Incorporated in FY 2004 

Agency: Department of Labor (DOL) 

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

Voluntary Standard Rationale 

NFPA 312-2000 Standard for 

Protection of Vessels During 

Construction, Repair, and 

Lay-Up 

NFPA 33-2003 Standard for 

Spray Application Using 

Flammable or Combustible 

Materials 

 Many consensus standards were relied on for various provisions in OSHA's 

final rule, including 15 consensus standards that are incorporated by 

reference. However, OSHA and its negotiated rulemaking committee 

determined that there was no single consensus standard available that 

covered all the topics in the rule. 

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

Voluntary Consensus Standards Discontinued in FY 2004 

Agency: Department of Health and Human Services (HHS) 

Government Standard: National Standard Format [Incorporated: 1997] 

Voluntary 

Standard Rationale 

ANSI X12 

837 

 The NSF was used widely across the health care payment industry and has become a 

defacto national standard. However, the Centers for Medicare and Medicaid Services 

(CMS) directed their contractors to discontinue use of the NSF standard and replace it with 

ANSI X12 837 by the beginning of FY 2003. 

Agency: Government Services Administration (GSA) 

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

Anchors) [Incorporated: 2000] 

Voluntary 

Standard Rationale 

Not 

applicable 

 Upon subsequent review, it was determined that this is not a government-unique standard. 

Rather, it is described by the Defense Logistics Agency, the originator of the document, as a 

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

standard ASTM E488. 

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

Consensus Standards from FY 1997 through FY 2004 

Government Unique Standards used in lieu of Voluntary Consensus Standards 

 

Agency: Consumer Product Safety Commission (CPSC) 

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

Voluntary Standard Rationale 

ASTM F1427-96 The CPSC rule goes beyond the provisions of the ASTM 

voluntary standard to provide increased protection to children 

from the risk of death and serious injury from entrapment. 

 

 

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

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

Voluntary Standard Rationale 

Voices of Safety International (VOSI) standard on 

lead in candle wicks 

The U.S. Consumer Product Safety Commission found that the 

VOSI standard is technically unsound, and thus would not result 

in the elimination or adequate reduction of the risk, and that 

substantial compliance with it is unlikely. See FR/Vol. 68, No. 

75/Friday, April 18, 2003, pp. 19145-19146, paragraph H2, 

Voluntary Standards for further information on this finding. 

 

 

Agency: Department of Labor (DOL) 

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

Voluntary Standard Rationale 

IEEE Standard 242-1986 Recommended Practice 

for Protection and Coordination of Industrial and 

Commercial Power Systems (IEEE Buff Book) and 

NFPA 70 - national Electric Code 

The MSHA rule is a design-specific standard. The NFPA and 

IEEE standards were used as a source for the rule; however, 

the exact requirements of the rule were tailored to apply 

specifically to electric circuits and equipment used in the coal 

mining industry. 

 

 

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

CFR 1910, Subpart E [Incorporated: 2003] 

Voluntary Standard Rationale 

Life Safety Code, NFPA 101-2000 The OSHA standard addresses only workplace conditions 

whereas the NFPA Life Safety Code goes beyond workplaces. 

However, in the final rule OSHA stated that it had evaluated the 

NFPA Standard 101, Life Safety Code, (NFPA 101-2000) and 

concluded that it provided comparable safety to the Exit Route 

Standards. Therefore, the Agency stated that any employer who 

complied with the NFPA 101-2000 instead of the OSHA 

Standard for Exit Routes would be in compliance. 

 

 

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

P [Incorporated: 2004] 

Voluntary Standard Rationale 

NFPA 312-2000 Standard for Protection of Vessels 

During Construction, Repair, and Lay-Up 

Many consensus standards were relied on for various provisions 

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

C-3
NFPA 33-2003 Standard for Spray Application 

Using Flammable or Combustible Materials 

incorporated by reference. However, OSHA and its negotiated 

rulemaking committee determined that there was no, one 

consensus standard available that covered all the topics in the 

rule. 

 

 

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

2003] 

Voluntary Standard Rationale 

Non-Sewered Waste Disposal Systems--Minimum 

Requirements, ANSI Z4.3-1987 

The ANSI standard was not incorporated by reference because 

certain design criteria allowed in the ANSI standard, if 

implemented in an underground coal mine, could present health 

or safety hazards. For instance, combustion or incinerating 

toilets could introduce an ignition source which would create a 

fire hazard. For certain other design criteria found in the ANSI 

standard, sewage could seep into the groundwater, or overflow 

caused by rain or run-off could contaminate portions of the mine. 

 

 

Government Standard: Steel Erection Standards [Incorporated: 2002] 

Voluntary Standard Rationale 

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

Series Cranes Standards 

Many consensus standards were relied upon for various 

provisions in the final rule, but there was no one consensus 

standard available that covered all of the topics covered by 

OSHA's final rule. 

 

 

Agency: Department of Transportation (DOT) 

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

Labels [Incorporated: 1998] 

Voluntary Standard Rationale 

ANSI Z535.4 - ANSI Requirements for Color Coded 

Header Messages for the Different Levels of Hazard

NHTSA explained in the NPRM that the American National 

Standard Institute (ANSI) has a standard4 for product safety 

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

hazard levels ranging from extremely serious to moderately 

serious and specifies corresponding hierarchies of signal words, 

i.e., “danger,” “warning,” and “caution,” and of colors. For the 

header, the ANSI standard specifies a red background with 

white text for “danger,” an orange background with black text for 

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

The ANSI standard specifies that pictograms should be black on 

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

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

the NPRM that when it earlier updated the requirements for air 

bag warning labels to require the addition of color and 

pictograms, it had chosen not to adopt the colors specified in the 

ANSI standard. NHTSA chose to use yellow instead of orange in 

the background of the heading for the air bag warning label, 

even though the word “warning” was used, because of 

overwhelming focus group preference for yellow. Only two of 

the 53 participants preferred orange. Participants generally 

stated that yellow was more eye-catching than orange. 

Participants also noted that red (stop) and yellow (caution) had 

meaning to them, but not orange. 

NHTSA asked for comment on three color options for the 

revised utility vehicle rollover warning label. Proposed label 1 

C-4
used the ANSI color format with the heading background in 

orange with the words in black. The remainder of the label had 

a white background with black text and drawings. Proposed 

label 2 used a color scheme like the air bag warning labels, 

which is the same as the ANSI color format except that the 

background color for the heading in the label is yellow. 

Proposed label 3 employed the color scheme used in the focus 

groups - the heading area had a red background with white text. 

