Sixth Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment 

Michael B. Moore

Kevin L. McIntyre

 Standards Coordination and Conformity Group

Standards Services Division

Technology Services Laboratory

NISTIR 7701
NISTIR 7701

Sixth Annual Report on Federal 

Agency Use of Voluntary Consensus 

Standards and Conformity Assessment 

Michael B. Moore

Kevin L. McIntyre

 Standards Coordination and Conformity Group

Standards Services Division

Technology Services Laboratory

August

ii

2003

U.S. DEPARTMENT OF COMMERCE

Donald L. Evans, Secretary

TECHNOLOGY ADMINISTRATION

Phillip J. Bond, Under Secretary of Commerce for Technology

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY

Arden L. Bement, Jr., Director
1

TABLE OF CONTENTS 

I. EXECUTIVE SUMMARY .................................................................................................. 4

1.1 The Interagency Committee on Standards Policy ......................................................... 4 

1.2 Federal Agency Use of Standards.................................................................................... 4 

1.3 Participation of Federal Agency Employees in the Voluntary Standards 

Development Process.................................................................................................................... 2 

1.4 Federal Agency Conformity Assessment Activity.......................................................... 3

II. NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT OF 1995 

AND THE OFFICE OF MANAGEMENT AND BUDGET CIRCULAR A-119 ................... 3

2.1 The National Technology Transfer and Advancement Act of 1995............................. 3 

2.1.1 NIST Responsibilities Under the NTTAA .......................................................... 4 

2.1.2 Federal Agency Responsibilities Under the NTTAA......................................... 4 

2.2 The Office of Management and Budget Circular A-119 (“the Circular”) .................. 5 

2.2.1 The Circular .......................................................................................................... 5 

2.2.2 Federal Agency Responsibilities Under the Circular ........................................ 6

III. THE INTERAGENCY COMMITTEE ON STANDARDS POLICY (ICSP)............. 8

3.1 Fiscal Year 2002 Activities............................................................................................... 8 

3.1.1 Ad Hoc Working Groups ..................................................................................... 8 

3.1.1.1 Regulatory Agencies Working Group Report.................................................. 9 

3.1.1.2 Working Group on Directory Databases Report........................................... 10 

3.2 Committee Policy Recommendations on Continuing Implementation of the NTTAA 

and Circular A-119 ..................................................................................................................... 10 

3.2.1 Meaning of the term “use.”................................................................................ 10 

3.3 Membership..................................................................................................................... 12 

3.3.1 Agency Standards Executives and Representatives......................................... 12 

3.3.2 Changes in Membership and Vacancies........................................................... 16

IV. FEDERAL AGENCY USE OF STANDARDS ............................................................ 17

4.1 General Discussion.......................................................................................................... 17 

4.2 Cumulative Use of Voluntary Consensus Standards by Agency................................ 18 

4.3 Cumulative Use of Government-Unique Standards by Agency ................................. 20

V. PARTICIPATION OF FEDERAL AGENCY EMPLOYEES IN THE VOLUNTARY 

STANDARDS DEVELOPMENT PROCESS .......................................................................... 22
2

5.1 Census of Federal Employees Participating in Voluntary Consensus Standards 

Development Activities............................................................................................................... 22 

5.2 Census of Voluntary Consensus Activities in Which Federal Employees 

Participated ................................................................................................................................. 23 

5.3 Changes in Employee Participation .............................................................................. 25 

5.4 Inventory of Standards Development Organizations.................................................. 26

VI. FEDERAL AGENCY CONFORMITY ASSESSMENT ACTIVITY ....................... 32

6.1 Background ..................................................................................................................... 32 

6.2 Continuing Activity......................................................................................................... 32 

6.2.1 Department of Commerce.................................................................................. 32 

6.2.2 Department of Energy ........................................................................................ 34 

6.2.4 Department of Housing and Urban Development ........................................... 38 

6.2.5 Department of Justice......................................................................................... 38 

6.2.6 Department of Transportation .......................................................................... 38 

6.2.7 Department of the Treasury .............................................................................. 38 

6.2.8 Agency for International Development............................................................. 38 

6.2.9 General Services Administration....................................................................... 39 

6.2.10 National Aeronautics and Space Administration (NASA).............................. 40 

6.3 New Activity .................................................................................................................... 40 

6.3.1 Department of Commerce.................................................................................. 41 

6.3.2 Department of Health and Human Services..................................................... 41 

6.3.3 Department of Transportation .......................................................................... 42 

6.3.4 General Services Administration....................................................................... 43

APPENDIX A--REPORTS OF CABINET-LEVEL DEPARTMENTS ................................ 46

Department of Agriculture......................................................................................................... 47 

Department of Commerce.......................................................................................................... 52 

Department of Defense ............................................................................................................... 63 

Department of Education........................................................................................................... 69 

Department of Energy ................................................................................................................ 71 

Department of Health and Human Services............................................................................. 78 

Department of Housing and Urban Development ................................................................... 91 

Department of the Interior......................................................................................................... 98 

Department of Justice............................................................................................................... 102 

Department of Labor................................................................................................................ 104 

Department of State.................................................................................................................. 107 

Department of Transportation ................................................................................................ 108 

Department of the Treasury .................................................................................................... 118 

Department of Veterans Affairs.............................................................................................. 122

APPENDIX B -- REPORTS OF INDEPENDENT AGENCIES AND COMMISSIONS .. 125
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Agency for International Development................................................................................... 126 

Consumer Products Safety Commission................................................................................. 128 

Environmental Protection Agency .......................................................................................... 130 

Federal Communications Commission ................................................................................... 156 

Federal Emergency Management Agency.............................................................................. 158 

Federal Trade Commission...................................................................................................... 159 

General Services Administration............................................................................................. 161 

International Trade Commission ............................................................................................ 169 

National Aeronautics and Space Administration .................................................................. 170 

National Archives and Records Administration.................................................................... 175 

National Communications Systems......................................................................................... 179 

National Science Foundation ................................................................................................... 182 

Nuclear Regulatory Commission............................................................................................. 183 

U.S. Government Printing Office ............................................................................................ 187 

U.S. Postal Service..................................................................................................................... 188

APPENDIX C -- LIST OF AGENCIES.................................................................................. 189

APPENDIX D – TABLES AND CHARTS............................................................................. 191

Table 1 – FY 2002 Statistics on Federal Agency Participation in Development and 

Adoption of Voluntary Consensus Standards........................................................................ 191 

Table 2 –Federal Agency Information Provided in Agency Reports................................... 192

Chart 1 – Number of Voluntary Consensus Standards Used ............................................... 193 

Chart 2 – Number of Voluntary Consensus Standards Activities with Employee 

Participation.............................................................................................................................. 194 

Chart 3 – Number of Voluntary Consensus Standards Substituted for Government-Unique 

Standards................................................................................................................................... 195 

Chart 4 – Number of Government-Unique Standards Used in Lieu of Voluntary Consensus 

Standards................................................................................................................................... 196
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Sixth Annual Report 

on Federal Agency Use of Voluntary Consensus Standards 

and Conformity Assessment 

I. EXECUTIVE SUMMARY

1.1 The Interagency Committee on Standards Policy 

The Interagency Committee on Standards Policy (ICSP) currently has 45 members, including 

agency Standards Executives, their alternates, and the National Institute of Standards and 

Technology (NIST) chair and secretariat. Several members of the NIST technical staff serve the 

secretariat in non-member committee support positions. Six agencies have vacant Standards 

Executive positions. 

Two additional agencies could be invited to the ICSP table: the new Department of Homeland 

Security, a cabinet-level department; and the Access Board, formerly the Architectural and 

Transportation Barrier Compliance Board, an independent federal Board created by Congress in 

1973. Both agencies will probably need to use government-unique and national consensus 

standards in their various programs, hence coordination with the membership of the ICSP will be 

essential. 

The committee meets at the call of the chair. The committee met four times in FY2002 at 

various locations in the Washington Metropolitan Area. It is anticipated that the committee will 

continue to meet, at a minimum, on a quarterly basis. 

1.2 Federal Agency Use of Standards 

The reports of federal agencies indicate that their use of voluntary consensus standards continued 

to increase, although at a reduced rate, in FY 2002. The efforts of the agencies to use voluntary 

consensus standards and to comply with the National Technology Transfer and Advancement 

Act (NTTAA) remain strong. 

The reduced rate of increase in the use of voluntary consensus standards reflects the effect of the 

continuing use of voluntary consensus standards to replace the declining number of governmentunique standards in the federal inventory. The declining inventory of government-unique 

standards has been created by past agency efforts to comply with the NTTAA. Obviously, as 

agencies replace government-unique standards with voluntary consensus standards, the inventory 

of government-unique standards used by federal agencies will decrease. It is expected that the 

rate of replacement of government-unique standards will continue to decline over future years 

until the number of those standards in the federal inventory reaches the level necessary for 

federal use. 
2

According to the figures reported by all of the agencies, the overall federal government use of 

government-unique standards in lieu of voluntary consensus standards increased while the 

number of voluntary consensus standards (VCSs) substituted for government-unique standards 

(GUSs) decreased slightly during the past year. At the same time, the number of voluntary 

consensus standards used by the federal government during FY 2002 decreased in comparison to 

FY 2001. This apparent decline in the number of voluntary consensus standards used by the 

agencies continues to reflect the fact that agencies use different methods to count how they use 

standards, often changing that method year to year based upon agency interpretation of the 

reporting requirements. The ICSP will continue to work to improve the consistency in reporting 

standards usage. The ongoing development of a cumulative inventory of all standards used by 

the federal government may help to alleviate this continuing issue. 

Overall Use of Standards Reported by Federal Agencies 

Year GUSs in lieu of VCSs VCSs substituted for GUSs VCSs Used 

2002 65 91 2,959 

2001 54 106 3,749 

Difference +11 -15 -790 

Source: Agency reports 

1.3 Participation of Federal Agency Employees in the Voluntary Standards 

Development Process 

Agencies further reported that the number of employees participating in the activities of 

voluntary consensus bodies increased in FY 2002, but the number of activities in which 

employees actually participated has decreased. The decrease in voluntary consensus standards 

body participation may be attributable to decreases in agency fiscal resources. In times of fiscal 

restraint, expenditures for employee travel and per diem normally decrease. Further, employee 

participation in activities that are not related directly to the ongoing standards activities also 

declines in order to conserve available agency resources. Vacancies on some standards 

development committees are often not filled when employees retire or transfer to other positions. 

As in the past, many agencies report the number of voluntary consensus “activities” in which 

their employees participate, rather than the number of voluntary consensus “bodies.” For future 

reporting, NIST seeks to clarify the meaning of “activities” versus “bodies.” Voluntary 

consensus “activities” include all committee, task group, work group, subcommittee, periodic 

meetings, or conferences that a voluntary consensus “body” conducts. A voluntary consensus 

“body,” for the purposes of this report, includes standards development organizations such as the 

American Society of Mechanical Engineers, the National Fire Protection Association, the 

Institute of Electrical and Electronics Engineers, or ASTM International. Next year’s reporting 

guidelines will specify whether agencies are to report “activities” or “bodies.” 
3

Employee Participation in Voluntary Consensus Standards Activities 

Year 

Employees Participating in VCS 

Activities 

VCS Activities in Which 

Employees Participate 

2002 3,229 1,157 

2001 2,838 847 

Difference +391 +310 

Source: Agency reports 

1.4 Federal Agency Conformity Assessment Activity

The agencies reported continued participation in conformity assessment activities. Four agencies 

reported new activities for FY 2002 in which they increased their participation in activities 

related to improving compliance with established voluntary consensus standards. Participation 

on various committees allowed representatives of the agencies to work with other federal 

agencies and non-governmental organizations in the development of conformity assessment 

policies and guidelines. 

II. NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT OF 1995 

AND THE OFFICE OF MANAGEMENT AND BUDGET CIRCULAR A-119 

2.1 The National Technology Transfer and Advancement Act of 1995 

President William J. Clinton signed Public Law 104-113, also known as the National 

Technology Transfer and Advancement Act of 1995 (NTTAA), on March 7, 1996. One purpose 

of the NTTAA is to ensure that government agencies achieve greater reliance on voluntary 

consensus standards developed by the private sector and decreased dependence on governmentunique standards developed by and for the government. Previously, when a government agency 

identified the need for a standard, it would often create and adopt a government-unique standard 

rather than use an existing, applicable voluntary consensus standard to address the need. The 

result was often unnecessary allocation of government resources to the development of 

government-unique standards when similar, private sector standards, developed through a 

consensus process, already existed. The development and implementation of similar standards in 

the private sector and among different government agencies creates confusion as to which 

standard is applicable. It also creates additional burdens for those who, while complying with a 

private sector consensus standard, also have to comply with a differing government standard. 

The NTTAA now requires that federal agencies use private sector, voluntary consensus 

standards whenever possible in lieu of creating government-unique standards. 

The NTTAA designates NIST as the primary federal agency responsible for providing 

encouragement and support to government agencies in their efforts to comply with the NTTAA. 

The NTTAA requires NIST to “coordinate federal, state, and local technical standards activities 

and conformity assessment activities, with private sector technical standards activities and 

conformity assessment activities, with the goal of eliminating unnecessary duplication and 
4

complexity in the development and promulgation of conformity assessment requirements and 

measures.” NIST is also directed to help federal agencies compare private-sector standards used 

in commerce with government-unique standards developed by the federal government. Through 

this activity, government agencies can identify and possibly eliminate government-unique 

standards that duplicate private sector standards. 

2.1.1 NIST Responsibilities Under the NTTAA

In summary, the NTTAA directs NIST to: 

► Coordinate with other federal agencies, as well as state and local governments, to 

achieve greater reliance on voluntary standards and lessened dependence on in-house 

standards. 

► Assist federal agencies in comparing standards used in manufacturing, commerce, 

industry, and educational institutions with the standards developed by the federal 

government. 

► Coordinate greater use by federal agencies and state and local governments of private 

sector standards. 

► Emphasize where possible the use of standards developed by private consensus 

organizations. 

2.1.2 Federal Agency Responsibilities Under the NTTAA 

In general, except as provided below, all federal agencies and departments should use technical 

standards that are developed or adopted by voluntary consensus standards bodies, using such 

technical standards as a means to carry out policy objectives or activities determined by the 

agencies and departments. 

In carrying out their responsibilities under the NTTAA, federal agencies, and departments, “. . . 

shall consult with voluntary, private sector, consensus standards bodies and shall, when such 

participation is in the public interest and is compatible with agency and departmental missions, 

authorities, priorities, and budget resources, participate with such bodies in the development of 

technical standards.” 

If the use of technical standards developed or adopted by voluntary consensus standards bodies is 

inconsistent with applicable law or otherwise impractical, a federal agency or department may 

elect to use technical standards that are not developed or adopted by voluntary consensus 

standards bodies, but the head of each such agency or department is to transmit to the Office of 

Management and Budget an explanation of the reasons for using such standards. Beginning with 

FY 1997, the NTTAA requires that the Office of Management and Budget transmit an annual 

report to Congress and its committees summarizing all explanations for the use of technical 

standards received in the preceding year. 
5

2.2 The Office of Management and Budget Circular A-119 (“the Circular”) 

2.2.1 The Circular

In 1982, the Office of Management and Budget issued Circular A-119 to establish policies for 

various federal agencies for improving the internal management of the Executive Branch in 

regulatory and procurement activities. The Circular has been revised several times, most 

recently in 1998, and is now consistent with Section 12(d) of the NTTAA. It directs federal 

agencies to use voluntary consensus standards in lieu of government-unique standards except 

where such use would be inconsistent with law or otherwise impractical. The Circular also 

provides guidance for agencies participating in voluntary consensus standards bodies and 

describes procedures for satisfying the reporting requirements in the NTTAA. The Circular’s 

policies are intended to minimize the reliance of federal agencies on government-unique 

standards. The Circular’s policies do not create the basis for discrimination in agency 

procurement or regulatory activities among standards developed in the private sector, whether or 

not they are developed by voluntary consensus standards bodies. 

In addition, the Circular, consistent with Section 12(b) of the NTTAA, directs the Secretary of 

Commerce to issue guidance to the agencies in order to coordinate conformity assessment 

activities. NIST published this guidance in the Federal Register on August 10, 2000 (65 FR 

48894-48902). 

The Circular notes that standards developed by voluntary consensus standards bodies are often 

appropriate for use in achieving federal policy objectives and in conducting federal activities, 

including procurement and regulation. 

The policies of OMB Circular A-119 are intended to: 

► Encourage federal agencies to benefit from the expertise of the private sector; 

► Promote federal agency participation in such bodies to ensure creation of standards 

that are useable by federal agencies; and 

► Reduce reliance on government-unique standards where an existing voluntary 

standard would suffice. 

The 1998 revision (February 19, 1998 [63 FR 8545]) states that the policy of the federal 

government for agency procurement and regulatory activities is to: 

► Rely on voluntary standards, both domestic and international, whenever feasible and 

consistent with law and regulation; 
6

► Participate in voluntary standards bodies when such participation is in the public 

interest and is compatible with agencies’ missions, authorities, priorities, and budget 

resources; and 

► Coordinate agency participation in voluntary standards bodies so that, “. . . the most 

effective use is made of agency resources . . .” and that the views expressed by such 

representatives are in the public interest and “. . . do not conflict with the interests and 

established views of the agencies.” 