The graphic areas had a yellow background with black and 

white drawings. The text area had a black background with 

yellow text. 

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

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

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

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

Recognizing that it might encounter additional conflicts between 

focus group preferences and the ANSI standard in future 

rulemakings, NHTSA requested comments in the NPRM on the 

extent to which any final choice regarding colors and signal 

words should be guided by the focus group preferences instead 

of the ANSI standard. NHTSA also requested comments on the 

broader issue of the circumstances in which it would be 

appropriate for agency rulemaking decisions to be guided by 

focus group results or other information when such information 

is contrary to a voluntary consensus standard such as the ANSI 

standard. 

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

regarding its proposal to upgrade the rollover warning label. As 

to the general questions it posed in the NPRM, NHTSA 

recognizes that ANSI’s mission differs somewhat from that of 

the agency’s focus groups with respect to the labeling of 

hazardous situations. ANSI’s mission is to develop and 

maintain a standard for communicating information about a 

comprehensive hierarchy of hazards, while the focus groups’ 

mission is to design an effective label for a specific hazard. The 

agency recognizes further that, given the difference in their 

missions, their conclusions about the appropriate manner of 

communication might differ on occasion. 

Since agency labeling decisions are highly dependent on the 

facts regarding the specific hazard being addressed, NHTSA 

anticipates making case-by-case determinations of the extent to 

which it should follow voluntary standards versus information 

from focus groups and other sources. NHTSA will rely on its own 

expertise and judgment in making determinations under the 

NTTAA and the statutory provisions regarding vehicle safety 

standards. 

 

 

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

Voluntary Standard Rationale 

ANSI ISO The Air Bag Warning Label uses yellow as the background 

color, instead of orange, in accordance with an ANSI standard 

and uses a graphic developed by Chrysler Corporation to depict 

the hazards of being too close to an air bag, instead of the 

graphic recommended by the ISO. These decisions were based 

on focus group testing sponsored by the agency which strongly 

indicated that these unique requirements would be far more 

C-5
effective with respect to safety than the industry standards. 

 

 

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

Brake Testers (PBBTs) Requirement [Incorporated: 2002] 

Voluntary Standard Rationale 

SAE J667 - Brake Test Code Inertia Dynamometer 

(cancelled February 2002) 

SAE J1854 - Brake Force Distribution Performance 

Guide - Trucks and Buses 

FMCSA used government-unique standards in lieu of voluntary 

consensus standards when it implemented its final rule to allow 

inspectors to use performance-based brake testers (PBBTs) to 

check the brakes on large trucks and buses for compliance with 

federal safety standards and to issue citations when these 

vehicles fail (67 FR 51770, August 9, 2002). The FMCSA 

evaluated several PBBTs during a round robin test series to 

assess their functional performance and potential use in law 

enforcement. The standard, a specific configuration of brake 

forces and wheel loads on a heavy-duty vehicle, was used to 

evaluate the candidate PBBTs and their operating protocols. 

The agency’s rationale for use of the government-unique 

standards was to verify that these measurements and new 

technology could be used by law enforcement as an alternative 

to stopping distance tests or on-road deceleration tests. PBBTs 

are expected to save time and their use could increase the 

number of commercial motor vehicles that can be inspected in a 

given time. Only PBBTs that meet specifications developed by 

the FMCSA can be used to determine compliance with the 

Federal Motor Carrier Safety Regulations. The final rule 

represents a culmination of agency research that began in the 

early 1990s. 

 

 

Agency: Environmental Protection Agency (EPA) 

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

Compression Ignition Engines [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

Engines, Exhaust Emission Measurement 

Procedures would be impractical because they rely too heavily 

on reference testing conditions. Agency decides instead to 

continue to rely on procedures outlined in 40 CFR Part 90. 

 

 

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

at or below 19KV [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

Engines, Exhaust Emission Measurement 

Procedures would be impractical because they rely too heavily 

on reference testing conditions. Agency decides instead to 

continue to rely on procedures outlined in 40 CFR Part 90. 

 

 

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

Engines [Incorporated: 2000] 

Voluntary Standard Rationale 

ISO 8178 - Reciprocating Internal Combustion 

Engines, Exhaust Emission Measurement 

Procedures would be impractical because they rely too heavily 

on reference testing conditions. Agency decides instead to 

continue to rely on procedures outlined in 40 CFR Part 90. 

 

 

C-6
Government Standard: EPA Method 1 – Traverse Points, Stationary Sources [Incorporated: 

1999] 

Voluntary Standard Rationale 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube Method) 

Is too general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

 

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

Voluntary Standard Rationale 

ASTM D3162 (1994) Standard Test Method for 

Carbon Monoxide in the Atmosphere (Continuous 

Measurement by Non-dispersive Infrared 

Spectrometry) 

This ASTM standard, which is stated to be applicable in the 

range of 0.5-100 ppm CO, does not cover the range of EPA 

Method 10 (20-1,000 ppm CO) at the upper end (but states that 

it has a lower limit of sensitivity). Also, ASTM D3162 does not 

provide a procedure to remove carbon dioxide interference. 

Therefore, this ASTM standard is not appropriate for combustion 

source conditions. In terms of non-dispersive infrared 

instrument performance specifications, ASTM D3162 has much 

higher maximum allowable rise and fall times (5 minutes) than 

EPA Method 10 (which has 30 seconds). 

 

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

Measurement of Carbon Monoxide: 3—Method of 

Analysis by Non-Dispersive Infrared Spectrometry 

1. This standard is lacking in the following areas: (1) Sampling 

procedures; (2) procedures to correct for the carbon dioxide 

concentration; (3) instructions to correct the gas volume if CO2 

traps are used; (4) specifications to certify the calibration gases 

are within 2 percent of the target concentration; (5) mandatory 

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

zero drift, span drift, precision); (6) quantitative specification of 

the span value maximum as compared to the measured value: 

The standard specifies that the instruments should be 

compatible with the concentration of gases to be measured, 

whereas EPA Method 10 specifies that the instrument span 

value should be no more than 1.5 times the source performance 

standard. 2. Is too general, too broad, or not sufficiently detailed 

to assure compliance with EPA regulatory requirements. 

 

 

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

(Air) [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 - Standard Practice for Opacity 

Monitor Manufacturers to Certify Conformance with 

Design and Performance Specifications. 

The EPA incorporates ASTM D6216 (manufacturers 

certification) by reference into EPA Performance Specification 1, 

Sect. 5 & 6 in another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1. 

 

 

C-7
Government Standard: EPA Method 101a - Mercury Emissions Sewer/Sludge 

Incinerator [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 - Standard Practice for Opacity 

Monitor Manufacturers to Certify Conformance with 

Design and Performance Specifications. 