2.2.2 Federal Agency Responsibilities Under the Circular 

The detailed requirements for federal agencies under the NTTAA are set forth in the Circular. 

Under the Circular, the Secretary of Commerce must: 

► Coordinate and foster executive branch implementation of the Circular and, as 

appropriate, provide administrative guidance to assist agencies in implementing the 

Circular including guidance on identifying voluntary consensus standards bodies and 

voluntary consensus standards; 

► Sponsor and support the ICSP, which is chaired by the National Institute of Standards 

and Technology to consider the various federal agency views and advise the Secretary of 

Commerce and agency heads on the Circular; 

► Report to the Director of OMB concerning the implementation of the policy 

provisions of this Circular; 

► Establish procedures for agencies to use when developing directories described in 

Section 15(b)(5) of the Circular and establish procedures to make these directories 

available to the public; and 

► Issue guidance to the agencies to improve coordination on conformity assessment in 

accordance with Section 8. 

Under the Circular, the heads of the various federal agencies must: 

► Implement the policies of the Circular in accordance with procedures described in the 

Circular; 

► Ensure agency compliance with the policies of the Circular; 

► For an agency with significant interest in the use of standards, designate a senior-level 

official as the Standards Executive who will be responsible for the agency’s 

implementation of the Circular and who will represent the agency on the ICSP; and 
7

► Transmit the annual report prepared by the agency Standards Executive as described 

in Sections 9 and 15b(6). 

Under the Circular, agency Standards Executives must promote effective use of agency resources 

and participation in the voluntary consensus standards process. They are responsible for 

developing: 

► Agency positions that are in the public interest and that do not conflict with each 

other; 

► Agency positions which are consistent with administration policy; and 

► Agency technical and policy positions that are clearly defined and known in advance 

to all federal participants on a given committee. 

Standards Executives must also coordinate their agency’s participation in voluntary consensus 

standards bodies by: 

► Establishing procedures to ensure that agency representatives who participate in 

voluntary consensus standards bodies will, to the extent possible, ascertain the views of 

the agency on matters of paramount interest and will, at a minimum, express views that 

are not inconsistent or in conflict with established agency views; 

► To the extent possible, ensuring that the agency’s participation in voluntary consensus 

standards bodies is consistent with agency missions, authorities, priorities, and budget 

resources; 

► Ensuring, when two or more agencies participate in a given voluntary consensus 

standards activity, that they coordinate their views on matters of paramount importance 

so as to present, whenever feasible, a single, unified position and, where not feasible, a 

mutual recognition of differences; 

► Cooperating with the Secretary of Commerce in carrying out their responsibilities 

under this Circular; 

► Consulting with the Secretary of Commerce, as necessary, in the development 

and issuance of internal agency procedures and guidance implementing the Circular, 

including the development and implementation of an agency-wide directory identifying 

agency employees participating in voluntary consensus standards bodies and the 

identification of voluntary consensus standards bodies; 

► Preparing, as described in Section 9, a report on uses of government-unique standards 

in lieu of voluntary consensus standards and a report on the status of agency standards 

policy activities; 
8

► Establishing a process for ongoing review of the agency’s use of standards for 

purposes of updating such use; and 

► Coordinating with appropriate agency offices (e.g., budget and legal offices) to ensure 

that effective processes exist for the review of proposed agency support for, and 

participation in, voluntary consensus standards bodies, so that agency support and 

participation will comply with applicable laws and regulations. 

III. THE INTERAGENCY COMMITTEE ON STANDARDS POLICY (ICSP) 

3.1 Fiscal Year 2002 Activities 

As reported in detail below, the ICSP had an active year with two continuing working group 

assignments. Three working groups that reported in FY 2001 have been discontinued due to 

inactivity. The Laboratory Accreditation and Conformity Assessment Working Group, the 

Working Group on Quality Management (ISO 9000), and the Standards Working Group of the 

CIO and of ICSP will be reactivated at the call of the chair. 

3.1.1 Ad Hoc Working Groups 

Ad Hoc Working Groups are initiated at the call of the committee chair to address specific issues 

or challenges that arise during full committee meetings. Membership is voluntary, but is 

solicited from agencies that have been determined to be significant, potential contributors to the 

working group’s mission. The historical status of the working groups is listed below. 

 1997 

1. Working Group on Regulatory Agencies 

2. Working Group on Quality Management Systems (ISO 9000) 

3. Working Group on ISO 14000 

4. Working Group on Laboratory Accreditation 

5. Working Group on Directory Database 

6. Working Group on Standards Management 

 1998 

1. Regulatory Agencies’ Working Group 

2. Working Group on Quality Management (ISO 9000) 

3. Working Group on ISO 14000 

4. Working Group on Laboratory Accreditation 

5. Working Group on Directory Database 

6. Working Group on Standards Management 
9

 1999 

1. Regulatory Agencies Working Group 

2. Working Group on Strategic Standards Management 

3. Working Group on Directory Databases 

4. Working Group on Quality Management (ISO 9000) 

5. Interagency Working Group on Environmental Management Systems (EMS) (ISO 

14000) 

6. Procurement Agencies Working Group 

7. Working Group on Federal Agency Participation 

8. Laboratory Accreditation Work Group 

9. Standards Working Group of the CIO and of ICSP 

 2000 

1. Regulatory Agencies Working Group 

2. Working Group on Strategic Standards Management – Dissolved 

3. Working Group on Directory Databases 

4. Working Group on Quality Management (ISO 9000) 

5. Interagency Working Group on Environmental Management Systems (EMS) (ISO 

14000) – Merged with the Executive Order 13148 group outside the ICSP 

6. Laboratory Accreditation Work Group – Merged into the Federal Coordination Group 

of the National Cooperation for Laboratory Accreditation (NACLA) 

7. Standards Working Group of the CIO and of ICSP 

 2001 

1. Laboratory Accreditation and Conformity Assessment Working Group 

2. Regulatory Agencies Working Group 

 2002 

1. Regulatory Agencies Working Group 

2. Working Group on Directory Databases 

3.1.1.1 Regulatory Agencies Working Group Report 

The chair of the Regulatory Agencies Working Group (RAWG) reports the following. 

The Interagency Committee on Standards Policy, Regulatory Agencies Working Group (ICSPRAWG) helps develop and implement standards policies of interest to regulatory entities of the 

federal government. Membership includes representatives from CPSC, DOE, EPA, FCC, FDA, 

NASA, NIST, NRC, and OSHA. The Working Group reports to the ICSP and serves as a forum 

for interagency information exchange and discussion of issues of mutual interest. 
10

During FY 2002, the Working Group focused on issues and activities related to the updating of 

voluntary standards referenced in mandatory regulations. It developed suggestions on how to 

expedite the updating process with a focus on the most significant standards for reference 

updates. 

3.1.1.2 Working Group on Directory Databases Report 

The chair of the Working Group on Directory Databases (WGDD) reports that the group was not 

active during FY 2002 but is planning activity during FY 2003. 

3.2 Committee Policy Recommendations on Continuing Implementation of the NTTAA 

and Circular A-119 

3.2.1 Meaning of the term “use.” 

Both the meaning of the term “use of standards” and how “use” should be counted and reported 

have been the subjects of many discussions during ICSP meetings. Some inconsistencies remain 

in the ways agencies interpret and report their use of standards, leading to difficulties in 

completing an accurate, comparative analysis of the use of voluntary consensus standards by the 

federal agencies. 

The ICSP established a working group to address the use of standards and how to report use. 

During FY 2002, the ICSP made a significant effort to define “use” and guide its membership on 

how to report “use” of standards. That effort is ongoing and may be expanded to include an 

outreach-training program to coordinate further the agency efforts. In FY 2003, NIST will 

survey agency needs regarding awareness and understanding of responsibilities under the 

NTTAA and the Circular. 

Agencies were asked in FY 2002 to identify the way in which they report their use of standards. 

Agency reports indicated that standards are used in many ways by federal agencies. Most 

obvious is incorporation by reference in regulatory and procurement documents. However, 

standards may also be “used” by the federal government in compliance guidelines issued by 

regulatory agencies, or by regulatory agencies during enforcement actions. Standards for goods 

and services are used in various ways during federal agency procurement activities. Individual 

standards may be part of individual procurement contracts or they may be part of a 

comprehensive list of standards acceptable for the provision of goods and services to the federal 

government. 

Five questions were asked in the FY 2002 annual survey of the agencies to learn how agencies 

report their use of standards. The following is a summary of responses received to the five 

questions on use: 

a. Does your federal agency report only the first-time use of standards, continued uses of 

standards, or both first time and continued uses of standards? 
11

 Thirteen agencies report both first-time use and continued use of standards. 

 Seven agencies report only the first time a standard is used. 

 Two agencies report only continued use of standards. 

 Two agencies report no use of standards. 

 Seven agencies did not respond to the question. 

b. Please read the following brief explanation before responding to this question. 

 When reporting standards use, some agencies report uses of standards. That is, they 

count the total number of instances where the agency has referenced a standard. For 

example, three separate references to a single standard are counted as three standards 

uses. On the other hand, other agencies report standards used. These agencies report the 

number of standards that the agency references. In this case, each standard is counted 

only once regardless of how many times it is referenced by the agency. 

 Nineteen agencies count the total number of instances they reference a standard. 

 Two agencies report no use of standards. 

 One agency counts the total number of instances it references a standard only once. 

 Nine agencies did not respond to the question. 

c. Does your federal agency report multiple editions of a single standard as one standard or 

as multiple standards used? 

 Eleven agencies report multiple editions as multiple standards. 

 Ten agencies report multiple editions as one standard. 

 One agency reports both types of use. 

 Two agencies report no use of standards. 

 Seven agencies did not respond to the question. 

d. Does your federal agency report standards that it uses for guidance purposes (as opposed 

to compliance purposes)? 

 Seven agencies report they count use of standards for compliance purposes only. 

 Seven agencies responded “Yes.” 

 Three agencies report they count standards used for guidance and compliance purposes. 

Three agencies report they count standards used for guidance purposes only. 

 Two agencies report no use of standards. 

 Nine agencies did not respond to the question. 

e. Does your federal agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 Fifteen agencies report that they use standards from non-ANSI-accredited standards 

developers. 

 Five agencies report they only count ANSI-accredited standards. 

 Two agencies report no use of standards. 
12

 Nine agencies did not respond to the question. 

In order to address differences in the interpretation of the meaning of the “use of standards” and 

to establish specific guidance for the reporting of use, the Chair of the ICSP will work with the 

committee to develop a guidance document for reporting the use of standards by federal 

agencies. 

3.3 Membership 

3.3.1 Agency Standards Executives and Representatives 

National Institute of Standards and Technology 

 Committee Chair 

 Dr. Belinda Collins 

 Committee Co-chair 

 Ms. Mary Saunders 

 Committee Secretariat 

 Mr. Kevin McIntyre 

Agency for International Development 

 Standards Executive 

 Ms. Kathleen O’Hara 

Consumer Product Safety Commission 

 Standards Executive 

 Mr. Colin Church 

 Standards Executive Representative 

 Ms. Jacquie Elder 

Executive Office of the President 

 Standards Executive 

 Ms. Suzanne Troje 

 OMB/ICSP Liaison 

 Ms. Jacqueline Zeiher 

Federal Communications Commission 

 Standards Executive 

 Mr. Michael Crowe 
13

Federal Emergency Management Agency 

 Standards Executive 

 VACANT 

 

Federal Trade Commission 

 Standards Executive 

 Mr. Alain Sheer 

General Services Administration 

 Standards Executive 

 VACANT 

 

 Standards Executive Representative 

 Mr. Charles Gallagher 

International Trade Commission 

 Standards Executive 

 Mr. Stephen McLaughlin 

National Aeronautics and Space Administration 

 Standards Executive 

 VACANT 

 

 Standards Executive Representative 

 Mr. Richard Weinstein 

National Archives and Records Administration 

 Standards Executive 

 Ms. Nancy Allard 

National Communications Systems 

 Standards Executive 

 Mr. Nick Andre 

National Science Foundation 

 Standards Executive 

 Mr. Alex Schwarzkopf 

Nuclear Regulatory Commission 

 Standards Executive 

 Mr. Michael Mayfield 

 Standards Executive Representative 

 Mr. Frank Cherny 
14

U.S. Department of Agriculture 

 Standards Executive 

 Dr. Greg Parham 

 Standards Executive Representative 

 Ms. Sandra Ginyard 

U.S. Department of Defense 

 Standards Executive 

 Mr. Gregory Saunders 

 Standards Executive Representative 

 Ms. Trudie Williams 

 

U.S. Department of Education 

 Standards Executive 

 Mr. Arthur Graham 

 Standards Executive Representative 

 Mr. Barry Stone 

U.S. Department of Energy 

 Standards Executive 

 Mr. Richard Black 

 Standards Executive Representative 

 Mr. Richard Serbu 

U.S. Department of Health and Human Services 

 Standards Executive 

 Ms. Janet Showalter 

 Standards Executive Representative 

 Ms. Christina Underdonk 

U.S. Department of Housing and Urban Development 

 Standards Executive 

 VACANT 

 

 Standards Executive Representative 

 Mr. David Engel 
15

U.S. Department of the Interior 

 Standards Executive 

 Mr. Daryl White 

 Standards Executive Representative 

 Ms. Sherry Barnett 

U.S. Department of Justice 

 Standards Executive 

 Mr. Michael Carr 

U.S. Department of Labor 

 Standards Executive 

 Mr. Steven Witt 

 Standards Executive Representative 

 Ms. Barbara Bielaski 

U.S. Department of State 

 Standards Executive 

 Ms. Marian Gordon 

U.S. Department of Transportation 

 Standards Executive 

 Ms. Linda Lawson 

 Standards Executive Representative 

 Mr. Robert Stein 

U.S. Department of the Treasury 

 Standards Executive 

 Mr. Michael Parker 

 Standards Executive Representative 

 Ms. Helen Whatley 

U.S. Department of Veterans Affairs 

 Standards Executive 

 Mr. Gary Krump 

 Standards Executive Representative 

 Mr. Pierre Lundy 
16

U.S. Environmental Protection Agency 

 Standards Executive 

 Dr. Mary McKiel 

 Standards Executive Representative 

 Mr. Craig Annear 

U.S. Government Printing Office 

 Standards Executive 

 VACANT 

 

 Standards Executive Representative 

 Ms. Sylvia Subt 

U.S. Postal Service 

 Standards Executive 

 VACANT 

 

 Standards Executive Representative 

 Mr. Bill Griggs 

3.3.2 Changes in Membership and Vacancies 

The committee currently has 45 members including Standards Executives, their alternates, and 

the NIST chair and secretariat. Several members of NIST’s technical staff serve the secretariat 

in non-member committee support positions. There are currently six Standards Executive 

vacancies. Two other agencies may need to address membership on the ICSP: the new 

Department of Homeland Security, a cabinet–level department and the Access Board, formerly 

the Architectural and Transportation Barrier Compliance Board, an independent federal Board 

created by Congress in 1973. 

There was some turnover in committee membership during the past year. Some members of the 

committee left since the last report due to retirement, career reassignments, and other reasons. 

Member agencies appointed 13 new members to the committee either to replace departing 

members or to fill existing vacancies. Future turnover in the next few years will affect the 

corporate memory of the committee. NIST will work with the ICSP to develop and sponsor 

outreach and training programs using current and new resources to educate and inform new 

members as they are appointed to the committee. NIST will continue to work with OMB and the 

respective agencies to fill all existing Standards Executive vacancies. 

The formation of the new Department of Homeland Security (DHS) necessitates a review of its 

structure to determine the need for appointment of its Standards Executive. The incorporation of 

various agencies into DHS also necessitates a review of current membership assignments in light 

of the various agencies’ transfers of all or parts of their current missions. It will also become 
17

necessary in the next year to determine if DHS is to submit an annual report on its use of 

standards. 

The Architectural and Transportation Barriers Compliance Board (ATBCB), referred to today as 

the Access Board, is concerned with accessibility for people with disabilities. It has about 30 

staff and a governing board of representatives from federal departments, plus public members 

appointed by the President. Key responsibilities of the board include developing and 

maintaining accessibility requirements for the built environment, transit vehicles, 

telecommunications equipment, and for electronic and information technology; providing 

technical assistance and training on these guidelines and standards; and enforcing accessibility 

standards for federally funded facilities. The possible addition of the Access Board to the 

membership of the ICSP will be discussed during the next year. 

 

IV. FEDERAL AGENCY USE OF STANDARDS 

4.1 General Discussion 

NIST and the ICSP have reviewed and discussed the nature of the annual report on federal 

agency use of standards and have determined at this time that the inclusion of tables illustrating 

the various types of standards usage can be misleading. This determination recognizes that the 

various agencies have different interpretations of the manner in which to report their use of 

standards. These various interpretations make it difficult to perform a valid comparison of the 

data reported by individual agencies. We are working on a more accurate and satisfactory way 

to summarize, report, and present relevant data for future reports. For this year we are calling the 

readers’ attention to these few key areas: 

 • The efforts of the agencies to comply with the NTTAA and OMB Circular through the 

use voluntary consensus standards in lieu of government-unique standards remain strong. 