The EPA incorporates ASTM D6216 (manufacturers 

certification) by reference into EPA Performance Specification 1, 

Sect. 5 & 6 in another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1. 

 

 

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

CEMS [Incorporated: 2001] 

Voluntary Standard Rationale 

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

Measurement of Carbon Monoxide: 3—Method of 

Analysis by Non-Dispersive Infrared Spectrometry. 

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

(2) procedures to correct for the carbon dioxide concentration; 

(3) instructions to correct the gas volume if CO2 traps are used; 

(4) specifications to certify the calibration gases are within 2 

percent of the target concentration; (5) mandatory instrument 

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

span drift, precision); (6) quantitative specification of the span 

value maximum as compared to the measured value: The 

standard specifies that the instruments should be compatible 

with the concentration of gases to be measured, whereas EPA 

Method 10 specifies that the instrument span value should be no 

more than 1.5 times the source performance standard. 2. Is too 

general, too broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements. 

 

 

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

2001] 

Voluntary Standard Rationale 

ASTM D4358-94 (1999), Standard Test Method for 

Lead and Chromium in Air Particulate Filter 

Samples of Lead Chromate Type Pigment Dusts by 

Atomic Absorption Spectroscopy 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12 . Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

 

ASTM E1741-95 (1995), Standard Practice for 

Preparation of Airborne Particulate Lead Samples 

Collected During Abatement and Construction 

Activities for Subsequent Analysis by Atomic 

Spectrometry 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12. Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

C-8
 

ASTM E1979-98 (1998), Standard Practice for 

Ultrasonic Extraction of Paint, Dust, Soil, and Air 

Samples for Subsequent Determination of Lead 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12. Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

 

 

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

Sulfide [Incorporated: 1999] 

Voluntary Standard Rationale 

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

and Exhaust Gas Analyses 

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

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

 

ASTM D4323-84 (1997) - Standard Test Method for 

Hydrogen Sulfide in the Atmosphere by Rate of 

Change of Reflectance 

ASTM D4323 only applies to concentrations of H2S from 1 ppb 

to 3 ppm without dilution. Many QC items are missing, such as 

calibration drift and sample line losses. The calibration curve is 

determined with only one point. 

 

 

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

1998] 

Voluntary Standard Rationale 

ISO, DIN, SCAN, and Standard Methods (SM 5320) EPA decided to use EPA Method 1650. This Method was 

developed by drawing on various procedures contained in the 

methods of voluntary consensus standards bodies and other 

standards developers, such as ISO, DIN, SCAN, and Standard 

Methods (SM 5320). However, none of these more narrowly 

focused voluntary consensus standards contained the 

standardized quality control and quality control compliance 

criteria that EPA requires for data verification and validation in 

its water programs. Therefore, EPA found none of these VCS 

standing alone to meet EPA’s needs. 

 

 

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

1999] 

Voluntary Standard Rationale 

ASME C00049 EPA looked at this standard for both Pulp and Paper Hazardous 

Air Pollutant rules and for the Small Municipal Waste 

Combustion rule. Contains sampling options beyond which 

would be considered acceptable for Method 5. 

 

ASTM D3685/3685M-95 - Standard Test method for 

Sampling and Determination of Particle Matter in 

Stack Gases 

EPA looked at this standard for both Pulp and Paper Hazardous 

Air Pollutant rules and for the Small Municipal Waste 

Combustion rule. Contains sampling options beyond which 

would be considered acceptable for Method 5. 

 

 

C-9
Government Standard: EPA Method 18 - VOC/GC [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D6060-96 (in review 2000) - Practice for 

Sampling of Process Vents with a Portable Gas 

Chromatography 

This standard lacks key quality control and assurance that is 

required for EPA Method 18. For example: lacks acceptance 

criteria for calibration, details on using other collection media 

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

requirements. 

 

 

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

Voluntary Standard Rationale 

ISO 7027 - Water Quality Determination of Turbidity EPA has no data upon which to evaluate whether the separate 

90 degrees scattered or transmitted light measurement 

evaluations according to the ISO 7027 method would produce 

results that are equivalent to results produced by the other 

methods. 

 

 

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

Voluntary Standard Rationale 

ASTM 3796-90 (1998), Standard Practice for 

Calibration of Type S Pitot Tubes 

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

assure compliance with EPA regulatory requirements. 

 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube Method) 

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

compliance with EPA regulatory requirements. 

 

ASTM D3464-96 (2001), Standard Test Method 

Average Velocity in a Duct Using a Thermal 

Anemometer 

Applicability specifications are not clearly defined, e.g., range of 

gas composition, temperature limits. Also, the lack of supporting 

quality assurance data for the calibration procedures and 

specifications, and certain variability issues that are not 

adequately addressed by the standard limit EPA's ability to 

make a definitive comparison of the method in these areas. 

 

ISO 10780:1994, Stationary Source Emissions-- 

Measurement of Velocity and Volume Flowrate of 

Gas Streams in Ducts 

The standard recommends the use of an L-shaped pitot, which 

historically has not been recommended by EPA. The EPA 

specifies the S-type design, which has large openings that are 

less likely to plug up with dust. 

 

 

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

Leaks [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM E1211-97 - Standard Practice for Leak 

Detection and Location Using Surface-Mounted 

Acoustic Emission Sensors 

This standard will detect leaks but not classify the leak as VOC, 

as in EPA Method 21. In addition, in order to detect the VOC 

concentration of a known VOC leak, the acoustic signal would 

need to be calibrated against a primary instrument. Background 

C-10
noise interference in some source situations could also make 

this standard difficult to use effectively. 

 

 

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

1999] 

Voluntary Standard Rationale 

European Committee for Standardization (CEN) EN 

1948-3 (1997), Determination of the Mass 

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

Identification and Quantification 

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

compliance with EPA regulatory requirements. 

 

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

Content [Incorporated: 1998] 

Voluntary Standard Rationale 

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

Determination of Volatile Organic Compound (VOC) 

Content-Difference Method 

Measured nonvolatile matter content can vary with experimental 

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

weighing dish, and size of sample. The standard ISO 11890-1 

allows for different dish weights and sample sizes than the one 

size (58 millimeters in diameter and sample size of 0.5 gram) of 

EPA Method 24. The standard ISO 11890-1 also allows for 

different oven temperatures and heating times depending on the 

type of coating, whereas EPA Method 24 requires 60 minutes 

heating at 110 degrees Celsius at all times. Because the EPA 

Method 24 test conditions and procedures define volatile matter, 

ISO 11890-1 is unacceptable as an alternative because of its 

different test conditions. 

 

ISO 11890-2 (2000) Part 2, Paints and Varnishes--

Determination of Volatile Organic Compound (VOC) 

Content-Gas Chromatographic Method 

ISO 11890-2 only measures the VOC added to the coating and 

would not measure any VOC generated from the curing of the 

coating. The EPA Method 24 does measure cure VOC, which 

can be significant in some cases, and, therefore, ISO 11890-2 is 

not an acceptable alternative to this EPA method. 

 

 

Government Standard: EPA Method 25 – Gaseous Nonmethane Organic 

Emissions [Incorporated: 2001] 

Voluntary Standard Rationale 

EN 12619:1999 Stationary Source Emissions--

Determination of the Mass Concentration of Total 

Gaseous Organic Carbon at Low Concentrations in 

Flue Gases--Continuous Flame Ionization Detector 

Method 

The standards do not apply to solvent process vapors in 

concentrations greater than 40 ppm (EN 12619) and 10 ppm 

carbon (ISO 14965). Methods whose upper limits are this low 

are too limited to be useful in measuring source emissions, 

which are expected to be much higher. 

 

ISO 14965:2000(E) Air Quality--Determination of 

Total Nonmethane Organic Compounds--Cryogenic 

Preconcentration and Direct Flame Ionization 

Method 

The standards do not apply to solvent process vapors in 

concentrations greater than 40 ppm (EN 12619) and 10 ppm 

carbon (ISO 14965). Methods whose upper limits are this low 

are too limited to be useful in measuring source emissions, 

which are expected to be much higher. 

 

 

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

Ionization [Incorporated: 2001] 

Voluntary Standard Rationale 

EN 12619:1999 Stationary Source Emissions--

Determination of the Mass Concentration of Total 

The standards do not apply to solvent process vapors in 

concentrations greater than 40 ppm (EN 12619) and 10 ppm 

C-11
Gaseous Organic Carbon at Low Concentrations in 

Flue Gases--Continuous Flame Ionization Detector 

Method 

carbon (ISO 14965). Methods whose upper limits are this low 

are too limited to be useful in measuring source emissions, 

which are expected to be much higher. 

 

ISO 14965:2000(E) Air Quality--Determination of 

Total Nonmethane Organic Compounds--Cryogenic 

Preconcentration and Direct Flame Ionization 

Method 

The standards do not apply to solvent process vapors in 

concentrations greater than 40 ppm (EN 12619) and 10 ppm 

carbon (ISO 14965). Methods whose upper limits are this low 

are too limited to be useful in measuring source emissions, 

which are expected to be much higher. 

 

 

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

Emissions [Incorporated: 1999] 

Voluntary Standard Rationale 

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

Emissions-- Manual Method of Determination of 

HCl--Part 1: Sampling of Gases Ratified European 

Text--Part 2: Gaseous Compounds Absorption 

Ratified European Text-- Part 3: Adsorption 

Solutions Analysis and Calculation 

Part 3 of this standard cannot be considered equivalent to EPA 

Method 26 or 26A because the sample absorbing solution 

(water) would be expected to capture both HCl and Cl2 gas, if 

present, without the ability to distinguish between the two. The 

EPA Methods 26 and 26A use an acidified absorbing solution to 

first separate HCl and Cl2 gas so that they can be selectively 

absorbed, analyzed, and reported separately. In addition, in EN 

1911 the absorption efficiency for Cl2 gas would be expected to 

vary as the pH of the water changed during sampling. 

 

 

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

Isokinetic [Incorporated: 1999] 

Voluntary Standard Rationale 

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

Emissions-- Manual Method of Determination of 

HCl--Part 1: Sampling of Gases Ratified European 

Text--Part 2: Gaseous Compounds Absorption 

Ratified European Text-- Part 3: Adsorption 

Solutions Analysis and Calculation 

Part 3 of this standard cannot be considered equivalent to EPA 

Method 26 or 26A because the sample absorbing solution 

(water) would be expected to capture both HCl and Cl2 gas, if 

present, without the ability to distinguish between the two. The 

EPA Methods 26 and 26A use an acidified absorbing solution to 

first separate HCl and Cl2 gas so that they can be selectively 

absorbed, analyzed, and reported separately. In addition, in EN 

1911 the absorption efficiency for Cl2 gas would be expected to 

vary as the pH of the water changed during sampling. 

 

 

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

Auditing [Incorporated: 2003] 

Voluntary Standard Rationale 

ASME Power Test Codes, Supplement on 

Instruments and Apparatus, part 5, Measurement of 

Quantity of Materials, Chapter 1, Weighing Scales 

It does not specify the number of initial calibration weights to be 

used nor a specific pretest weight procedure. 

 

ASTM E319-85 (Reapproved 1997), Standard 

Practice for the Evaluation of Single-Pan 

Mechanical Balances 

This standard is not a complete weighing procedure because it 

does not include a pretest procedure. 

 

 

Government Standard: EPA Method 29 – Metals Emissions from Stationary 

Sources [Incorporated: 2001] 

Voluntary Standard Rationale 

ASTM D4358-94 (1999), Standard Test Method for 

Lead and Chromium in Air Particulate Filter 

Samples of Lead Chromate Type Pigment Dusts by 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

C-12
Atomic Absorption Spectroscopy EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12. Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

 

ASTM E1741-95 (1995), Standard Practice for 

Preparation of Airborne Particulate Lead Samples 

Collected During Abatement and Construction 

Activities for Subsequent Analysis by Atomic 

Spectrometry 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12. Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

 

ASTM E1979-98 (1998), Standard Practice for 

Ultrasonic Extraction of Paint, Dust, Soil, and Air 

Samples for Subsequent Determination of Lead 

These ASTM standards do not require the use of glass fiber 

filters as in EPA Method 12 and require the use of significantly 

different digestion procedures that appear to be milder than the 

EPA Method 12 digestion procedure. For these reasons, these 

ASTM standards cannot be considered equivalent to EPA 

Method 12. Also, the subject ASTM standards do not require 

the use of hydrogen fluoride (HF) as in EPA Method 29 and, 

therefore, they cannot be used for the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas these three 

ASTM standards require cellulose filters and other probable 

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

EPA Method 29. 

 

CAN/CSA Z223.26-M1987, Measurement of Total 

Mercury in Air Cold Vapour Atomic Absorption 

Spectrophotometeric Method 

It lacks sufficient quality assurance and quality control 

requirements necessary for EPA compliance assurance 

requirements. 