 • The use of new voluntary consensus standards to replace existing government-unique 

standards continues to increase although at a slower rate due to a declining inventory of 

government-unique standards available for replacement. 

 • The current inventory of voluntary consensus standards and government-unique 

standards used by the federal government in federal regulations stands at 7,464 citations. 

 • The total number of standards incorporated by reference into the Code of Federal 

Regulations by federal regulatory agencies is approximately 9,500. This total includes 

voluntary consensus standards, government-unique standards, and standards developed 

by private organizations, consortia, and other standards development organizations. 

The tables and text of this section reflect data that are part of a dynamic, ongoing inventory of all 

technical documents incorporated by reference into the FY 2001 Code of Federal Regulations 

(CFR) by federal regulatory agencies. The Standards Services Division of NIST developed the 

inventory during FY 2002 to establish a baseline of the use of standards by regulatory agencies 

from which future use or non-use of standards by the federal government can be measured. The 

inventory contains technical documents incorporated by reference into the FY 2001 CFR, 

including voluntary consensus standards; government-unique standards; private, non-consensus 
18

standards; and technical publications. All of the identified documents are incorporated into the 

regulatory text of the FY 2001 CFR, with some recent updates, by the various federal regulatory 

agencies. 

NIST extrapolated the data in the regulatory inventory from the Finding Aids section contained 

in each volume of the FY 2001 Code of Federal Regulations. The specific information comes 

from the section in the Finding Aids entitled, “Incorporations by Reference.” The inventory does 

not now include voluntary consensus standards that are incorporated by reference in the lists of 

standards various agencies use for the development of procurement documents. NIST proposes 

to develop that inventory later. 

The data provided in this section reflects the cumulative use of voluntary consensus standards 

and government-unique standards in federal regulations by federal agencies. Data on standards 

used by procurement agencies in FY 2002 and any other data or comments reported by 

individual agencies may be extrapolated from the individual agency reports in Sections VII and 

VIII of this report. 

4.2 Cumulative Use of Voluntary Consensus Standards by Agency 

Table 4.2 lists the total number of voluntary consensus standards that are currently incorporated 

by reference in the CFR by the respective agencies. The data were taken from NIST’s initial 

inventory of standards incorporated by reference in the CFR developed in the past year. NIST is 

in the process of refining and verifying the data extrapolated from information in the Finding 

Aids sections of the FY 2001 edition of the CFR. The totals for some agencies are still under 

review, but are believed to be 85 percent to 95 percent accurate. A list of agency acronyms is 

included in Appendix C to this report. 
19

Table 4.2 

Cumulative Use of Voluntary Consensus Standards by Agency 

Federal Agency Total 

DOT/USCG 1,653 

HUD 753 

EPA 749 

DOT/RSPA 579 

DOL/OSHA 453 

DOA/RUS 373 

DOE 225 

DOI/MMS 182 

DOT/NHTSA 174 

ATBCB 159 

HHS/FDA 130 

DOL/MSHA 84 

NARA 44 

CPSC 29 

DOT/OPS 23 

FTC 21 

DOT/FRA 19 

FCC 17 

NRC 17 

HHS/PHS 16 

DOL/Public Contracts 13 

DOI/OSM 12 

HHS 10 

Treasury, BATF 7 

DOE/FERC 5 

U.S. Army Corps of Engineers 5 

HHS/Center for Medicare & 

Medicaid Services 4 

Education 4 

DOT/FAA 3 

DOT/FMCSA 3 

DOA/AMS 2 

DOT/FHWA 2 

HHS/HCFA 2 

DOC/TA 1 

DOA/CCC 1 

DOJ 1 

National Science Foundation 1 

SBA 1 

USAID 1 

Grand Total 5,778 

 Source: NIST Inventory of Standards – November 2002 
20

4.3 Cumulative Use of Government-Unique Standards by Agency 

Table 4.3 contains an inventory of the current total of government-unique standards incorporated 

by reference in the CFR. The data are separated by agency and were taken from NIST’s initial 

inventory of standards incorporated by reference in the CFR developed in the past year. As 

noted before, NIST is in the process of refining and verifying the data it extrapolated from 

information in the Finding Aids sections of the FY 2001 edition of the CFR. The totals for some 

agencies are still under review but are believed to be 85 percent to 95 percent accurate. A list of 

agency acronyms is included in Appendix C to this report. 
21

Table 4.3

Cumulative Use of Government-Unique Standards by Agency

Federal Agency Total 

EPA 739 

DOT/USCG 257 

HHS/FDA 190 

HUD 189 

DOI 52 

DOA/RUS 33 

DOT/NHTSA 27 

DOI/OSM 22 

DOL/Public 

Contracts 21 

DOA/APHIS 20 

DOT/RSPA 18 

DOL/OSHA 16 

DOL/MSHA 15 

DOE 11 

DOT/FAA 10 

DOA/AMS 7 

FCC 6 

HHS/PHS 6 

DOA/FSIS 6 

DOA/GIPSA 6 

DOC/NOAA/NMFS 6 

USPS 6 

ATBCB 4 

Treasury, BATF 4 

CPSC 3 

DOT/FRA 3 

DOT/FHWA 2 

DOA/GIS 2 

DOC/NIST 2 

DOT/OPS 1 

NRC 1 

DOC/TA 1 

Grand Total 1,686 

 Source: NIST Inventory of Standards – November 2002 
22

V. PARTICIPATION OF FEDERAL AGENCY EMPLOYEES IN THE 

VOLUNTARY STANDARDS DEVELOPMENT PROCESS 

5.1 Census of Federal Employees Participating in Voluntary Consensus Standards 

Development Activities 

Reported federal employee participation in voluntary consensus standards development activities 

increased by 108 over last year’s report. However, this number may be misleading because this 

year’s report includes participation in all voluntary consensus standards development activities, 

rather than just participation in voluntary consensus standards committee activity. Expanding 

the scope of this part of the report is intended to capture such additional voluntary consensus 

standards development activities as subgroups of consensus standards development committees, 

independent task forces of standards development organizations, leadership positions on 

standards development organization boards, and other activities not counted in previous reports. 

Federal agency resource commitments to voluntary consensus standards development activities 

go beyond mere participation on technical standards development committees. Various 

voluntary consensus standards development organizations often invite federal employees to serve 

in leadership positions. For example, several federal agencies have been asked to nominate 

senior staff members to serve on the American National Standards Institute’s Board of Directors. 

Other agencies allow employees to serve in leadership positions in technical organizations such 

as the American Industrial Hygiene Association or the American Society of Safety Engineers. 

This commitment of federal agency resources in addition to technical standards development 

committees demonstrates a greater involvement of the federal government in the overall activity 

of voluntary consensus development organizations. 
23

Table 5.1

Census of Federal Employees Participating in Voluntary Consensus Standards 

Development Activities

Federal Agency Number of 

Employees 

Participating 

in 2002 

Change from 

Census Reported in 

2001 

DOE 681 +18 

HHS 615 +334 

DoD 461 -79 

DOC 439 -1 

DOI 300 +219 

DOT 176 -1 

NRC 144 +5 

NASA 131 -8 

USDA 82 +23 

Treasury 66 -1 

DOL 60 -16 

GSA 44 +3 

EPA 42 -4 

CPSC 29 -2 

VA 14 +2 

NARA 13 +4 

HUD 10 None 

NCS 10 None 

DOJ 5 None 

FCC 5 None 

Education 2 None 

GPO 0 -2 

 Source: Agency Reports 

5.2 Census of Voluntary Consensus Activities in Which Federal Employees Participated 

The total number of voluntary consensus activities in which federal employees participated 

declined by 354 from last year’s report. This significant decline can be attributed to the 

necessary reevaluation of the commitment of agency personnel resources in light of reductions in 

agency workforce populations connected to budgetary restrictions, employee turnover, and 

retirements. 

Many agencies are facing reductions in their FTE allotments due to budget restrictions. As a 

result, some committee positions are refilled when employees retire or leave for new positions. 

Further, the continued reliance of federal agencies on the outsourcing of standards development 

activities to the private sector has reduced the number of full-time federal employees available 

for participation in voluntary consensus standards activities. 
24

Overall, many federal regulatory, and procurement activities have been reduced. The regulatory 

agendas and procurement priorities of many agencies have been reevaluated, and agency 

participation on many technical standards development bodies has been eliminated or reduced in 

priority. Accordingly, federal employee participation on voluntary consensus standards activities 

that are not directly related to the missions of regulatory and procurement agencies has been 

eliminated or curtailed. 

However, it should be noted that while the number of activities in which federal employees 

participated has declined, the number of employees participating on these bodies has increased. 

This most likely demonstrates a greater commitment toward the allocation of limited agency 

resources to those voluntary consensus standards activities most directly affecting agency 

regulatory or procurement activity. Stretching limited agency resources over a large number of 

voluntary consensus standards activities may have a negative effect on the federal government’s 

impact on the voluntary consensus standards process. 

Table 5.2

Census of Voluntary Consensus Activities in Which Federal Employees Participate

Federal Agency Number of 

Consensus 

Activities in 

2002 

Change from Census 

Reported in 2001 

DOC 165 -3 

DOD 109 +54 

DOE 57 -1 

DOT 54 -114 

USDA 51 +12 

HHS 40 -17 

NASA 36 +4 

GSA 24 -83 

EPA 22 +2 

DOI 20 -9 

VA 20 -4 

DOL 15 -20 

NCS 15 -3 

NRC 15 -3 

NARA 12 +7 

CPSC 8 -1 

Treasury 8 None 

FCC 7 +6 

HUD 5 None 

DOJ 2 -1 

Education 1 None 

GPO 0 -2 

 Source: FY 2002 Agency Reports
25

5.3 Changes in Employee Participation 

In recognizing that more employees are participating on fewer committees, NIST believes that 

this results from several factors. First, financial resources for participation on technical 

committees and attendance at national, regional, or local Standards Development Organizations 

(SDO) conferences have been reduced due to departmental and agency budget constraints. Past 

resources for travel, per diem, membership dues, and organizational fees are no longer available, 

or have been severely curtailed. Second, many regulatory agencies are experiencing a reduction 

in the development of new departmental or agency regulations due to individual department or 

agency regulatory agendas. Regulatory agencies are issuing fewer new regulations and are not 

updating or revising older outdated regulations. Hence, expenses related to employee 

participation on the technical committees responsible for related national voluntary consensus 

standards is thought to be unnecessary in times of budget constraint. Finally, some departments 

and agencies have failed to replace retiring or reassigned employees on technical committees. 

The overall impact of this decline in participation creates a void in the voluntary consensus 

standards development process. Technical input from federal employees serving on the various 

technical committees is necessary to ensure a continuing process of consensus. The views of the 

government, particularly regulatory or procurement agencies, add significantly to the openness 

of the consensus standards development process and help reduce or eliminate problems that may 

arise when the federal agencies choose to incorporate voluntary consensus standards into the 

federal standards inventory. 

Further, federal employees serving on technical committees become familiar with the voluntary 

consensus standards process and the reasoning behind the development and promulgation of 

specific voluntary consensus standards. Participation on technical committees can serve as a 

learning experience for newer federal employees. Federal employees can bring back to their 

departments and agencies both an awareness of the technical discussions that occur during the 

development of a voluntary consensus standard and the rationale for decisions made by the 

committee. This awareness of the committee’s actions may reduce or eliminate the need for 

redundant or extraneous discussions at the departmental or agency level as new or updated 

federal regulations are developed. 

Additionally, the participation of established federal employees on technical committees and 

other consensus standards activities helps to maintain the knowledge and competence of the 

federal workforce as new technologies evolve in the marketplace. There is an opportunity for the 

federal government to develop or use newer voluntary consensus standards that reflect current 

technologies and offer alternative means of compliance with existing federal regulations. 

Regulated populations within the economy are not hampered or restrained by outdated federal 

rules and regulations that fail to recognize advances in marketplace technologies. 

It is recommended that the departments and agencies of the federal government consider 

adopting and implementing strategies within the context of their individual strategic plans to 

increase federal employee involvement in the voluntary consensus standards development 
26

process. This is essential if the federal government is to maintain, or even increase, its important 

role in the national voluntary consensus process. 

5.4 Inventory of Standards Development Organizations 

According to agency reports, federal agencies interact with at least 213 individual standards 

development organizations (SDOs). These include various consortia, ANSI-accredited SDOs, 

non-ANSI-accredited SDOs, and other organizations that develop product or performance 

standards. NIST surveyed the agencies to determine with which specific standards development 

organizations their employees interact during agency regulatory or procurement activities. As 

noted and discussed in previous sections, the number of federal employees participating in 

various standards development activities has increased while the number of standards 

development bodies they work with has decreased. NIST is seeking to establish with which 

bodies the agencies interact in order to provide guidance for federal agency participation directly 

related to an agency’s regulatory or procurement activities. NIST can thus fulfill its coordination 

obligations under the NTTAA and OMB Circular as a clearinghouse for information on ongoing 

voluntary consensus standards activity provided by various agencies that interact with the 

various SDOs. 

The following table shows the current inventory of SDOs on which federal agencies have 

reported employee representation. 
Inventory of Standards Development Organizations with Whom Federal Agencies Inter

Abbreviation USDA DoD DoC DoE DoT GPO HHS AA Aluminum Association X AABB American Association of Blood Banks X AAMA American Architectural Manufacturers Association X AAMI Association for the Advancement of Medical Instrumentation X X AAMVA American Association of Motor Vehicle Administrators X AAPM American Association of Physicists in Medicine X AASHTO American Association of State Highway and Transportation Officials X AAR Association of American Railroads X AATCC American Association of Textile Chemists and Colorists X ABMA American Bearing Manufacturers Association X ABYC American Boat and Yacht Council X ACGIH American Conference of Governmental Industrial Hygienists X ACI American Concrete Institute X X ACNP American College of Nuclear Physicians X ACR American College of Radiology X ACRI Air Conditioning & Refrigeration Institute X ADA American Dental Association X X ADSC American Dental Standards Committee X AGA American Gas Association AGMA American Gear Manufacturers' Association X AGS American Glovebox Society X AHA American Hardboard Association X AIA Aerospace Industries Association of America AIAA American Institute of Aeronautics and Astronautics X X AIHA American Industrial Hygiene Association X X AIIM Association for Information and Image Management X X X AISC American Institute of Steel Construction X X AITC American Institute of Timber Construction X AIUM American Institute of Ultrasound in Medicine X ALCA American Leather Chemists Association X ALI Automotive Lift Institute - ALOIM AMCA Air Movement and Control Association X ANMC American National Metric Council X ANS American Nuclear Society X ANSI American National Standards Institute X X X X X X AOACI Association of Official Analytical Chemists International X API American Petroleum Institute X APTA American Public Transportation Association X AREMA American Railway Engineering & Maintenance-of-Way Assoc. X ASA Acoustical Society of America X X ASAE American Society of Agricultural Engineers 

- 27 -
Abbreviation USDA DoD DoC DoE DoT GPO HHS 

ASC American Society of Cinematographers X ASCE American Society of Civil Engineers X X X X ASHRAE American Society of Heating, Refrigerating, and Air-Conditioning Engineers X X ASM American Society of Metals ASME American Society of Mechanical Engineers X X X X ASNT American Society for Nondestructive Testing X X ASQ American Society For Quality X X ASQC American Society of Quality Control X ASSE(1) American Society of Safety Engineers X ASSE(2) American Society of Sanitary Engineering X ASTM American Society for Testing and Materials X X X X X ATIS Alliance for Telecommunications Industry Solutions X AWEA American Wind Energy Association X AWI Architectural Woodwork Institute X AWPA American Wood Preservers Association X X AWS American Welding Society X X AWWA American Water Works Association X X X BHMA Builders Hardware Manufacturers Association X BOCA Building Officials and Code Administrators International X CAMI Consortium for Advanced Manufacturing - International X CEN European Committee for Standardization X CENELEC European Committee for Electrotechnical Standardization X CGA Compressed Gas Association X CGNS Computational Fluid Dynamics (CFD) General Notation System CGSB Canadian General Standards Board X X CI Cordage Institute XCIE International Commission for Illumination X CIRMS Council on Ionizing Radiation Measurements and Standards X CISPI Cast Iron Soil Pipe Institute X CMVSA Commercial Motor Vehicle Safety Alliance X CODEX Codex X XCSI Construction Specifications Institute X X CTI(1) Cooling Technology Institute X CTI(2) Cooling Tower Institute X DFI Deep Foundations Institute X DIN Deutsches Institut fur Nomung - German Institute for Standardization X DISAI Data Interchange Standards Association, Inc. X DSMO Data Standards Maintenance Organization X ECAMA Electronic Components Assemblies & Materials Association X ECGA Electrical Generating Systems Association XEDA Electrostatic Discharge Association X EIA(1) Electronic Industries Alliance X X FAA NAVARRO Navarro Committee X GCA Graphic Communications Association X 

- 28 -
Abbreviation USDA DoD DoC DoE DoT GPO HHS 

GEIA Government Electronics & Information Technology Association X GSSA Green Seal Standards for Adhesives GTB Groupe de Travail Brussels X HFESI(1) Human Factors and Ergonomics Society, Inc. X HFIA High Frequency Industry Association X HFS(1) Human Factors Society X HLS High Level Seven X HPB Health Protection Branch, Health Canada X HPS Health Physics Society X X HPVA Hardwood Plywood & Veneer Association X IAEA International Atomic Energy Agency X IAI International Alliance for Interoperability X IAPMO International Association of Plumbing and Mechanical Officials X ICAC Institute of Clean Air Companies X ICAO International Civil Aviation Organization X ICBO International Conference of Building Officials X ICDD International Center for Diffraction Data X ICEA Insulated Cable Engineers Association X X IEA International Energy Agency X IEC International Electrotechnical Commission X X X IEEE Institute of Electrical and Electronic Engineers X X X X X IES Illuminating Engineering Society of North America X X IEST Institute of Environmental Sciences & Technology X IETF Internet Engineering Task Force X IIE Institute of Industrial Engineers X IIIA International Imaging Industry Association IMO International Maritime Organization X IPC Institute for Interconnecting and Packaging Electronic Circuits X X INMM Institute of Nuclear Materials Management X X IOVW International Organization of Vines and Wines X ISTA International Seed Testing Association X ISAC International Society for Analytical Cytology X ISAS The Instrumentation, Systems, and Automation Society X ISBT International Society for Blood Transfusion X ISCVS International Society for Cardiovascular Surgery X ISO International Organization for Standardization X X X X X ISO/IEC International Organization for Standardization/International Electrotechnical 

Commission 

X

ISOB International Organization for Standardization in Microbiology X ITE Institute of Transportation Engineers X ITI Information Technology Industry Council X X ITRI Interconnection Technology Research Institute ITS America Intelligent Transportation Society of America X IUPAC International Union of Pure and Applied Chemistry X 

- 29 -
Abbreviation USDA DoD DoC DoE DoT GPO HHS 

JEDEC Joint Electron Device Engineering Council X LIA Laser Institute of America X MMPA Magnetic Materials Producers Association X MPI Master Painters Institute X MSSVFI Manufacturers Standardization Society of the Valve and Fittings Industry X NAAMM National Association of Architectural Metal Manufacturers X NACE National Association of Corrosion Engineers International X X NACLA National Cooperation for Laboratory Accreditation X X NAFTA NAFTA Land Transportation Standards Subcommittee X NAPM National Association of Photographic Manufacturers X NARM National Association of Relay Manufacturers X NATDGS North American Transport of Dangerous Goods Standards X NCCLS National Council of Chemical Laboratory Standards X NCITS National Committee for Information Technology Standards X NCPDP National Council for Prescription Drug Programs X NCRPM National Council of Radiation Protection and Measurements X X NCSL National Conference of Standards Laboratories X NCVHS National Center for Vital and Health Statistics X NEMA National Electrical Manufacturers Association X X X NFPA(1) National Fire Protection Association X X X X NFPA(2) National Fluid Power Association X NHLA National Hardwood Lumber Association X NIBS National Institute of Building Sciences X NIRMAI Nuclear Information and Records Management Association, Inc. X NISO National Information Standards Organization X NPMA National Petroleum Management Association X NRECA National Rural Electric Cooperative Association X NSC National Safety Council X XNSFI NSF International X NUBC National Uniform Billing Committee X NUCC National Uniform Claim Committee X OECD Organization for Economic Cooperation and Development X X OLA Optical Laboratories Association X PDI Plumbing and Draining Institute X PHCCA Plumbing-Heating-Cooling Contractors Association X PIA Parachute Industry Association X PMI Project Management Institute X PRI Performance Review Institute QCDS Quarter-Inch Cartridge Drive Standards, Inc. X RCC Range Commander Council RESNA Rehabilitation Engineering and Assistive Technology Society of North America X RIA Robotics Industry Association X RMA Rubber Manufacturers Association X RTCA Radio Technical Commission for Aeronautics 

- 30 -
Abbreviation USDA DoD DoC DoE DoT GPO HHS 

RTCM Radio Technical Commission for Maritime Services RWMA Resistance Welders Manufacturers Association X SAE Society of Automotive Engineers X X X X SAMA Scientific Apparatus Makers Association X SAWE Society of Allied Weight Engineers X SDA The Soap and Detergent Association X SDI Steel Door Institute X SES Standards Engineering Society X X SFPE Society of Fire Protection Engineers X SFSA Steel Founders Society of America X SHACCNA Sheet Metal & Air Conditioning Contractors Nat'l. Assoc. X SIA Security Industry Association X SISO Simulation Interoperability Standards Organization X SNAME Society of Naval Architects and Marine Engineers X SPC Society for Protective Coatings X SPRI Single Ply Roofing Institute X SSPC SSPC (The Society for Protective Coatings) STP Society of Toxicological Pathologists X SWI Steel Window Institute X TIA Telecommunications Industry Association X TOG The Open Group X TRAI The Tire and Rim Association, Inc. X TRB Transportation Research Board X TTMA Truck Trailer Manufacturers Association X UHMS Undersea and Hyperbaric Medical Society X UL Underwriters Laboratories X X UNCFPPA UN Centre for Facilitation of Procedures & Practices for Administration, Commerce

& Transport 

X

UNECE United Nations Economic Commission for Europe WP .29/GRSP X X USANC U.S. Adopted Names Council X USBGN U.S. Board on Geographic Names USP United States Pharmacopoeia X VITA VITA Standards Organization X W3C World Wide Web Consortium X WDMA Window and Door Manufacturers Association X WEDI Workgroup for Electronic Data Interchange X WMC Workflow Management Coalition X WRC Welding Research Council X WWPA Western Wood Products Association X WEF Water Environment Federation X 

- 31 -
32

VI. FEDERAL AGENCY CONFORMITY ASSESSMENT ACTIVITY 

6.1 Background

Conformity assessment is defined in ISO/IEC Guide 2: 1996, as “any activity concerned with 

determining directly or indirectly that relevant requirements are fulfilled.” Conformity 

assessment procedures provide a means of ensuring that the products, services, or systems 

produced or operated have the required characteristics and that these characteristics are 

consistent from product to product, service to service, or system to system. 

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

system assessment and registration; accreditation of the competence of those activities and 

recognition of an accreditation program’s capability. A specific conformity assessment process 

may include one or more of these conformity assessment activities. While each of these 

activities is a distinct operation, they are closely interrelated. In addition, standards are 

interwoven into all aspects of these activities and can have a major impact on the outcome of a 

conformity assessment process. 

 

Conformity assessment activities form a vital link between standards (which define necessary 

characteristics or requirements for products) and the products themselves. Together standards 

and conformity assessment activities affect almost every aspect of life in the United States. 

6.2 Continuing Activity 

The following section contains information on federal agency conformity assessment activity as 

reported by the individual agencies. The information was taken directly from the reports the 

agencies submitted to NIST. 

6.2.1 Department of Commerce 

NIST Committee Participation

NIST’s Standards Services Division (NIST/SSD) continues to participate in the ANSI 

International Conformity Assessment Committee (ICAC), which serves as the U.S. Technical 

Advisory Group (TAG) to ISO's Council Committee on Conformity Assessment (CASCO). 

SSD staff also continues to participate in CASCO Working Group 25 on alignment of ISO/IEC 

17025 with ISO 9000/2000, Working Group 22 on a code of good practice for conformity 

assessment, and Working Group 20 on the revision of ISO/IEC Guide 7 on the inclusion of 

conformity assessment requirements in standards. 

SSD staff also continues to be active in a CASCO ad hoc group on Regulators Interface and in 

working groups of the International Accreditation Forum (IAF). 

NIST/SSD personnel continue to serve on the ANSI committee that is responsible for accrediting 

certification bodies and on the U.S. National Committee to the IECEE (IEC System for 
33

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

scheme that allows manufacturers to obtain a test certificate from an approved U.S. National 

Certification Body (NCB) and to use this test report to obtain certification marks in other 

participating countries. 

NIST/SSD staff also continues to participate in the U.S. Technical Advisory Group (TAG) to 

ISO TC 176, the ISO committee responsible for the development and maintenance of the ISO 

9000 standards series, and in American Society for Quality (ASQ) Z-1, the U.S. committee 

responsible for adoption of the ISO 9000 series as U.S. national standards. 

The Chief of SSD at NIST serves as the Chair of the ANSI-Registrar Accreditation Board 

National Accreditation Program Environmental Management Systems Council. The Council is 

responsible for accrediting registrars that assess facilities for conformance to the ISO 14001 

standard. 

NIST/SSD has published a number of directories and reports on conformity assessment-related 

issues and maintains a Web site (http://www.ts.nist.gov/ca) that provides a one-stop-shopping 

source for information on conformity assessment issues. 

National Cooperation for Laboratory Accreditation (NACLA)

Section 12b of the National Technology Transfer and Advancement Act (NTTAA) of 1995 

directed NIST to coordinate conformity assessment activities of federal, state, and local entities 

to eliminate unnecessary duplication of conformity assessment activities. In response, NIST 

continues to be a driving force behind the creation and functioning of NACLA. NACLA is 

composed of organizations in the United States, with observers from Mexico and Canada that 

actively support development of a system for recognizing the competence of testing and 

calibration laboratories leading to worldwide acceptance of test and calibration reports from 

those laboratories. Concerned with costly, multiple, duplicate assessments, and the lack of 

domestic or international recognition of laboratory accreditations, the group has explored 

solutions that could lead the United States, and perhaps eventually its North American Free 

Trade Agreement (NAFTA) partners, toward the goal of having only one assessment of a 

laboratory in a given field of testing, based on internationally accepted procedures. The NACLA 

vision is for a U.S. laboratory accreditation system that achieves the following goals: 

• For the testing laboratory, a single accreditation in a given field of testing, with 

worldwide recognition of the laboratory's competence. 

• For the manufacturer/supplier, a test performed once, with worldwide acceptance. 

• For the acceptance body (that is a government agency or an industry specifier), an 

accreditation based on uniform criteria and intended to ensure that a laboratory is 

qualified to provide data of consistent quality. 

In the past year, NACLA continued to improve its program and to take appropriate actions to 

align with the evolving international system for recognition of competent accreditation bodies. 

Some milestones during the period include the following: 
34

• Adoption of a new version (Revision D) of the NACLA Recognition Procedure. The 

revision incorporates several procedural improvements that have been developed by the 

International Laboratory Accreditation Cooperation (ILAC). 

• A meeting of NACLA officials with officials of the Asia Pacific Laboratory 

Accreditation Cooperation (APLAC) to discuss ways that the two organizations might 

cooperate, to the benefit of both. 

• Recognition of an additional U.S. accreditation body: the American Industrial Hygiene 

Association (AIHA). There are now four accreditation bodies recognized by NACLA, 

including the NIST National Voluntary Laboratory Accreditation Program (NVLAP). 

• Sponsorship of the first National Forum on Laboratory Accreditation. The event was 

well attended and well received. The second annual Forum is scheduled for March 2003. 

The NIST Standards Services Division Chief is a member of the NACLA Operations Council 

and co-chairs the NACLA External Affairs Committee. Under the NIST-NACLA Memorandum 

of Understanding (signed July 2000), NIST recognizes NACLA as a suitable private sector 

alternative to NIST’s National Voluntary Conformity Assessment System Evaluation 

(NVCASE) program. NIST relies on NACLA recognition of qualified accreditation bodies in 

support of NIST responsibilities as a designating authority under the U.S.-European Union 

Mutual Recognition Agreement (MRA), the APEC Telecommunications MRA, and the CITEL 

MRA. More than 100 laboratories have been designated as Conformity Assessment Bodies 

(CABs) under the provisions of the U.S.-EU and APEC MRAs, pursuant to this MOU. 

National Voluntary Laboratory Accreditation Program

NIST/SSD’s National Voluntary Laboratory Accreditation Program (NVLAP) operates in 

conformance with ISO Guide 58 and accredits calibration and testing laboratories to ISO/IEC 

17025. NVLAP operates programs in response to congressional mandates and in support of 

several federal agencies, including the Department of Energy, the Nuclear Regulatory 

Commission, the Food and Drug Administration, the Department of Defense, the Environmental 

Protection Agency, and the Federal Communications Commission, and supports state and local 

governments. 

6.2.2 Department of Energy 

National Voluntary Laboratory Accreditation Program 

DOE facilities, including Sandia National Laboratories, Pacific Northwest National Laboratory, 

Honeywell Federal Manufacturing and Technologies, Bechtel BWXT Idaho, and Oak Ridge 

Metrology Center, are accredited under the NIST NVLAP to perform calibrations in a variety of 

metrology parameters, including dimensional, radiation, physical, and electrical metrology. The 

scope of accreditation of each laboratory can be obtained from the NVLAP Web site located at 

http://ts.nist.gov/ts/htdocs/210/214/214.htm. 
35

Department of Energy Laboratory Accreditation Program (DOELAP)

Through DOELAP, DOE establishes specific performance testing requirements and site 

assessment criteria for accreditation of DOE personnel dosimetry systems and radio bioassay. 

DOELAP incorporates standards (including ISO/IEC Guide 25, General Requirements for the 

Competence of Calibration and Testing Laboratories, Health Physics Society (HPS) Standards, 

and DOE Technical Standards), establishes DOE organizational responsibilities and 

accreditation processes, and establishes procedures for administering DOELAP and for acquiring 

accreditation. 

DOELAP evaluates the respective DOE personnel dosimetry or radio bioassay program’s 

laboratory performance, based on performance testing criteria, and their operational competence, 

based on established “quality system” criteria regarding good laboratory practice. DOELAP is 

used for worker monitoring and protection at DOE and DOE contractor sites and facilities, as 

required in Title 10, Code of Federal Regulations, Part 835, “Occupational Radiation 

Protection.” 

National Cooperation for Laboratory Accreditation

DOE has been active in founding and supporting NACLA, and is currently a member 

organization of NACLA and participates in managing NACLA activities. 

DOE Voluntary Protection Program (VPP)

DOE has established VPP criteria for its facilities' occupational safety and health programs, 

based on the Occupational Safety and Health Administration's (OSHA) VPP. These criteria 

establish a baseline that denotes compliance with all occupational safety and health standards, 

rules, and regulations. DOE conducts on-site evaluations to establish how successful DOE 

applicants for VPP have exceeded the baseline criteria. 

DOE Topical Committees (TCs)

The Department of Energy Technical Standards Program (TSP), within DOE's Office of 

Environment, Safety, and Health, has chartered a number of DOE Topical Committees that 

directly and indirectly advocate and support conformity assessment activities across DOE. 

These topical committees are composed of DOE and DOE contractor subject matter experts, and 

generally include members and observers from other federal agencies, industry, and standards 

development organizations. The TCs are chartered to coordinate with these groups on standards 

activities, including conformity assessment. DOE Topical Committees involved in conformity 

assessment activities include the following: 

Metrology TC – Comprised of representatives from laboratories across the DOE complex, the 

Metrology TC coordinates the efforts of many DOE organizations involved in metrology and 

actively interacts with NIST, NASA, DOD, and other federal agencies in its activities. The 

group has developed a Web site that contains information on metrology capabilities at the 
36

various DOE laboratories, past meeting minutes, committee members, and contacts, white papers 

on metrology issues, and future meeting announcements. The group is in the process of 

developing information on calibration uncertainty analysis procedures and supplier certification 

programs used in the various DOE laboratories. 

Accreditation TC – Comprised of representatives from laboratories across the DOE complex, the 

Accreditation TC promotes unified laboratory accreditation activities across DOE and actively 

interacts with NACLA, ASCI, ISO, and other organizations to promote nationally and 

internationally recognized accreditation standards. The group has also developed a Web site that 

contains information on past committee meetings, committee membership and contacts, and 

white papers on accreditation issues. 

Environmental Management Systems TC (EMS TC) – The EMS TC provides information and 

assistance to DOE organizations interested in establishing ISO 14000 certified environmental 

management programs. Several DOE sites achieved accreditation during the year. 

Quality and Safety Management Special Interest Group/Quality Assurance Topical Committee – 

The QSM SIG/QA TC develops, improves, and provides management information related to 

quality and safety issues involving the DOE community, including information and assistance to 

DOE organizations interested in ISO 9000 criteria or a move from DOE specific standards to 

industry consensus standards. 

 

High Efficiency Particulate Air (HEPA) Filter Qualification Testing/HEPA TC – The DOE 

conducts functional and quality testing of HEPA filters, used in critical applications at DOE 

facilities, at a designated facility for HEPA filters to ensure conformance with ASTM standards 

and to help ensure adequate performance in safety applications. 

Biota Dose Assessment Topical Committee (BDATC) – The BDATC has broad representation 

from DOE offices, national laboratories, universities, and the private sector. The BDATC brings 

together the expertise in health physics, radioecology, environmental monitoring, and risk 

assessment as a resource base for DOE on biota dose assessment. It coordinates these interests 

to establish common standards and processes for biota dose assessment across DOE, the United 

States, and internationally. Through its standard, the BDATC provides radiation dose evaluation 

methods that can be used to meet DOE requirements. The international community, including 

the IAEA and the Atomic Energy Control Board (AECB) of Canada, are interested in broader 

application of the DOE BDATC standard. 