 

 

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

Pitot [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

 

C-13
Government Standard: EPA Method 3 – Molecular Weight Carbon Dioxide, 

Oxygen [Incorporated: 1999] 

Voluntary Standard Rationale 

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

and Exhaust Gas Analyses" 

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

compliance with EPA regulatory requirements. 

 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

 

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

Anodizing [Incorporated: 2002] 

Voluntary Standard Rationale 

ASTM D4358-94 (1999) - Standard Test Method for 

Lead and Chromium in Air Particulate Filter 

Samples of Lead Chromate Type Pigment Dusts by 

Atomic Absorption Spectroscopy 

This MACT standard (Petroleum Refineries) only cites Method 

29. Therefore, the following EPA comment is only applicable for 

Method 29 not Method 12 and 306: Method 29 requires the use 

of hydrofluoric acid (HF) in its process of digestion of the 

sample. ASTM D4358-94 (1999) does not require the use of 

HF; therefore, it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas the subject 

ASTM standard requires cellulose filters and other probable 

non-glass fiber media, and this further negates their use as 

Method 29 equivalent methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979). 

 

 

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

Jar [Incorporated: 2002] 

Voluntary Standard Rationale 

ASTM D4358-94 (1999) - Standard Test Method for 

Lead and Chromium in Air Particulate Filter 

Samples of Lead Chromate Type Pigment Dusts by 

Atomic Absorption Spectroscopy 

This MACT standard (Petroleum Refineries) only cites Method 

29. Therefore, the following EPA comment is only applicable for 

Method 29 not Method 12 and 306: Method 29 requires the use 

of hydrofluoric acid (HF) in its process of digestion of the 

sample. ASTM D4358-94 (1999) does not require the use of 

HF; therefore, it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas the subject 

ASTM standard requires cellulose filters and other probable 

non-glass fiber media, and this further negates their use as 

Method 29 equivalent methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979). 

 

 

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

FTIR [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D6348-98, Determination of Gaseous 

Compounds by Extractive Direct Interface Fourier 

Suggested revisions to ASTM D6348-98 were sent to ASTM by 

the EPA that, would allow the EPA to accept ASTM D6348-98 

C-14
Transform (FTIR) Spectroscopy as an acceptable alternative. The ASTM Subcommittee D22-03 

is currently undertaking a revision of ASTM D6348- 98. 

Because of this, we are not citing this standard as an acceptable 

alternative for EPA Method 320 in the final rule today. 

However, upon successful ASTM balloting and demonstration of 

technical equivalency with the EPA FTIR methods, the revised 

ASTM standard could be incorporated by reference for EPA 

regulatory applicability. In the interim, facilities have the option 

to request ASTM D6348-98 as an alternative test method under 

40 CFR 63.7(f) and 63.8(f) on a case-by-case basis. 

 

 

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

IAP [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D5835-95, Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration 

1. They lack in detail and quality assurance/quality control 

requirements. Specifically, these two standards do not include 

the following: (1) Sensitivity of the method; (2) acceptable levels 

of analyzer calibration error; (3) acceptable levels of sampling 

system bias; (4) zero drift and calibration drift limits, time span, 

and required testing frequency; (5) a method to test the 

interference response of the analyzer; (6) procedures to 

determine the minimum sampling time per run and minimum 

measurement time; and (7) specifications for data recorders, in 

terms of resolution (all types) and recording intervals (digital and 

analog recorders, only). 2. Is too general, too broad, or not 

sufficiently detailed to assure compliance with EPA regulatory 

requirements. 

 

CAN/CSA Z223.2-M86(1986), Method for the 

Continuous Measurement of Oxygen, Carbon 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and 

Oxides of Nitrogen in Enclosed Combustion Flue 

Gas Stream 

1. It does not include quantitative specifications for 

measurement system performance, most notably the calibration 

procedures and instrument performance characteristics. The 

instrument performance characteristics that are provided are 

nonmandatory and also do not provide the same level of quality 

assurance as the EPA methods. For example, the zero and 

span/calibration drift is only checked weekly, whereas the EPA 

methods requires drift checks after each run. 2. Is too general, 

too broad, or not sufficiently detailed to assure compliance with 

EPA regulatory requirements. 

 

ISO 10396:1993, Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

1. They lack in detail and quality assurance/quality control 

requirements. Specifically, these two standards do not include 

the following: (1) Sensitivity of the method; (2) acceptable levels 

of analyzer calibration error; (3) acceptable levels of sampling 

system bias; (4) zero drift and calibration drift limits, time span, 

and required testing frequency; (5) a method to test the 

interference response of the analyzer; (6) procedures to 

determine the minimum sampling time per run and minimum 

measurement time; and (7) specifications for data recorders, in 

terms of resolution (all types) and recording intervals (digital and 

analog recorders, only). 2. Is too general, too broad, or not 

sufficiently detailed to assure compliance with EPA regulatory 

requirements. 

 

ISO 12039:2001, Stationary Source Emissions-- 

Determination of Carbon Monoxide, Carbon Dioxide, 

and Oxygen--Automated Methods 

This ISO standard is similar to EPA Method 3A, but is missing 

some key features. In terms of sampling, the hardware required 

by ISO 12039:2001 does not include a 3-way calibration valve 

assembly or equivalent to block the sample gas flow while 

calibration gases are introduced. In its calibration procedures, 

ISO 12039:2001 only specifies a two-point calibration while EPA 

Method 3A specifies a three-point calibration. Also, ISO 

C-15
12039:2001 does not specify performance criteria for calibration 

error, calibration drift, or sampling system bias tests as in the 

EPA method, although checks of these quality control features 

are required by the ISO standard. 

 

 

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

Emission Rate Correction Factor [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube Method) 

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

compliance with EPA regulatory requirements. 

 

 

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

Voluntary Standard Rationale 

ASTM D3154-00, Standard Method for Average 

Velocity in a Duct (Pitot Tube Method) 

1. The standard appears to lack in quality control and quality 

assurance requirements. It does not include the following: (1) 

Proof that openings of standard pitot tube have not plugged 

during the test; (2) if differential pressure gauges other than 

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

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

frequency and validity range for calibration of the temperature 

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

detailed to assure compliance with EPA regulatory 

requirements. 

 

ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube Method) 

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

compliance with EPA regulatory requirements. 

 

ASTM E337-84 (1996), Standard Test Method for 

Measuring Humidity with a Psychrometer (the 

Measurement of Wet- and Dry-Bulb Temperatures) 

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

assure compliance with EPA regulatory requirements. 