Meteorology Topical Committee (MTC) – The DOE MTC works across DOE, with other federal 

agencies, and with the American Nuclear Society (ANS) to help promote the use of ANS 3.11 as 

a replacement for various agency standards. The MTC can also provide on-site evaluations of 

on-site meteorology programs to support implementation of the new ANS 3.11 standard. 
37

6.2.3 Department of Health and Human Services 

U.S. Food and Drug Administration

The Center for Devices and Radiological Health (CDRH) has liaison with the ANSI 

Accreditation Committee, the ANSI International Conformity Assessment Committee, ANSI 

Board Committee on Conformity Assessment, and ASTM Committee E-36 on Conformity 

Assessment. The Center uses suppliers' declaration of conformity as described in ISO/IEC 

Guide 22 in its standards recognition program and has developed an MRA with the European 

Union on mutual recognition of each other's conformity assessment procedures related to 

manufacture and marketing of medical devices. 

The Center for Veterinary Medicine (CVM) inspects drug manufacturers for compliance with 

current Good Manufacturing Practices (cGMP) requirements and inspects laboratories that 

provide pivotal animal studies for drug approvals for compliance with Good Laboratories 

Practices. 

The Office of Regulatory Affairs (ORA) actively participates with the National Cooperation for 

Laboratory Accreditation (NACLA). An ORA official is a member of the NACLA Operations 

Council and has the role of participating in the NACLA Recognition Committee for Accrediting 

Bodies who apply for mutual recognition. Other FDA officials participate with NACLA in the 

evaluation of accrediting bodies under ISO/IEC 58 and ISO/IEC 17025 and sit on NACLA 

technical committees. 

ORA officials are also involved with Codex Alimentarius activities, especially in the area of 

pesticide residues, which relies on methods development by ISO and AOAC. Other activities 

include participation and the coordination of federal-state conferences to develop uniformity in 

the reporting of food testing results. The ISO/IEC 17025 standard is the foundation in this 

coordination effort. 

Agency for Healthcare Research and Quality

The Agency for Healthcare Research and Quality (AHRQ) is the government’s leading agency in 

the development and deployment of evidence-based research on health care quality and costs. 

One key area of this work is AHRQ’s support for voluntary consensus standards use in the health 

care field. As the leading agency sponsoring research on health care quality that will support 

clinical health care system and public policy decision makers, AHRQ regularly is involved in 

evaluating health care standards across the spectrum of patient care. AHRQ’s Evidence-Based 

Practice Centers (EPCs) includes 13 centers across the country and in Canada that are available 

to public and private partners seeking to research disease conditions and standards of care for 

those conditions. Numerous EPC reports have been used as crucial inputs of evidence in larger 

consensus-based standards processes. AHRQ’s National Guidelines Clearinghouse (NGC) is a 

public resource for evidence-based clinical practice guidelines. NGC is sponsored by AHRQ in 

partnership with the American Medical Association and the American Association of Health 
38

Plans. The NGC is nationally recognized archive for numerous standards, including voluntary 

consensus standards. 

6.2.4 Department of Housing and Urban Development 

The Department continues to operate 25 conformity assessment programs, under the HUD 

Building-Products Standards & Certification Programs. All of the programs comply with the 

ISO guidelines and procedures. These are the same standards used by ANSI and other nationally 

recognized third-party certification agencies. 

6.2.5 Department of Justice 

The Office of Science and Technology of the National Institute of Justice (NIJ) in collaboration 

with NIST continues to sponsor the Office of Law Enforcement Standards (OLES). The OLES 

develops methods for testing equipment performance; develops methods for examining 

evidentiary materials; develops standards for equipment and operating procedures; develops 

standard reference materials; and performs other scientific and engineering research as required 

by the criminal justice and public safety communities. This interagency cooperative effort 

results in improvements in the quality and consistency of various conformity assessment 

requirements and processes at the federal, state, and local levels. 

6.2.6 Department of Transportation 

Federal Railway Administration (FRA)

The FRA’s conformity assessment activities are visible internationally through expanded efforts 

in the area of safe, uniform international transport of hazardous materials by participation in the 

Canadian General Standards Board Tank Car Committee and the ASME Transportation Pressure 

Vessel Committee, as well as continuing to participate in the North American Transport of 

Dangerous Goods Standard (NATDGS) Working Group and the AAR Tank Car Committee, as 

reported last year. Participation in six voluntary consensus standards bodies as well as in 

numerous committees and sub-committees of those bodies gives FRA access to the 

developmental stages of private sector conformity assessment standards to make sure the agency 

viewpoint is considered in the development of their standards. 

6.2.7 Department of the Treasury 

The standards that Treasury bureaus have adopted will continue to involve conformity 

assessment activities, which include internal audit and eventual certification in conformance with 

acceptable practices. 

6.2.8 Agency for International Development 

The agency continues to participate in the Contractor Performance Reporting system developed 

and managed by the National Institutes for Health, including participating as a member of the 
39

committee that determines information requirements. This may be considered a conformity 

assessment activity since it is standardizing the way that the participating agencies assess 

contractors' performance. 

6.2.9 General Services Administration 

Green Seal

Green Seal is an independent, non-profit “third party certification” organization devoted to the 

creation of scientific evaluation criteria for environmentally preferred products. These criteria 

are then used to provide credible, objective, and unbiased product review. In addition, a list of 

relevant Green Seal standards and Green Seal recommended products is maintained on the GSA 

Hardware SuperStore Web page under “Environmental Issues.” 

National Institute of Building Sciences (NIBS)

Master Painters Institute (MPI)

Scientific Certification Systems (SCS)

GSA continues to provide suppliers with the option of certifying their products under the SCS 

Specification for Architectural and Anti-Corrosive Paint. This was a joint effort by the National 

Institute of Building Sciences (NIBS), Master Painters Institute (MPI), ICI Paint, the Department 

of Defense, the General Services Administration, the Chemical Manufacturers’ Association, and 

the Scientific Certification Systems. This criteria is based on International Organization for 

Standardization (ISO) Standard 14042, as prepared by Technical Committee ISO/TC 207, 

Environmental Management Subcommittee SC 5, Life Cycle Assessment and has been adopted 

as a standard by MPI. In addition, a copy of this standard and a list of SCS Certified products 

are maintained on the GSA Hardware SuperStore Web page under “Environmental Issues.” 

Clean Air Act National Emission Standards for Hazardous Air Pollutants (CAA/NESHAP) 

Compliance for Shipbuilding and Aerospace coatings 

The Clean Air Act (40CFR Subpart 63.741-63.753 and 63.780) designate “Shipbuilding and 

Ship Repair Facilities” and “Aerospace Manufacturing and Rework Facilities” as a regulated 

emissions source categories. Clean Air Act rules limit the volatile organic hazardous air 

pollutant (VOHAP) content of several types of solvents, coatings, strippers, and maskants used 

within these industrial categories. Compliance is based on proper documentation that volatile 

organic compound (VOC) or VOHAP emissions were within allowable limits. For select items 

regulated by the NESHAP, the GSA Hardware SuperStore continued to collect brief technical 

data certificates that provide much of the data that the U.S. EPA requires the coating end user to 

maintain at their location. These certificates were then faxed to the Department of Defense 

liaison office. Also, GSA provided input to how to structure a new Web site that is to offer these 

documents electronically in the future. 
40

Hazardous Material Information Resource System (HMIS) Functional Working Group

The HMIS Functional Working Group (FWG) is chartered under the sponsorship of the HMIS 

Policy Working Group (PWG). Its role is to represent the users of hazardous materials 

information and management systems that deal with Material Safety Data Sheets (MSDS) or 

related/associated technical information, and strive to ensure that the functional needs of those 

users are met. In addition, the FWG prepares recommendations to the PWG on issues pertaining 

to the functional aspects of improvements to existing or future DOD hazardous materials 

information and management systems. The core FWG membership consists of voting 

representatives from the Army, Air Force, Navy, DLA, and GSA. 

6.2.10 National Aeronautics and Space Administration (NASA) 

As an acquisition-oriented agency, conformity assessment is a major element of NASA’s 

policies and procedures to assure the safety and mission success of NASA programs. NASA is 

continuously evaluating and improving our conformity assessment practices and procedures. 

NASA has a long-standing practice of working with other government agencies and the public 

sector to integrate best practices into our activities. NASA continues to work with the 

Department of Defense (DOD) and the aerospace industry to adopt and define consistent quality 

practices. NASA routinely utilizes other government agencies to assist us with Contract 

Administration Services (CAS) including substantial conformity assessment activities. The 

Defense Contract and Audit Agency, Defense Contract Management Agency, Office of Naval 

Research, and other activities continue to provide conformity assessment services for NASA 

programs. These are ongoing relationships that utilize the expertise and infrastructure that are 

resident within these agencies and allow NASA to limit their internal assessments to areas where 

external capabilities are not available. The management and monitoring processes established 

for these CAS activities provides a mechanism to continually exchange ideas and best practices 

related to conformity assessment. 

Finally, NASA is pursuing Star status in the Occupational Safety and Health Administration's 

(OSHA) Voluntary Protection Program (VPP). Participation in the VPP provides a mechanism 

for both improving internal safety practices and for utilizing the services of the OSHA programs 

to perform oversight inspections. To date the Langley Research Center and the Johnson Space 

Center have achieved Star status and have been recognized by OSHA. The other NASA Centers 

are in various stages of preparation for assessment by OSHA. 

6.3 New Activity 

The following section contains information on new federal agency conformity assessment 

activity as reported by the individual agencies. The information was taken directly from the 

reports the agencies submitted to NIST. 
41

6.3.1 Department of Commerce 

Telecommunications Certification Bodies (TCB) Program

In May 2000 NIST initially evaluated ANSI’s Conformity Assessment Program for compliance 

with ISO/IEC Guide 61 and the Federal Communications Commission requirements for its TCB 

program. Upon successful completion of an on-site assessment and two witness audits, NIST 

recognized ANSI’s Conformity Assessment Program for a period of two years. In May 2002, 

NIST re-evaluated ANSI and extended its recognition for two more years. 

National Information Assurance Partnership (NIAP)

NIST and the National Security Agency (NSA) have established a program under the National 

Information Assurance Partnership (NIAP) to evaluate IT product conformance to international 

standards. The program, officially known as the NIAP Common Criteria Evaluation and 

Validation Scheme for IT Security, or Common Criteria Scheme in abbreviated form, is a 

partnership between the public and private sectors. NAIP assessment programs are based on 

national and international IT security standards and criteria. The initial assessment programs 

will focus on the testing and evaluation of commercial IT products; follow-on programs will 

address the assessment of IT systems and networks to support the system certification and 

accreditation processes. Present IT product testing programs include the NIAP Common Criteria 

Evaluation and Validation Program (see more at http://niap.nist.gov/cc-scheme/) and the NIST 

Cryptographic Module Validation Program (see http://csrc.nist.gov/cryptval/). 

6.3.2 Department of Health and Human Services 

U.S. Food and Drug Administration

The Office of Regulatory Affairs laboratories are finalizing and implementing the new quality 

system in preparation for accreditation to ISO 17025. 

The Center for Biologics Evaluation and Research (CBER) laboratories that conduct official 

product testing are in the process of becoming ISO 17025 accredited. CBER has conducted 

initial staff training and is in the process of writing a Laboratory Quality Assurance Manual 

centrally documenting Center policies and procedures related to the official testing of regulated 

biological products. CBER is implementing a quality management software tool to assist in the 

effort, and has quality insurance managers to coordinate the implementation of an ISO 17025-

based quality system. 

In addition, CBER has recently initiated activities with a variety of organizations that may result 

in the development of standards mostly for cellular therapies and tissue products. These 

organizations include, the American Society for Reproductive Medicine, the American 

Association of Tissue Banks, and Eye Bank Association of America. 
42

CBER has also participated in a collaborative effort with other U.S. governmental and 

nongovernmental organizations, including the National Institute of Standards and Technologies, 

the National Cancer Institute, and the College of American Pathologists in developing reference 

material and guidance to test for the presence of Her2 gene protein. Consistent methodology for 

detecting Her2 neu gene protein is necessary for treatment of breast cancer with the therapeutic 

monoclonal antibody, trastuzumab (Herceptin). 

CBER also organized an Adenovirus Reference Materials Working Group that developed an 

adenoviral virus reference material. This material was developed in a unique collaborative effort 

with donations from multiple organizations and institutions. The reference material is used to 

define the particle unit and infectious units for adenovirus vectors used in gene therapy. 

Centers for Medicare and Medicaid Services (CMS)

Although CMS was involved in a limited number of conformity assessment activities to assure 

adherence by their contractors to the national health care payment standards, it is anticipated that 

these activities will increase significantly in future years. In addition, CMS participated in 

interagency efforts to harmonize health care standards implementation activities under the Health 

Insurance Portability and Accountability Act (HIPAA) with other federal agencies, including the 

Department of Defense, the Veterans Administration, and state Medicaid agencies. They also 

conducted a review of private sector certification services available that could assist in 

establishing a mechanism to better certify the use of health care standards by contractors. CMS 

contracted with Claredi to conduct certification reviews to evaluate compliance of the Medicare 

contractor implementation of HIPAA transaction standards in FY 2002. CMS also directed each 

of their contractors to conduct extensive internal testing of the programming for those 

implementations. 

CMS is also participating with the National Forum for Health Care Quality Measurement and 

Reporting in the endorsement of standards for performance measures of quality among various 

providers. This effort brings together all stakeholders to make a determination founded in a 

membership-driven consensus process and an evidence base for the subject matter. The various 

endorsements will occur over the next two years. 

6.3.3 Department of Transportation 

Federal Motor Carrier Safety Administration (FMCSA)

The FMCSA has used, or proposed, voluntary consensus standards agreed to by the Commercial 

Vehicle Safety Alliance’s Information Systems Committee to determine what data elements 

should be collected and coded into state and national inspection and crash files. The decisions 

agreed to by this committee affect state enforcement personnel, the trucking industry, and 

anyone using the safety data. As called for in Section 225 of the Motor Carriers Safety 

Improvement Act of 1999 (Public Law 106-159, 113 Stat. 1748), the FMCSA has worked with 

the National Highway Traffic Safety Administration and the states to adopt the Commercial 

Vehicle Analysis Reporting System. Since the beginning of calendar year 2001, an average of 
43

one staff member has participated in meetings with a number of states to gauge their 

commitment to participating in this new crash data collection approach. Although still in the 

pilot stage, the FMCSA asked states to ensure that certain crash data are reported in an accurate, 

timely, and complete manner. 

6.3.4 General Services Administration 

ISO SC 10 TC 29

The U.S. Technical Advisory Group (TAG) is responsible for determining the U.S. position on 

IEC/ISO standards pertaining to technical committee or subcommittees in addition to the review 

of policy matters. The standards include hand tools and accessories for safety requirements 

relating to the elements of design, use, and selection of performance, tolerances, and outline 

configurations of (including but not limited to) wrenches, pliers, screwdrivers, shears, punches, 

chisels, hammers, and toolboxes. The standards will include the development of requirements, 

the consideration of various types and classes of hand tools and accessories required for specified 

classes of service, and the tests needed to determine conformance with the service classification 

requirements. 

American Society of Mechanical Engineers (ASME), B107 Main Committee

GSA’s Hardware SuperStore is a member of the ASME B107 main committee relating to hand 

tools, and actively participates in the development of non-government procurement and safety 

standards. This committee is actively involved in maintaining and improving standards to assure 

customer requirements are satisfied. 

Tool Fastener Working Group

The goal of this group is to improve the performance of fastener systems by evaluating at the 

tool-fastener interface, in addition to creating a review committee to evaluate and improve nongovernment standards. 

Joint Group on Environmental Attribute (JGEnvAtt) meeting – GSA/ Department of Defense/ 

Other Federal Agency, HQ DLA, Fort Belvoir, Virginia

On February 21, 2002, GSA summarized to attendees the latest Hardware SuperStore’s efforts in 

delineating those FSC 8010 products that meet the definition of “Low-VOC.” We interfaced 

with key DOD and EPA personnel to learn of the latest efforts to delineate products with 

environmental attributes. We gathered and brought back references on the latest, four approved 

environmental attributes, of which “Low-Volatile Organic Compound” (Low-VOC) is one. 

National Defense Industrial Association/ Department of Defense 

From March 25 through March 28, 2002, GSA staff attended the 28th Annual Environmental 

Symposium and Exhibition sponsored by the Department of Defense in Charleston, South 
44

Carolina. GSA gathered detailed data on potential suppliers, and DOD/ Navy/ Marine Corps/ 

U.S. EPA environmental initiatives that affect our commodities. We learned of new 

environmental initiatives within the Department of Defense and were able to visit 110 

governmental and private booth exhibits, and interface with an estimated 150 Department of 

Defense customers. 

From August 19 through August 22, 2002, GSA attended the 7th Annual Joint Service Pollution 

Prevention Symposium and Exhibition sponsored by the Department of Defense. GSA created 

and presented a 20-minute presentation on how to identify and purchase “Low-Volatile Organic 

Compound (Low-VOC)” coatings from GSA. The presentation was attended by 40 people. We 

networked with over 100 customers, and visited over 200 private companies and government 

agency exhibits. 

National Aerospace Defense Contractors Accreditation Program (NADCAP)

NADCAP represents major prime contractors, suppliers, and government agencies in aerospace, 

defense, and related industries throughout the United States and internationally. NADCAP is 

administered by the Performance Review Institute (PRI), an independent, for-profit trade 

association affiliated with the Society of Automotive Engineers (SAE). Through NADCAP, PRI 

accredits subcontractors and suppliers to aerospace and industry consensus standards. Through 

NADCAP, PRI assures and enhances quality, saves valuable time and efforts, and cuts direct and 

overhead costs by performing the following functions: 

• Compiling audit criteria 

• Securing acceptance of these lists as internationally recognized ASE Aerospace 

Standards 

• Auditing suppliers’ technical capabilities and conformance to applicable procedures 

and/or government agencies 

• Focusing the responsibility for quality maintenance on the supplier and subcontractors 

• Publishing a qualified manufacturer’s list and making it available to prime contractors 

• Promoting the benefits of using accredited suppliers 

The GSA Hardware SuperStore is a prime member of the Sealants and Coating Groups and is a 

member of the Qualified Product Management Council. 

Society of Automotive Engineers (SAE) 

The GSA Hardware SuperStore is a member of the SAE, G8 – Aerospace Coatings Committee 

and G9 – Aerospace Sealants Committee, and actively participates in the development of 

Aerospace Material Standards. These committees are actively involved in the conversions of 

Military Specifications and the development of Aerospace Material Standards. 

The goal of the Chairman of the G8 – Laboratory Accreditation Sub-Committee is to develop a 

laboratory accreditation protocol consistent with ISO and IEC accreditation standards. This 

standard, AS5505, May 2001, provides interpretation of ISO/IEC 17025 and establishes 
45

additional requirements for accreditation of testing laboratories for evaluating organic coatings. 

This step was necessary for the development of the Qualified Manufacturers List program for 

G8 – Aerospace Coatings. 

Building Products Pre-Approval Program (BPPAP)

GSA/FSS sends a Hardware SuperStore representative to the Building Products Pre-Approval 

Program (BPPAP) Committee of the National Institute for Building Sciences, Washington, D.C. 

This committee coordinates the development of non-governmental architectural and industrial 

paint and coatings standards with the Master Painters Institute. Through this committee, more 

than 26 Federal Specifications and Commercial Item Descriptions have been replaced with 

Master Painters Institute Standards. 

The BPPAP committee, through Scientific Certifications Systems (SCS) (a third party, 

internationally recognized certification organization), is pursuing development of 

Environmentally Preferred Purchasing (EPP), and certification for products, mandated by 

Executive Order 13101. The BPPAP reviews and approves the protocol for EPP certification 

that SCS performs. 

 

USDA Forest Service

In April 2002, GSA attended a joint meeting with representatives from the USDA Forest Service 

Missoula and San Dimas Technology & Development Centers. We discussed new requirements 

for wildland fire suppression equipment and abolishing the practice of allowing third-party 

certification to NFPA standards for protective clothing and equipment. As a result, future GSA 

contractors for wildland fire fighter clothing and personal protective equipment will be required 

to be ISO registered. The requirement will be phased in over a period of approximately three 

years. 

GSA/FSS sends a Hardware SuperStore representative to the USDA, Forestry Service, Tree 

Marking Paint Standard Development Committee. The GSA provided expert consultation for 

environmental, health, and technical issues leading to development of the FS 2400-400 

specification. 

National Fire Protection Association (NFPA) Technical Committee on Wildland Fire Fighting 

Protective Clothing and Equipment

GSA attended the committee’s meetings in Seattle, Washington (May 2002), and Missoula, 

Montana (August 2002). As part of the revision process of the National Fire Protection 

Association’s (NFPA) Standard 1977 (Protective Clothing & Equipment for Wildland Fire 

Fighting), the government-unique requirements for the fire shelter will be dropped from the 

standard. A performance-based standard will be developed for inclusion in the following 

revision of NFPA 1977. A new government (Forest Service) specification for a new, improved 

design of the fire shelter is just now being implemented and it was determined that adequate 

performance data could not be developed in time for the upcoming revision of NFPA 1977. 
46

APPENDIX A--REPORTS OF CABINET-LEVEL DEPARTMENTS 

This section contains the actual reports of the various cabinet-level department reports as 

submitted to NIST. Due to the need to have this year’s information submitted via e-mail rather 

than through NIST’s online process, many different formats were used by the various 

departments to submit their information. Several departments chose not to address the voluntary 

questions 7, 8, and 9. The information in this section reflects NIST’s effort to present in a 

consistent format all of the data the departments chose to submit. The substantive text and 

numerical responses of each department’s report remains as submitted. 

The format NIST has chosen to present the submitted data is as follows: 

Name of Department 

1. Number of Government-Unique Standards used in lieu of Voluntary Consensus 

Standards. 

2. Number of Voluntary Consensus Standards substituted for Government-Unique 

Standards. 

3. Number of Voluntary Consensus Standards used in FY 2002. 

4. Number of agency employees participating in Voluntary Consensus Standards 

activities. 

5. List of Voluntary Consensus Standards Bodies in which there was agency 

participation. 

6. How agencies report their use of standards. 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for 

any changes. 

8. Conformity assessment activities in which agencies were involved. 

9. Examples or case studies of standards successes. 

10. Additional comments. 
47

Department of Agriculture

1. As required by P.L. 104-113, identification of all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards (for each instance, 

include agency rationale for such case, as well as the specific government-unique 

standard used and the voluntary consensus standard that was not selected). 

 0 

2. Identification of voluntary consensus standards that have been substituted for 

government-unique standards because of an agency review under section 15b (7) of the 

Circular. 

 0 

In those cases where USDA’s Agricultural Marketing Service (AMS) uses governmentunique standards, no voluntary consensus standards exist. 

The American Dairy Products Institute (ADPI) has published a series of milk and dry 

milk standards that can be used when USDA certification is not requested by the buyer or 

seller. These standards are based on the USDA standards and contain the same 

requirements. The majority of the dairy industry prefers the USDA certification because 

of its official certificate value. 

AMS also uses government-unique specifications for the School Lunch Program’s 

commodity purchases and other domestic feeding programs to meet the nutritional and/or 

program requirements. USDA develops unique specifications to meet the needs of the 

food program. USDA’s specifications may not be consistent with all commercial 

products in that they allow for less salt, fat, and sugar. 

3. The number of voluntary consensus standards that the agency has used during FY 2002, 

based upon procedures set forth in sections 11 and 12 of the Circular. 

 177 

4. The number of agency employees participating in voluntary consensus standards 

activities. 

 82 

5. The number of voluntary consensus standards bodies in which the agency participates by 

name and acronym. 

 51 
48

3A Sanitary Standards Program (domestic dairy equipment standards writing body). 

3A/NSF Meat and Poultry Equipment Standards (domestic meat and poultry equipment 

standards writing body). 

International Dairy Federation (international standards body) IDF. 

CODEX Committee on Milk and Milk Products (international standards body). A 

member of the Dairy Program serves as U.S. Delegate to this committee. 

American Society for Testing Materials (ASTM). 

International Standards Organization (ISO). 

 

Universal Standards Agreement. 

United Nations Economic Commission for Europe (UNECE) meetings of the Working 

Party on the Coordination of Standardization of Perishable Produce and Quality 

Development. A member of the Fruit and Vegetable Programs, Fresh Products Branch 

served as the Vice-Chair during the past year and was elected Chairman of the Working 

Party during the November 2002 meeting. 

UNECE Specialized Section on the Standardization of Fresh Fruits and Vegetables. A 

member of the Fruit and Vegetable, Fresh Products Branch served as Chairman of the 

2002 meeting. 

UNECE Specialized Section on the Standardization of Dry and Dried Fruit 

Codex Committee on Processed Fruits and Vegetables (CCPFV). A member of the 

Branch currently serves as Chairman of the CCPFV. 

Codex Committee on Fresh Fruits and Vegetables 

Codex Ad Hoc Task Force on Fruit & Vegetable Juices 

Codex Committee on Processed Fruits and Vegetables 

Codex Working Group on Certain Processed Vegetables 

Codex Working Group on Jams, Jellies, and Marmalades 

Codex Working Group on Canned Citrus Fruits 

American National Standards Institute (ANSI) Government Member Council (GMC). 

The Livestock and Seed Program is a member of the ANSI Government Member 
49

Council, which provides a forum for the discussion of government standards and 

conformity assessment issues as they relate to the American National Standards Institute 

and its members. Representatives of virtually every federal department participate in the 

ANSI GMC. 

United Nations/Economic Commission for Europe Committee for Trade Industry and 

Enterprise Development. Meeting of Experts for the Standardization of Meat, April 8-10, 

2002, Geneva, Switzerland. The Livestock and Seed Program is the Chair of this 

international committee that has representation on it from countries coming from North 

America, South America, Europe, and Asia. At the meetings earlier this year, the 

Committee adopted an international lamb cutting and quality standard. 

International Organization for Standardization (ISO) Technical Committee 176 for 

Quality Management and Quality Assurance 

ISO Technical Committee 34 for Food Products/Subcommittee 6 for Meat and Meat 

Products 

American Society for Testing and Materials (ASTM) International 

Industry-wide Cooperative Meat Identification Standards Committee (ICMISC). The 

ICMISC is a committee composed of industry, government, and academic representatives 

that maintains the voluntary standard nomenclature for retail labeling of beef, pork, lamb, 

and veal cuts. 

International Seed Testing Association (ISTA) 

Organization for Economic Co-operation and Development (OECD) Seed Schemes 

Poultry Program employees hosted the UN/ECE Committee for Trade Industry and 

Enterprise Development, Meeting of Experts for the Standardization of Meat, October 

29-31, 2001, Washington, DC. 

UN/ECE Committee for Trade Industry and Enterprise Development, Meeting of Experts 

for the Standardization of Meat, April 8-10, 2002, Geneva, Switzerland. 

UN/ECE Committee for Trade Industry and Enterprise Development, Meeting of Experts 

for the Standardization of Meat, September 16-18, 2002, Rennes, France. 

Meat and Poultry Business-to-Business Data Standards Organization (mpXML). This 

body is a not-for-profit industry corporation created to establish e-commerce standards 

for the meat and poultry supply chain. 

American National Standards Institute (ANSI) committee to update the “Accessible and 

Usable Building and Facilities” ICC/ANSI A117.1-2003. 
50

Access Board committee working to combine the two major federal standards, the 

Uniform Federal Accessibility Standards (UFAS) and American with Disabilities Act 

Accessibility Guidelines (ADAAG). 

Southern Building Code Congress International, Inc. (SBCCI) 

Building Officials and Code Administrators International, Inc (BOCA) 

International Conference of Building Officials (ICBO) 

Council of American Building Officials (CABO) 

National Fire Protection Association (NFPA) 

International Code Council (ICC) 

Federal Manufactured Housing Construction Safety Standard (FMHCSS) 

American Wood Preservers’ Association (AWPA) 

American Society of Civil Engineers (ASCE) 

American Concrete Institute (ACI) 

Prestressed Concrete Institute (PCI) 

American Welding Society (AWS) 

International Conference of Building Officials (ICBO) 

Uniform Building Code (UBC) 

Southern Pine Inspection Bureau (SPIB) 

West Coast Lumber Inspection Bureau (WCLB) Grading Rules 

Institute of Electrical and Electronics Engineers (IEEE) 

Insulated Cable Engineers Association (ICEA) 

Alliance for Telecommunications Industry Solutions (ATIS) Protection Engineers’ Group 

American Water Works Association (AWWA) 
51

6. Describe how your agency currently reports its use of voluntary consensus standards. 

Specifically, you should be prepared to answer the following questions: (Note: Questions 

will be structured on the Web entry database to accept either “Yes/No” or multiplechoice responses.) 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards or (3) both first time and continued uses of standards? 

 USDA reports continued uses of standards. 

b. Does your agency report (1) the total number of standards it uses or (2) each 

instance where the agency uses (i.e., references) a standard? 

 USDA reports total number of standards it uses. 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 USDA reports one standard used. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

 USDA reports both standards that it uses for guidance purposes and compliance 

purposed. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 No. 

7. An evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

USDA concurs that the standards policy stated in Circular A-119 is effective in reducing 

duplicate systems of standards. It effectively defines the role and coordinates the use of 

government-unique standards in the marketplace. 

8. No comment. 

9. No comment. 

10. No comment. 
52

Department of Commerce 

1. Number of government unique standards used in lieu of voluntary standards. 

0 

2. Number of voluntary consensus standards substituted for government unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 0 

4. Number of agency employees participating in voluntary consensus standards activities. 

 439 

5. Number of voluntary consensus standards bodies in which there is agency participation. 

 165 

6. Describe how your agency currently reports its use of voluntary consensus standards. 

 The Department of Commerce reported no use of voluntary consensus standards during 

 FY2002. 

7. Provide an evaluation of the effectiveness of Circular A-119 policy and recommendations 

for any changes. 

In general, NIST finds that the Circular provides satisfactory guidance to federal agencies 

regarding how to comply with PL 104-113. With regard to the definitions of “use” as it 

relates to federal agency use of voluntary consensus standards, NIST is leading the effort 

among member agencies of the ICSP to reach agreement on clarification of this term. 

Agreement within the ICSP on these clarifications should result in greater consistency in 

the data reported by federal agencies to NIST for inclusion in future annual reports. 

8. Provide the conformity assessment activities in which the agency has been involved. 

Telecommunications Certification Bodies (TCB) Program

In May 2000, NIST initially evaluated American National Standards Institute’s (ANSI’s) 

Conformity Assessment Program for compliance with ISO/IEC Guide 61 and the Federal 

Communications Commission (FCC) requirements for its TCB program. Upon 

successful completion of an on-site assessment and two witness audits, NIST recognized 
53

ANSI’s Conformity Assessment Program for a period of two years. In May 2002, NIST 

re-evaluated ANSI and extended its recognition for two more years. 

ANSI evaluates prospective TCBs for compliance with ISO/IEC Guide 65 and FCC 

requirements for the TCB program. FCC requires that a TCB must have core testing 

capability and that the testing laboratory must be accredited to ISO/IEC Standard 17025. 

NIST recommends thus accredited organizations to FCC for designation as TCBs. 

NIST Committee Participation

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

Conformity Assessment Committee (ICAC), which serves as the U.S. Technical 

Advisory Group (TAG) to ISO's Council Committee on Conformity Assessment 

(CASCO). SSD staff also participates in CASCO Working Group 25 on alignment of 

ISO/IEC 17025 with ISO 9000/2000, Working Group 22 on a code of good practice for 

conformity assessment, and Working Group 20 on the revision of ISO/IEC Guide 7 on 

the inclusion of conformity assessment requirements in standards. Further, SSD staff is 

active in a CASCO ad hoc group on Regulators Interface and in working groups of the 

International Accreditation Forum (IAF). 

NIST/SSD personnel serve on the ANSI committee that is responsible for accrediting 

certification bodies and on the U.S. National Committee to the IECEE (IEC System for 

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

scheme that allows manufacturers to obtain a test certificate from an approved U.S. 

National Certification Body (NCB) and to use this test report to obtain certification marks 

in other participating countries. 

NIST/SSD also participates in the U.S Technical Advisory Group (TAG) to ISO TC 176, 

the ISO committee responsible for the development and maintenance of the ISO 9000 

standards series, and in American Society for Quality (ASQ) Z-1, the U.S. committee 

responsible for adoption of the ISO 9000 series as U.S. national standards. 

The Chief of NIST/SSD serves as the Chair of the ANSI-Registrar Accreditation Board 

(RAB) National Accreditation Program (NAP) Environmental Management Systems 

(EMS) Council. The Council is responsible for accrediting registrars that assess facilities 

for conformance to the ISO 14001 standard. 

 

NIST/SSD has published a number of directories and reports on conformity assessmentrelated issues and maintains a Web site (http://www.ts.nist.gov/ca) that provides a onestop-shopping source for information on various conformity assessment issues. 

National Cooperation for Laboratory Accreditation (NACLA)

Section 12b of the National Technology Transfer and Advancement Act (NTTAA) of 

1995 directed NIST to coordinate conformity assessment activities of federal, state, and 
54

local entities to eliminate any unnecessary duplication of conformity assessment 

activities. In response, NIST has been a driving force behind the creation of NACLA. 

NACLA is composed of organizations in the United States, with observers from Mexico 

and Canada that actively support development of a system for recognizing the 

competence of testing and calibration laboratories leading to worldwide acceptance of 

test and calibration reports from those laboratories. Concerned with costly, multiple, 

duplicate assessments, and the lack of domestic or international recognition of laboratory 

accreditations, the group has explored solutions that could lead the United States, and 

perhaps eventually its North American Free Trade Agreement (NAFTA) partners, toward 

the goal of having only one assessment of a laboratory in a given field of testing, based 

on internationally accepted procedures. The NACLA vision is for a U.S. laboratory 

accreditation system that achieves the following goals: 

● For the testing laboratory, a single accreditation in a given field of testing, with 

worldwide recognition of the laboratory's competence. 

● For the manufacturer/supplier, a test performed once, with worldwide 

acceptance. 

● For the acceptance body (that is a government agency or an industry specifier); 

an accreditation based on uniform criteria and intended to ensure that a laboratory 

is qualified to provide data of consistent quality. 

In the past year, NACLA continued to improve its program and to take appropriate 

actions to align with the evolving international system for recognition of competent 

accreditation bodies. Some milestones during the period include the following: 

● Adoption of a new version (Revision D) of the NACLA Recognition Procedure. 