 

 

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

1999] 

Voluntary Standard Rationale 

ASME PTC-38-80 R85 or C00049, Determination of 

the Concentration of Particulate Matter in Gas 

Streams 

It lacks sufficient quality assurance and quality control 

requirements necessary for EPA compliance assurance 

requirements. 

 

ASTM D3685/D3685M-98, Test Methods for 

Sampling and Determination of Particulate Matter in 

Stack Gases 

It lacks sufficient quality assurance and quality control 

requirements necessary for EPA compliance assurance 

requirements. 

ISO 9096:1992, Determination of Concentration and 

Mass Flow Rate of Particulate Matter in Gas 

It lacks sufficient quality assurance and quality control 

requirements necessary for EPA compliance assurance 

C-16
Carrying Ducts-- Manual Gravimetric Method requirements. 

 

 

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

CC/ECD [Incorporated: 1998 and 2003] 

Voluntary Standard Rationale 

Standard Methods 6640B Standard Methods 6640B for acid herbicides was tentatively 

deemed impractical for EPA’s needs because its sample 

preparation and quality control procedures were not similar 

enough to EPA Method 515.1 to ensure that there would not be 

underreporting of acid herbicide contamination. EPA plans to 

offer to work with the Standard Methods committee to resolve 

this issue prior to the next publication. 

 

 

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

CG/ECD [Incorporated: 2003] 

Voluntary Standard Rationale 

ASTM D5317-98 -- Standard Test Method For 

Determination of Chlorinated Organic Acid 

Compounds in Water by Gas Chromatography With 

an Electron Capture Detector 

ASTM D5317-98 specifies acceptance windows for the initial 

demonstration of proficiency for laboratory fortified blank 

samples that are as small as 0 percent to as large as 223 

percent recovery for picloram, with tighter criteria for other 

regulated contaminants. Therefore, this method permits 

unacceptably large control limits, which include 0 percent 

recovery. 

 

Standard Method 6640 B for the chlorinated acids The use of this voluntary consensus standard would have been 

impractical due to significant shortcomings in the sample 

preparation and quality control sections of the method 

instructions. Section 1b of Method SM 6640 B states that the 

alkaline wash detailed in section 4b2 is optional. The hydrolysis 

that occurs during this step is essential to the analysis of the 

esters of many of the analytes. Therefore, this step is 

necessary and cannot be optional. In addition, the method 

specifies that the quality control limits for laboratory-fortified 

blanks are to be based upon plus or minus three times the 

standard deviation of the mean recovery of the analytes, as 

determined in each laboratory. Therefore, this method permits 

unacceptably large control limits, which may include 0 percent 

recovery. 

 

 

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

In/HPLC [Incorporated: 2003] 

Voluntary Standard Rationale 

Standard Method 6610, 20th Edition Standard Method 6610, 20th Edition has recently been 

approved for compliance monitoring. Standard Method 6610, 

20th Supplemental Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The preservatives in 

all of the other approved EPA and Standard Methods 

procedures for these analytes are weak acids that adjust the pH 

to a specific value based upon the pKa of the preservative. The 

use of HCL would require accurate determinations of the pH of 

the sample in the field and could be subject to considerable 

error and possible changes in pH upon storage. Although not 

specifically observed for oxamyl or carbofuran during the 

development of similar methods, structurally similar pesticides 

have been shown to degrade over time when kept at pH 3. 

C-17
Therefore, approval of this method is impractical because it 

specifies the use of a strong acid (HCL) when positive control of 

the pH is critical. 

 

Standard Method 6610, 20th Supplemental Edition Standard Method 6610, 20th Edition has recently been 

approved for compliance monitoring. Standard Method 6610, 

20th Supplemental Edition permits the use of a strong acid, 

hydrochloric acid (HCL), as a preservative. The preservatives in 

all of the other approved EPA and Standard Methods 

procedures for these analytes are weak acids that adjust the pH 

to a specific value based upon the pKa of the preservative. The 

use of HCL would require accurate determinations of the pH of 

the sample in the field and could be subject to considerable 

error and possible changes in pH upon storage. Although not 

specifically observed for oxamyl or carbofuran during the 

development of similar methods, structurally similar pesticides 

have been shown to degrade over time when kept at pH 3. 

Therefore, approval of this method is impractical because it 

specifies the use of a strong acid (HCL) when positive control of 

the pH is critical. 

 

 

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

Sources [Incorporated: 2001] 

Voluntary Standard Rationale 

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

method 5 and does not include some quality control procedures 

specified in the EPA method and which are appropriate to use in 

this rule. 

 

 

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

Voluntary Standard Rationale 

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

and Exhaust Gas Analyses 

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

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

 

ISO 11632:1998 - Stationary Source Emissions - 

Determination of the Mass Concentration of Sulfur 

Dioxide - Ion Chromatography 

 

ISO 7934:1998 - Stationary Source Emissions - 

Determination of the Mass Concentration of Sulfur 

Dioxide - Hydrogen Peroxide/Barium Perchlorate/ 

Thorin Method 

This standard is only applicable to sources with 30 mg/m3 SO2 

or more. In addition, this method does not separate SO3 from 

SO2 as does EPA Method 6; therefore, this method is not valid if 

more than a negligible amount of SO3 is present. Also, does 

not address ammonia interferences. 

 

 

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

IAP [Incorporated: 1999] 

Voluntary Standard Rationale 

ASTM D5835-95 - Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022, the 

standard lacks in detail and quality assurance and quality control 

requirements; very similar to ISO 10396. 

 

CAN/CSA Z223.2-M86 - (1986) Method for the 

Continuous Measurement of Oxygen, Carbon 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and 

Oxides of Nitrogen in Enclosed Combustion Flue 

It is too general. This standard lacks in detail and quality 

assurance/quality control requirements. Appendices with valid 

quality control information are not a required part of this method.

C-18
Gas Streams 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

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

lacks in detail and quality assurance plus quality control 

requirements. Similar to ASTM D5835. 

 

 

Government Standard: EPA Method 7 - Nitrogen Oxide Emissions Stationary 

Sources [Incorporated: 1999] 

Voluntary Standard Rationale 

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

and Exhaust Gas Analyses 

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

3, 6, 7, and 15 with variants. 

 

 

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

Voluntary Standard Rationale 

ASTM D5835-95 - Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022, It lacks in 

detail and quality assurance and quality control requirements; 

very similar to ISO 10396. 

 

CAN/CSA Z223.2-M86 - (1986) Method for the 

Continuous Measurement of Oxygen, Carbon 

Dioxide, Carbon Monoxide, Sulphur Dioxide, and 

Oxides of Nitrogen in Enclosed Combustion Flue 

Gas Streams 

It is too general. This standard lacks in detail and quality 

assurance/quality control requirements. Appendices with valid 

quality control information are not a required part of this method.