The revision incorporates several procedural improvements that have been 

developed by the International Laboratory Accreditation Cooperation (ILAC). 

● A meeting of NACLA officials with officials of the Asia Pacific Laboratory 

Accreditation Cooperation (APLAC) to discuss ways that the two organizations 

might cooperate, to the benefit of both. 

● Recognition of an additional U.S. accreditation body: the American Industrial 

Hygiene Association (AIHA). There are now four accreditation bodies 

recognized by NACLA. 

● Sponsorship of the first National Forum on Laboratory Accreditation. The 

event was well attended and well received. The second annual Forum is 

scheduled for March 2003. 

The Standards Services Division Chief is a member of the NACLA Operations Council 

and chairs the NACLA International Affairs Committee. Under the NIST-NACLA 

Memorandum of Understanding, signed July 2000, NIST recognizes NACLA as a 

suitable private sector alternative to NIST’s National Voluntary Conformity Assessment 

System Evaluation (NVCASE) program. NIST relies on NACLA recognition of 

qualified accreditation bodies in support of NIST responsibilities as a designating 

authority under the U.S.-European Union Mutual Recognition Agreement (MRA), the 
55

APEC Telecommunications MRA, and the CITEL MRA. More than 100 laboratories 

have been designated as Conformity Assessment Bodies (CABs) under the provisions of 

the U.S.-EU and APEC MRAs, pursuant to this MOU. 

National Voluntary Laboratory Accreditation Program – NIST/SSD’s National Voluntary 

Laboratory Accreditation Program (NVLAP) operates in conformance with ISO Guide 58 

and accredits calibration and testing laboratories to ISO/IEC 17025. NVLAP operates 

programs in support of several federal agencies, including the Department of Energy, the 

Nuclear Regulatory Commission, the Food and Drug Administration, the Department of 

Defense, the Environmental Protection Agency, the Federal Communications 

Commission, and in support of state and local governments. 

National Information Assurance Partnership (NIAP) – NIST and the National Security 

Agency have established a program under the National Information Assurance 

Partnership (NIAP) to evaluate IT product conformance to international standards. The 

program, officially known as the NIAP Common Criteria Evaluation and Validation 

Scheme for IT Security or Common Criteria Scheme in abbreviated form, is a partnership 

between the public and private sectors. NAIP assessment programs are based on national 

and international IT security standards and criteria. The initial assessment programs will 

focus on the testing and evaluation of commercial IT products; follow-on programs will 

address the assessment of IT systems and networks to support the system certification 

and accreditation processes. Present IT product testing programs include the NIAP 

Common Criteria Evaluation and Validation Program (see more at http://niap.nist.gov/ccscheme/) and the NIST Cryptographic Module Validation Program (see 

http://csrc.nist.gov/cryptval/). 

9. Provide Any Examples or Case Studies of Standards Successes: 

U.S. Smart Card Interoperability Specifications 

The federal government is expanding smart card use among federal employees because of 

the security features and inherent versatility of smart cards. For example, a single smart 

card could be used as an identification card, to provide access to secure buildings, to 

securely logon to computer systems, and to make small purchases. However, the federal 

government has been reluctant to use smart cards on a large scale primarily due to the 

lack of interoperability among smart card products. 

Scientists in NIST ITL’s Computer Security Division have been working with the 

General Services Administration, other federal agencies, and industry partners for the 

past several years to establish a Government Smart Card (GSC) program to facilitate 

widespread deployment of interoperable smart card systems. Specifically, ITL set out to 

build a framework for smart card interoperability, enabling broad adoption of this critical 

technology by the public and private sectors. The mechanism and technical foundation 

for this framework is the Government Smart Card Interoperability Specification (GSCIS). The GSC-IS version 2.0 was published on June 27, 2002, as NISTIR 6887. (See 

more at http://smartcard.nist.gov.) 
56

The GSC-IS lays the groundwork for smart cards to work in an open environment. It 

defines an architectural model for interoperable smart card service provider modules, 

compatible with both file system cards and virtual machine cards, which allows smart 

card application developers to obtain various services (e.g., encryption, authentication, 

digital signatures, etc.) from GSC-compliant smart cards through a common, 

interoperable smart card services interface. 

First IEEE Wireless Personal Area Network (802.15) Standard

ITL contributed significantly to a new standard for wireless personal area networks 

(WPANS) approved by the Institute of Electrical and Electronics Engineers (IEEE) on 

March 21, 2002 (http://standards.ieee.org/announcements/802151app.html). The 

approval of IEEE 802.15.1 was the long-awaited formal acceptance of the Bluetooth 

Special Interest Group (SIG) Core Specification by a recognized standards body. 

Although the Bluetooth Core Specification defines all the layers from physical layer to 

the application layer, only the lower layers, which are considered within the scope of the 

IEEE 802 Medium Access Control and Physical layers, are included. This wireless 

technology operates in the 2.4 GHz frequency band and provides voice communications 

at 64 bit/s and data transfers up to 732 kbit/s at distances up to ten meters. The 

technology is meant to be inexpensive, thus positioning itself for system integration as 

one of the pervasive computing technologies. 

Interactive Digital Television Standard

The Advanced Television System Committee (ATSC), an international industry 

consortium of more than 200 members consisting of broadcasters, content creators, 

software vendors, and equipment manufacturers, announced at its October 2001 meeting 

that the DTV Application Software Environment (DASE) standard was approved. DASE 

is the North America middleware standard for broadcast interactive television. NIST and 

the DASE specialist group are developing these standards in advance of widespread use 

of digital television technology. The NIST open reference implementation of the DASE 

standard provides application developers and consumer electronic manufacturers an 

application development environment and a basis for an interoperable Digital TV 

receiver implementation. 

The NIST implementation was a deciding factor in the final approval of the DASE 

standards documentation. Because of the complexity and size of this forward-looking 

standard, industry participants requested that ATSC demonstrate that DASE could, in 

fact, be implemented. The ATSC membership voted, by a clear majority, that this 

requirement was satisfied by the NIST Procedural (Java) Application Environment 

implementation and the Samsung Declarative Application Environment implementation. 

The interactive digital television community has been very responsive to the NIST 

prototype implementation. Over 800 copies of the software have been downloaded since 

its release, announced in June at the 2001 DASE Symposium held at NIST. The NIST 

implementation is an enormous undertaking, consisting of over 100,000 lines of JavaTM 
57

code. The NIST environment provides not only the DASE implementation, but also an 

ATSC DTV receiver simulation and DASE reference applications. This is a major 

accomplishment for the digital TV industry, as all analog transmission is mandated by the 

FCC to be digital in 2007. 

10. Comments. 

The Department of Commerce encourages its staff to participate in standards committee 

activities relating to the mission of the Department, subject to resource availability. 

Agency employees participate in the standards development activities of U.S. private 

sector standardization bodies; local, state, and federal governments; and both private and 

governmental (treaty and non-treaty) international standardization organizations. 

Standards of interest to the Department cover a broad range of technical areas including: 

(1) energy conservation, (2) information and computer technology, (3) 

telecommunications, (4) environmental safety and health, (5) meteorological work, and 

(6) a variety of other product sectors and fields of technology. 

The Standards Committee Participation (SCP) Database maintained by NIST collects and 

disseminates information on DOC staff participation in standards development activities. 

NIST publishes an annual directory containing statistics on all DOC standards committee 

participation as well as alphabetical listings of staff participants and standards 

organizations and committees. 

Four hundred thirty-nine DOC staff participated in the standards writing activities of 170 

(112 national and 58 international) standards developing organizations. Because of the 

volume of NIST participants relative to the remaining DOC agencies, the DOC standards 

participant information contained in the SCP Database is divided into two parts -- NIST 

and other (non-NIST) DOC agencies. Therefore, the data presented below is separated 

accordingly. 
58

 NIST Participation

NIST had 387 participants in the activities of 139 standards organizations. NIST 

participated on 451 committees and held 1,270 memberships on these committees. Ten 

of the standards organizations in which NIST staff members participated had 20 or more 

NIST memberships. 

Listed below are 12 standards organizations and the American National Standards 

Institute (ANSI) in which NIST holds at least 20 committee memberships. These 

organizations/agencies accounted for 74 percent (965) of the 1,302 NIST committee 

memberships: 

Organizations with NIST Members

Committee 

Memberships

American Society for Testing and Materials 530 

American National Standards Institute 101 

International Organization for Standardization 65 

Institute of Electrical and Electronic Engineers 45 

American Society of Mechanical Engineers 43 

International Electrotechnical Commission 39 

CIE (International Commission on Illumination) 30 

American Concrete Institute 23 

International Organization of Legal Metrology 23 

Telecommunications Industry Association 23 

Telecommunications Industries of America 23 

CGPM (Conférence Générale des Poids et Mesures) 20 

NCITS (National Committee for Information Technology 

Standards) 20 

Total 965 

 Other Department of Commerce Participation

Fifty-two staff members of other DOC agencies participated in 51 committees of 

26 standards organizations. They held 94 memberships on those committees. Nine of 

those standards organizations had five or more other DOC participants. 
59

The following organizations/agencies accounted for the 94 committee memberships held 

by DOC agencies other than NIST: 

Organization # of Memberships Percentage 

ANSI 11 11.7% 

INCITS 8 8.5% 

ISO 8 8.5% 

FCMSSR 7 7.4% 

DOD/FAA/DOC 6 6.4% 

ITU-R 6 6.4% 

TIA 6 6.4% 

DOS 5 5.3% 

IEEE 5 5.3% 

IHO 4 4.3% 

ICA 3 3.2% 

ITU-T 3 3.2% 

SAE 3 3.2% 

WMO 3 3.2% 

ASTM 2 2.1% 

ICAO 2 2.1% 

USGS 2 2.1% 

WIPO 2 2.1% 

ACSM 1 1.1% 

ATA 1 1.1% 

DOD 1 1.1% 

DOI 1 1.1% 

NATO 1 1.1% 

NCS 1 1.1% 

NOAA 1 1.1% 

RTCA 1 1.1% 

 Total 94 100% 
60

DOC AGENCIES (EXCLUDING NIST): SUMMARY OF STANDARDS-RELATED 

ACTIVITIES 

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

committees, one ICAO committee and one committee of the U.S.-Russia Working Group 

Standards for Chemicals. This year, ITA’s work in standards furthered toy safety 

standardization and international civil aviation standards adoption and acceptance 

worldwide. 

National Oceanic and Atmospheric Administration (NOAA) – Standardization of data 

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

seeks to establish voluntary standards with selected industrial associations, academia, and 

national organizations of state and local governments (e.g., the American Association of 

State Climatologists), as well as through participation in professional societies (e.g., 

American Meteorological Society). All NOAA line organizations participate in standards 

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

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

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

Committee) either through joint participation in international organizations such as the 

World Meteorological Organization, or by means of bilateral and multilateral agreements 

with other nations. These standardization activities apply to all phases of environmental 

data acquisition, processing, and distribution. 

National Telecommunications and Information Administration (NTIA) – The NTIA 

contributes to the development and application of national and international 

telecommunication standards by participating and holding leadership roles in various 

voluntary standards committees at the national and international levels (e.g., 

Telecommunications Industry Association, International Telecommunication Union). 

These standards enhance the quality and reliability of the domestic telecommunications 

infrastructure, promote healthy competition in telecommunications products and services, 

and expand international trade opportunities for U.S. telecommunications firms. 

United States Patent and Trademark Office (USPTO) – The USPTO participates and 

contributes to the resolution of identified requirements for international standards, 

primarily through the Standing Committee on Information Technologies of the World 

Intellectual Property Organization. USPTO staff also participates in standardization 

activities of the International Patent Classification Union and the ANSI-Accredited 

Committee on Patent Standards. 

Bureau of the Census – DOC’s Bureau of the Census is active in the development of 

standards and specifications for: (1) the capture and storage of geographic information in 

computer-readable formats along with metadata documenting the characteristics of those 

data; and (2) the definitions of statistical, economic, and geographic terms. The Census 

Bureau participated in the following groups in FY 2000: Federal Geographic Data 
61

Committee -- various subcommittees and working groups; ANSI/NCITS-L1 Geographic 

Information Systems; ISO Technical Committee 211; Ad hoc Baseline Committee on the 

U.S. International Boundary; U.S.G.S. Spatial Data Transfer Standards (SDTS) Technical 

Review Board; International Cartographic Association, Commission on National and 

Regional Atlases; U.S.G.S. National Atlas of the United States Steering Committee; and 

the Open GIS Consortium (OGC). 

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

U.S. focal point for standards-related information at home and abroad; it provides 

information on U.S., foreign, regional, and international voluntary standards bodies; 

mandatory government regulations; and conformity assessment procedures for 

nonagricultural products. NCSCI maintains an extensive collection of reference 

materials, including U.S. military and other federal government specifications, U.S. 

industry and national standards, international standards, and selected foreign national 

standards. Staff members respond to requests for specialized standards information, 

provide contact points for translations of foreign standards and regulations, and 

disseminate information to U.S. industry concerning proposed foreign regulations and 

general standards issues. 

In direct response to U.S. obligations resulting from the World Trade Organization 

(WTO) Agreement on Technical Barriers to Trade (TBT Agreement) and NAFTA, 

NCSCI serves as the U.S. national inquiry point responsible for responding to questions 

concerning U.S. standards, technical regulations and conformity assessment procedures. 

NCSCI also serves as the U.S. member of the International Organization for 

Standardization (ISO) Information Network (ISONET). NCSCI, with other national 

WTO and NAFTA inquiry points and ISONET members, is part of a network that 

regularly exchanges standards-related information and has access to foreign trade-related 

technical standards, regulations, and conformity assessment procedures. 

Signatories to the WTO TBT Agreement are required to notify the WTO Secretariat in 

Geneva of proposed technical regulations that could affect trade and provide a 

recommended 60-day comment period to allow other WTO Members to review and 

comment on the proposals. NCSCI staff receive copies of the one-page notifications and 

disseminate them at no charge through a Web-based subscription service called Export 

Alert! NCSCI also acquires the full text of the proposed technical regulations from the 

relevant foreign inquiry point. NCSCI staff is also responsible for notifying the WTO 

Secretariat of proposed U.S. technical regulations that may affect trade. 

Federal Information Processing Standards (FIPS) – FY2002 – Under the Information 

Technology Management Reform Act (Public Law [P.L.] 104-106), the Secretary of 

Commerce approves standards and guidelines that are developed by NIST for federal 

computer systems. Under Section 513 of the Information Technology Management 

Reform Act of 1996, the Computer Security Act of 1987, P.L. 104-106, and the Federal 

Information Security Management Act (FISMA), NIST develops standards, guidelines, 

and associated methods and techniques for federal computer systems. This includes 
62

standards and guidelines needed to ensure the cost-effective security and privacy of 

sensitive information in federal computer systems, when there are compelling federal 

requirements and there are no existing voluntary industry standards. These standards and 

guidelines are issued by NIST as FIPS for use government-wide. FIPS address federal 

requirements for the interoperability of different systems, for the portability of data and 

software, and for computer security. When FIPS are considered necessary, NIST 

announces proposed FIPS in the Federal Register for public review and comment. 

During FY 2002, NIST made the following FIPS announcements: 

● December 2001 – NIST announced the Secretarial approval of FIPS 197, 

Advanced Encryption Standard (AES). The AES provides a sound technical 

specification for encrypting and decrypting data. It is to replace FIPS 46-3, Data 

Encryption Standard, which has been in use for more than 20 years. 

● March 2002 – NIST announced the Secretarial approval of FIPS 198, KeyedHash Message Authentication Code (HMAC). The HMAC is an essential 

component of a comprehensive group of cryptographic techniques that federal 

agencies need to protect data, communications, and operations. 

● August 2002 – NIST announced the Secretarial approval of FIPS 180-2, Secure 

Hash Standard (SHS), a revision of FIPS 180-1. The SHS was revised to address 

advances in technology since FIPS 180-1 was issued in 1992 to provide federal 

agencies and departments with an updated technical standard for use with FIPS 

197, Advanced Encryption Standard. 

● August 2002 – NIST announced the Secretarial approval of changes to FIPS 

186-2, Digital Signature Standard (DSS). The purpose of this change was to 

expand the DSS by specifying two voluntary industry standards for generating 

and verifying digital standards. 
63

Department of Defense 

1. Number of government-unique standards used in lieu of voluntary standards. 

 The Department of Defense reports voluntary consensus standards usage on a categorical 

basis; therefore, this information is not available. 