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

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

lacks in detail and quality assurance plus quality control 

requirements; similar to ASTM D5835. 

 

 

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

Voluntary Standard Rationale 

ASTM D5835-95 - Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022, it lacks in 

detail and quality assurance and quality control requirements; 

very similar to ISO 10396. 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

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

lacks in detail and quality assurance plus quality control 

requirements; similar to ASTM D5835. 

 

 

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

Voluntary Standard Rationale 

ASTM D5835-95 - Standard Practice for Sampling 

Stationary Source Emissions for Automated 

Determination of Gas Concentration 

Similar to Methods 3a, 6c, 7e, 10, ALT 004, CTM 022, it lacks in 

detail and quality assurance and quality control requirements; 

very similar to ISO 10396. 

 

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the Automated Determination of Gas 

Concentrations 

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

lacks in detail and quality assurance plus quality control 

requirements; similar to ASTM D5835. 

 

 

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

Voluntary Standard Rationale 

ASTM D3031-81 – Method of Test for Total Sulfur in This method has been deleted from the final rule because it was 

C-19
Natural Gas (Hyrogenation), Withdrawn discontinued by the ASTM in 1990 with no replacement. If the 

total sulfur content of the fuel being fired in the turbine is less 

than 0.4 weight percent, we are adding a provision that the 

following methods may be used to measure the sulfur content of 

the fuel: ASTM D4084-82 or 94, D5504-01, D6228-98, or the 

Gas Processors Association Method 2377-86. This provision is 

consistent with the provision in 40 CFR 60.13(j)(1) allowing 

alternatives to reference method tests to determine relative 

accuracy of CEMS for sources with emission rates 

demonstrated to be less than 50 percent of the applicable 

standard. 

 

 

Government Standard: EPA Performance Specification 1 [Incorporated 2001] 

Voluntary Standard Rationale 

ASTM D6216-98 –Standard Procedure for Opacity 

Monitor Manufacturers to Certify Conformance with 

Design and Performance Specifications 

EPA incorporates ASTM D6216 (manufacturers certification) by 

reference into EPA Performance Specification 1, Sections 5 and 

6 in another rulemaking. ASTM D6216 does not address all the 

requirements specified in PS-1. 

 

 

Government Standard: EPA Performance Specification 2 (sulfur dioxide portion 

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

Voluntary Standard Rationale 

ISO 7935:1992, Stationary Source Emissions--

Determination of the Mass Concentration of Sulfur 

Dioxide--Performance Characteristics of Automated 

Measuring Methods" 

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

compliance with EPA regulatory requirements. 

Voluntary Standard Rationale 

ISO 10849:1996, Determination of the Mass 

Concentration of Nitrogen Oxides--Performance 

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

compliance with EPA regulatory requirements. 

 

 

Government Standard: EPA Performance Specifications 11 - Particulate Matter Continuous 

Monitoring System [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of 

particles - Performance characteristics, test 

methods and specifications. 

This international standard is only applicable on a site specific 

basis by direct correlation with the manual method ISO 9096 

(which does not produce particulate matter measurements like 

EPA Method 5). This appears to be a PM CEMS performance 

specification similar to EPA Performance Specification 11, but 

does not contain detailed RATA procedures. Also, EPA doesn’t 

have a final performance specification to compare this to. 

 

 

Government Standard: GLI Method 2 [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 7027 - Water Quality Determination of Turbidity EPA has no data upon which to evaluate whether the separate 

90 degrees scattered or transmitted light measurement 

evaluations according to the ISO 7027 method would produce 

results that are equivalent to results produced by the other 

methods. 

 

 

C-20
Government Standard: Standard Method 2130B [Incorporated: 1999] 

Voluntary Standard Rationale 

ISO 7027 - Water Quality Determination of Turbidity EPA has no data upon which to evaluate whether the separate 

90 degrees scattered or transmitted light measurement 

evaluations according to the ISO 7027 method would produce 

results that are equivalent to results produced by the other 

methods. 

 

 

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

Voluntary Standard Rationale 

ASTM C1111-98 (1998) - Standard Test Method for 

Determining Elements in Waste Streams by 

Inductively Coupled Plasma-Atomic Emission 

Spectrometers 

This standard lacks details for instrument operation QA/QC, 

such as optimizing plasma operating conditions; upper limit of 

linear dynamic range; spectral interference correction; and 

calibration procedures, which include initial and continuous 

calibration verifications. Also lacks internal standard and 

method of standard addition options for samples with 

interferences. 

 

ASTM D6349-99 (1999) - Standard Test Method for 

Determining Major and Minor Elements in Coal, 

Coke, and Solid Residues from Combustion of Coal 

and Coke by Inductively Coupled Plasma-Atomic 

Emission Spectrometers 

This standard lacks details for instrument operation QA/QC, 

such as optimizing plasma operating conditions, upper limit of 

linear dynamic range, spectral interference correction, and 

calibration procedures, that include initial and continuous 

calibration verifications. Also lacks details for standard 

preparation, and internal standard and method of standard 

addition options for samples with interferences. 

 

 

Agency: Government Printing Office (GPO) 

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

Voluntary Standard Rationale 

ISO 14644-1 & ISO 14644-2 It is not feasible due to quality assurance standards. Second 

ISO standard not issued until end of FY 2000 and being phased 

out. 

 

 

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

Voluntary Standard Rationale 

ANSI/ASQC Z1.4 It is not feasible due to quality assurance standards. It is cited 

in small number of contracts due to editing errors and being 

corrected and phased out. 

 

 

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

Voluntary Standard Rationale 

ANSI/AIM X5-2 & ANSI X3.182 It is not feasible due to quality assurance standards. It is cited 

in small number of contracts due to editing errors and being 

corrected and phased out. 

 

 

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

Voluntary Standard Rationale 

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

12207.2 

It is not feasible due to quality assurance standards. It is cited 

in small number of contracts due to editing errors and being 

corrected and phased out. 

C-21
 

 

Agency: General Services Administration (GSA) 

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

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

2000] [Discontinued: 2001] 

Voluntary Standard Rationale 

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

 National security information. 

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

Ambulances [Incorporated: 2000] 

Voluntary Standard Rationale 

ASTM F2020 - Standard Practice for Design, 

Construction, and Procurement of Emergency 

Medical Services Ambulances 

The ASTM Standard Practice for Design, Construction, and 

Procurement of Emergency Medical Services (EMSS) 

Ambulances (ASTM F2020) is not practical for use, and 

therefore GSA uses the Federal Specification for Ambulances 

(KKK-A-1822E). GSA has determined the ASTM document is 

not practical for use for the following reasons: 

1) GSA has determined that ASTM F2020 contains specific 

practices that are technically and economically impractical to 

use for the acquisition of commercial based vehicles because 

the document is financially burdensome and technically 

ineffective. Specifically at issue is the ASTM Standard 

Specification for Medical Oxygen Delivery Systems for EMS 

Ground Vehicles, F1949-99 which is inclusive to ASTM F2020. 

2) GSA has determined that ASTM F2020 is impractical 

because it is defined as a standard practice which is ambiguous 

and an ineffective substitution for specifications or requirements 

for use in GSA contract documents. ASTM F1949-99, a 

Standard Specification for Medical Oxygen Delivery Systems for 

EMS Ground Vehicles is included in ASTM F2020. ASTM 

F1949-99 is defined as a “standard specification”. 

3) GSA has determined that ASTM F2020 is impractical 

because ASTM International does not provide interpretations 

and written guidance to their publications which is inadequate 

and less useful. ASTM members may only offer personal 

opinions. ASTM offers no mechanism to support timely 

resolution of conflicts between contractor and procurement 

organizations on technical subject matter. GSA provides 

interpretations, clarifications and engineering determinations 

when required. This is one of the most important concerns 

presented by the Ambulance Manufacturers Division (AMD). 

4) The AMD has determined through consensus that it is 

impractical to replace the Federal Specification for Ambulances, 

KKK-A-1822E with the ASTM Standard Practice, F2020. GSA 

initiated a survey to collect public responses from a wide range 

of constituent users of the Federal Ambulance Specification. 

The National Association of Emergency Medical Technicians 

(NAEMT), the International Association of Fire Chiefs (IAFC), 

the National Association of State EMS Directors (NASEMSD) 

C-22
and the National Association of EMS Physicians universally 

accept and support the continued use of the Federal 

Specification. The AMD and constituent users have determined 

that it is impractical to replace the Federal Specification for 

Ambulances, KKK-A-1822E with the ASTM Standard Practice, 

F2020 because rule promulgation is burdensome and costly. 

Staff and administration resources would need to be diverted in 

each state EMS office to implement the change in statutes, 

public health codes, rules and regulations. 

5) GSA has determined that ASTM F2020 is impractical 

because it is burdensome to GSA procurement efforts. While the 

current ASTM document recites many of the requirements from 

the Federal Specification, a future ASTM document would likely 

have diverging requirements unacceptable to the Government. 

This was verified by a member of the ASTM F2020 

subcommittee at the September 4, 2003 meeting of the Federal 

Interagency Committee on Emergency Medical Services. 

 

 

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

2003] 

Voluntary Standard Rationale 

SAE/AMS 2431 - Peening Media, General 

Requirements 

This government-unique standard contains specific size & 

performance required for Air Force critical applications that are 

not present in the voluntary standards. 

_________________________________________________________________________________ 

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

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

Voluntary Standard Rationale 

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

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

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

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

applicable test method standard ASTM E488. 

 

Agency: Department of Health and Human Services (HHS) 

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

Voluntary Standard Rationale 

ISO 13408-1 Asceptic Processing of Health Care 

Products, Part 1, General Requirements 

FDA is not using the ISO standard because the applicability of 

these requirements is limited to only portions of aseptically 

manufactured biologics and does not include filtration, freezedrying, sterilization in place, cleaning in place, or barrier-isolator 

technology. There are also significant issues related to 

aseptically produced bulk drug substance that are not included 

in the document. 

_________________________________________________________________________ 

C-23
Government Standard: National Standard Format [Incorporated: 1997] [Discontinued: 2004] 

Voluntary Standard Rationale 

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

industry and has become a defacto national standard. However, 

the Centers for Medicare and Medicaid Services (CMS) directed 

their contractors to discontinue use of the NSF standard and 

replace it with ANSI X12 837 by the beginning of FY 2003. 

 

 

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

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

Voluntary Standard Rationale 

ASTM Standard E1115 - Test Method for Evaluation 

of Surgical Hand Scrub Formulations 

Sensitivity and bias of the ASTM Standard has not been 

established. 

 

ASTM Standard E1173-93 - Standard Test Method 

of an Evaluation of Preoperative, Precatheterization, or Pre-injection Skin Preparations 

Sensitivity and bias of the ASTM Standard has not been 

established. 

 

ASTM Standard E1174-00 - Standard Test method 

for the Evaluation of the Effectiveness of Health 

Care Personnel or Consumer Handwash 

Formulations 

Sensitivity and bias of the ASTM Standard has not been 

established. 

 

 

Agency: Department of Housing and Urban Development (HUD) 

Government Standard: 24 CFR 200.935 - Administrator qualifications and procedures for HUD 

building products and certification programs [Incorporated: 2000] 

Voluntary Standard Rationale 

ANSI A119.1 N - Recreation Vehicles HUD Building-Product Standards & Certification Programs. 

HUD was required by legislation to “establish Federal 

construction and safety standards for manufactured homes and 

to authorize manufactured home safety research and 

development”. Recently, HUD retained a private consensus 

body (NFPA) to update and modernize the Manufactured Home 

Standards. At the conclusion of the development process, 

NFPA will submit the revised standard to HUD for regulatory 

adoption. 

 

 

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

Standards [Incorporated: 2000] 

Voluntary Standard Rationale 

ANSI A119.1 - Recreation Vehicles and NFPA 501C 

- Standard on Recreational Vehicles 

HUD-Unique Manufactured Home Construction & Safety 

Standards. HUD was required by legislation to “establish 

Federal construction and safety standards for manufactured 

homes and to authorize manufactured home safety research 

and development”. Recently, HUD retained a private consensus 

body (NFPA) to update and modernize the Manufactured Home 

Standards. At the conclusion of the development process, NFPA 

will submit the revised standard to HUD for regulatory adoption. 

 

 

C-24
Agency: National Archives and Records Administration (NARA) 

Government Standard: NARA data standard [Incorporated: 2000] 

Voluntary Standard Rationale 

Archives, Personal Papers, and Manuscripts 

(APPM); 

General International Standard Archival Description 

(ISAD(G)); 

International Standard Archival Authority Record for 

Corporate Bodies, Persons, and Families 

(ISAAR(CPF)); 

Encoded Archival Description (EAD); 

Machine Readable Cataloging (MARC) 

These voluntary standards do not meet the precise needs of the 

agency. 

C-25