 

2. Number of voluntary consensus standards substituted for government-unique standards. 

 64 

 

Voluntary Standard Government–Unique Standard 

SAE-AS35411 MIL-F-35411 

SAE-AMS6322 MIL-S-6049 

SAE-AMS6325 MIL-S-6049 

SAE-AMS6470 MIL-S-6709 

SAE-AMS6472 MIL-S-6709 

SAE-AS7413 MIL-C-7413 

SAE-AMS6444 MIL-S-7402 

SAE-AMS6447 MIL-S-7402 

SAE-J24714 MIL-C-24714 

NASM45595 MIL-W-45595 

SAE-AMS-R-83285 MIL-R-83285 

SAE-AMS-R-8412 MIL-R-8412 

SAE-AMS-R-83845 MIL-R-83845 

SAE-AMS5511 MIL-S-4043 

NASM4751 MIL-C-4751 

NAS838 MIL-C-5501 

NAS842 MIL-C-5501 

ASTM438 MIL-B-5687 

ASTM439 MIL-B-5687 

SAE-AMS5542 MIL-N-7786 

NAS9307 MIL-DTL-7885 

NAS9308 MIL-R-7885 

NAS9310 MIL-DTL-7885 

NAS9311 MIL-DTL-7885 

NAS9312 MIL-DTL-7885 

SAE-AMS5121 MIL-S-7947 

SAE-AMS5046 MIL-S-7952 

SAE-AMS1424 MIL-A-8243 

SAE-AS13572 MIL-S-13572 

NEMA-HP3 MIL-W-16878 

NASM25049 MIL-K-25049 

SAE-AS85421 MIL-F-85421 
64

SAE-AS85421/1 MIL-F-85421/1 

SAE-AS85421/2 MIL-F-85421/2 

SAE-AS85421/3 MIL-F-85421/3 

SAE-AS85421/4 MIL-F-85421/4 

SAE-AS85421/5 MIL-F-85421/5 

SAE-AS85421/6 MIL-F-85421/6 

SAE-AS85421/7 MIL-F-85421/7 

SAE-AS85421/8 MIL-F-85421/8 

SAE-AS85421/9 MIL-F-85421/9 

SAE-AS85421/10 MIL-F-85421/10 

SAE-AS85421/11 MIL-F-85421/11 

SAE-AS85421/12 MIL-F-85421/12 

SAE-AS85421/13 MIL-F-85421/13 

SAE-AS85421/14 MIL-F-85421/14 

SAE-AS85421/15 MIL-F-85421/15 

SAE-AS85421/16 MIL-F-85421/16 

SAE-AS85421/17 MIL-F-85421/17 

SAE-AS21150 MS21150 

SAE-AS21151 MS21151 

SAE-AS21152 MS21152 

SAE-AS21153 MS21153 

NASM21382 MS21382 

NASM21383 MS21383 

NASM22384 MS21384 

NASM21385 MS21385 

NASM21386 MS21386 

NASM21387 MS21387 

PIA-PS22002 MS22002 

PIA-PS22003 MS22003 

PIA-PS22010 MS22010 

PIA-PS22019 MS22019 

PIA-PS22020 MS22020 

SAE-J20 ZZ-H-428 

3. Number of voluntary consensus standards used in FY 2002. 

 53 

 During FY 2002 DoD used on a first-time basis (adopted) 53 voluntary consensus 

standards. The total number of voluntary consensus standards available for use in the 

DoD document inventory numbers 8914. 

4. Number of agency employees participating in voluntary consensus standards activities. 

 461 
65

5. List by name and acronym of voluntary consensus standards bodies in which DoD 

participated during the reporting period. 

109 

Aerospace Industries Association - AIA 

Air Conditioning & Refrigeration Institute - ARI 

Air Movement and Control Association - AMCA 

Alliance for Telecommunications Industry Solutions - ATIS 

Aluminum Association - AA 

American Architectural Manufacturers Association - AAMA 

American Association of Textile Chemists and Colorists - AATCC 

American Bearing Manufacturers Association - ABMA 

American Boat and Yacht Council - ABYC 

American Concrete Institute - ACI 

American Conference of Governmental Industrial Hygienists - ACGIH 

American Dental Association - ADA 

American Gear Manufacturers’ Association - AGMA 

American Hardboard Association - AHA 

American Industrial Hygiene Association - AIHA 

American Institute of Aeronautics and Astronautics - AIAA 

American Institute of Steel Construction - AISC 

American Institute of Timber Construction - AITC 

American Leather Chemists Association - ALCA 

American National Metric Council - ANMC 

American National Standards Institute - ANSI 

American Petroleum Institute - API 

American Railway Engineering & Maintenance-of-Way Assoc. - AREMA 

American Society for Nondestructive Testing - ASNT 

American Society For Quality - ASC 

American Society for Testing and Materials - ASTM 

American Society of Cinematographers - ASC 

American Society of Civil Engineers - ASCE 

American Society of Heating, Refrigerating, and Air-Conditioning Engineers - ASHRAE 

American Society of Mechanical Engineers – ASME 

American Society of Sanitary Engineering - ASSE 

American Water Works Association - AWWA 

American Welding Society - AWS 

American Wood Preservers Association - AWPA 

APA-The Engineered Wood Association - APA 

Architectural Woodwork Institute - AWI 

Association for the Advancement of Medical Instrumentation - AAMI 

BOCA International - BOCA 

Builders Hardware Manufacturers Association - BHMA 
66

Canadian General Standards Board - CGSB 

Cast Iron Soil Pipe Institute - CISPI 

Compressed Gas Association - CGA 

Construction Specifications Institute - CSI 

Cooling Technology Institute - CTI 

Cordage Institute - CI 

Data Interchange Standards Association, Inc. - DISA 

Deep Foundations Institute - DFI 

Electronic Components Assemblies & Materials Association - ECAMA 

Electronic Industries Alliance - EIA 

Electrostatic Discharge Association - EDA 

Government Electronics & Information Technology Association - GEITA 

Hardwood Plywood & Veneer Association - HPVA 

High Frequency Industry Association - HFIA 

Human Factors and Ergonomics Society, Inc. - HFES 

IDE Alliance (formerly The Graphic Communications Association) - IDEA 

Illuminating Engineering Society of North America - IESNA 

Information Technology Industry Council - ITIC 

Institute for Interconnecting and Packaging Electronic Circuits - IPEC 

Institute of Clean Air Companies - ICAC 

Institute of Electrical and Electronics Engineers - IEEE 

Institute of Environmental Sciences & Technology - IEST 

Insulated Cable Engineers Association - ICEA 

International Association of Plumbing and Mechanical Officials - IAPMO 

International Committee for Information Technology Standards - ICITS 

International Electrotechnical Commission - IEC 

International Organization For Standardization - IOS 

Internet Engineering Task Force - IETF 

Joint Electron Device Engineering Council - JEDEC 

Magnetic Materials Producers Association - MMPA 

Manufacturers Standardization Society of the Valve and Fittings Industry - MSSVFI 

Master Painters Institute - MPI 

NACE International - NACE 

National Association of Architectural Metal Manufacturers - NAAMM 

National Association of Relay Manufacturers - NARM 

National Electrical Manufacturers Association - NEMA 

National Fire Protection Association - NFPA 

National Fluid Power Association - NFPA 

National Hardwood Lumber Association - NHLA 

National Information Standards Organization - NISO 

National Institute of Building Sciences - NIBS 

National Petroleum Management Association - NPMA 

NSF International - NSFI 

Parachute Industry Association - PIA 

Plumbing and Draining Institute - PDI 
67

Plumbing-Heating-Cooling Contractors Association - PHCCA 

Quarter-Inch Cartridge Drive Standards, Inc. - QICDS 

Resistance Welders Manufacturers Association - RWMA 

Rubber Manufacturers Association - RMA 

SAE International – SAEI 

Scientific Apparatus Makers Association - SAMA 

Sheet Metal & Air Conditioning Contractors National Association - SMACC 

Simulation Interoperability Standards Organization - SISO 

Society for Protective Coatings - SPC 

Society of Allied Weight Engineers - SAWE 

Standards Engineering Society - SAE 

Steel Door Institute - SDI 

Steel Founders Society of America - SFSA 

Steel Window Institute - SWI 

The Open Group - TOG 

The Soap and Detergent Association - SDA 

The Tire and Rim Association, Inc. - TRA 

TIA - TIA 

Truck Trailer Manufacturers Association - TTMA 

UN Centre for Facilitation of Procedures & Practices for Administration, Commerce & 

 Transport - UNCFPPACT 

Underwriters Laboratories - UL 

Western Wood Products Association - WWPA 

Window and Door Manufacturers Association - WDMA 

Workflow Management Coalition - WMC 

World Wide Web Consortium – WWWC 

6. DoD reports use of voluntary consensus standards in the following manner: 

 a. DoD reports the first-time use of standards during the specified time frame. 

 b. DoD reports the total number of standards available for use. 

c. DoD reports each edition (slash sheet) of a single standard as a separate document. 

 d. DoD does not report standards used for guidance purposes. 

e. DoD reports documents developed by all standards organizations (both ANSI 

accredited and non-accredited). 

7. The A-119 policy does mandate that government agencies review at least once a year 

their respective voluntary consensus standards programs. This mandate is an excellent 

means of determining if agencies are relying on government-unique standards to a greater 

extent than is necessary. The Department, however, is not certain that all agencies are 

employing the same criteria to report voluntary consensus standards usage. The 

Department recommends a committee draft language explaining the term “usage” and 

forward this language to OMB for inclusion in the next revision of A-119. 

8. No comment. 
68

9. No comment. 

10. No comment. 
69

Department of Education 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 0 

3. The number of voluntary consensus standards that your agency used during FY 2002 

based upon procedures set forth in sections 11 and 12 of the Circular. 

 17 

Note: The number of standards used has greatly increased from last year because we are 

now counting the number of consensus standards used to support issuance of section 

5(a)(1) (General Duty clause of the OSH Act) violations. In most cases, the consensus 

standard used is a more current version of a consensus standard that has been 

incorporated by reference in the OSHA standards or a consensus standard addressing an 

area not specifically covered by an OSHA standard. 

4. The number of agency employees participating in voluntary consensus standards 

 activities during this period. 

 2 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

1 

 ASC X12 Committee 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

 

a. No response. 

b. No response. 

 

c. No response. 
70

d. No response. 

e. No response. 

 

7. No response. 

8. No comment. 

9. No comment. 

10. Since 1989, the U.S. Department of Education’s National Center for Education Statistics 

(NCES) has been actively working with the American National Standards Institute 

(ANSI) on developing Electronic Data Interchange (EDI) transaction sets through the 

Accredited Standards Committee (ASC) X12 committee to electronically convey 

administrative educational information between educational agencies. This effort is now 

known as the Standardization of Postsecondary Education Electronic Data Exchange 

(SPEEDE) and Exchange of Permanent Records Electronically for Students and Schools 

(ExPRESS) Project. SPEEDE/ExPRESS represents the combined efforts of many 

organizations focused upon the development of ANSI ASC X12 Electronic Data 

Interchange Standards for Education. For more information, please visit 

http://nces.ed.gov/edi/speedeExp.asp. The following are ANSI Transaction Sets that are 

of interest to the Educational Community. Each of the transaction sets described below 

should be wrapped in electronic envelopes that provide routing, time stamp, and security 

information. These envelopes consist of the ISA/IEA and GS/GE Control Segments. In 

addition to the transactions sets listed, Transaction Set 997 - Functional Acknowledgment 

is an integral part of the EDI process. For more information, please visit 

http://nces.ed.gov/edi/tstable.asp Transaction Sets Relating to Individual Student Records 

* TS 130 - Student Educational Record (Transcript) * TS 131 - Student Educational 

Record (Transcript) Acknowledgment * TS 138 - Testing Results Request and Report * 

TS 146 - Request for Student Educational Record (Transcript) * TS 147 - Response to 

Request for Student Educational Record (Transcript) * TS 189 - Application for 

Admission to Educational Institutions * Implementation Guides are available at 

http://nces.ed.gov/edi/IGs.asp Transaction Sets Relating to Human Resource Data * TS 

132 - Human Resource Information Transaction Sets Relating to Student Financial Aid 

Records * TS 135 - Student Loan Application * TS 139 - Student Loan Guarantee Result 

* TS 144 - Student Loan Transfer and Status Verification * TS 190 - Student Enrollment 

Verification * TS 191 - Student Loan Pre-Claims and Claims Transaction Sets Relating 

to Institutional Records * TS 133 - Educational Institution Record * TS 152 - Statistical 

Government Information used to transmit CCD, IPEDS and Library surveys to NCES * 

TS 188 - Educational Course Inventory. 
71

Department of Energy 

Standards Management: The Department of Energy (DOE) implements the federal 

guidance and requirements of OMB Circular A-119 (OMB A-119) and the statutory 

requirements of Public Law (PL) 104-113 (15 USC 272) on the use of voluntary 

consensus standards (VCSs) through specific departmental directives (policies, orders, 

requirements, guides, and technical standards) and supporting programs and management 

systems. The Department’s Integrated Safety Management System (ISMS - Internet 

address is http://tis.eh.doe.gov/ism/) establishes the overall business processes for DOE 

and its contractors to incorporate management of DOE’s environment, health, and safety 

matters for workers and the public as an integral part of our technical and business 

management, using standards as one of its primary tools. 

DOE’s overall standards activities are managed through a Technical Standards Program 

(TSP), established under the DOE Standards Executive. (The TSP Internet address is 

http://tis.eh.doe.gov/techstds/). The TSP provides the means for DOE to implement fully 

the policy and requirements of PL 104-113 and OMB A-119, and establishes a focus 

from which to promote the use of VCSs across DOE and to support active participation 

with Standards Development Organizations (SDOs). The TSP also manages the 

development of DOE internal standards where SDO standards are not available to meet 

unique DOE technical needs, and cannot be readily developed by an SDO. The TSP has 

processes for converting DOE Technical Standards to VCSs, including continuing 

initiatives with ASCE, ANS, and ASTM. 

 

The TSP also charters “Topical Committees” (TCs) that coordinate on standards 

development activities in specific technical areas across DOE, with other federal 

agencies, and with national and international SDO counterparts. The TCs are comprised 

of subject matter experts from across the DOE community, and encompass such diverse 

areas as laboratory accreditation, metrology, fire protection, environmental management 

systems, meteorology, biota dose assessment, chemical safety, emergency management, 

and nuclear safety training. DOE TCs may include observers and participants from other 

federal agencies, industry, and SDOs. 

 

The DOE Standards Executive actively participates with the Interagency Committee on 

Standards Policy (ICSP), supported by the DOE TSP. The DOE, the Nuclear Regulatory 

Commission (NRC), and NIST conduct coordination meetings with key SDOs to review 

common standards needs and activities, identify issues, and coordinate development 

efforts. The DOE, NRC, and NIST also cooperated to sponsor and maintain U.S. 

participation with ISO’s TC85 Nuclear Energy committees and working groups (under 

ASTM administration). DOE representatives also routinely interface with AMSE and 

ASTM representatives to discuss ongoing standards activities. 

 

The DOE Information Technology (IT) Standards Program, in coordination with the 

DOE TSP, tracks IT standards development, coordinates with subject matter experts, 

adopts new or retires outdated standards, and maintains a Profile of Adopted Standards 
72

(primarily international and national standards at 

http://cio.doe.gov/ITReform/ArchitectureStandards/repository_info.htm). DOE’s Office 

of Energy Efficiency and Renewable Energy, Codes and Standards Program (Internet 

address is http://www.eren.doe.gov/buildings/codes_standards/aboffmsn.htm) also 

conducts a legislatively mandated, multi-year effort to improve the energy efficiency in 

the Nation’s buildings through energy efficiency standards, codes, and guidelines for 

buildings, building equipment, and appliances. The Department is required to 

promulgate amended energy efficiency standards designed to achieve the maximum 

improvement in energy efficiency that the Secretary determines are technically feasible 

and economically justified. The Department’s codes and standards development efforts 

in these areas are closely coordinated with SDOs and include early involvement of 

industry and state stakeholders and relevant federal agencies. 

 

Standards Use: DOE “uses” VCSs extensively in managing, operating, and regulating 

our diverse sites, laboratories, operations, facilities, and activities – over a range that 

includes nuclear weapons production, energy research, oil storage, hydroelectric power, 

accelerator operations, nuclear facility decommissioning, and fusion experiments. VCSs 

are consulted, referenced and applied in our research and development activities; security 

and safeguards programs; environment, safety and health management; and in missionrelated design, procurement, construction, operations, maintenance, emergency 

operations, and decommissioning efforts. 

For DOE reporting purposes, “use” means that a VCS has been cited, referenced, applied, 

or otherwise incorporated into DOE requirements, operations, and activities for the first 

time, or in continued use, as noted below. For FY 2002, DOE documented the use of 

1,189 different VCSs. The use of a particular VCS by several different organizations or 

in different versions is reported as a single use by DOE. DOE also uses a number of 

consortia standards (about 35 – all information technology) that are tracked, but not 

reported. 

 

The VCSs reported “used” by DOE in the annual review are compiled from several 

sources that incorporate VCSs that are actually used by DOE and DOE contractors, 

including: DOE regulations (as an acceptable means to meet specific DOE requirements 

or as a reference); DOE directives - policy, orders, manuals, guides (as an acceptable 

means to meet specific DOE requirements or as a reference; DOE contracts (management 

and operations, management and integration - as a committed means to carry out 

contracted DOE missions and functions); and DOE safety basis documents (stated as a 

commitment or applied reference in DOE safety analysis reports, standards/requirements 

identification documents, and “work smart” standards sets). 

Other extensive uses of VCSs at DOE that are not documented and reported include: 

procedures writing; establishing safety criteria (e.g., for fire protection, nuclear criticality 

safety, nuclear facility safety); as supporting references or cites in internal DOE 

Technical Standards; and personal or contractor uses and participations that are not on 

behalf of DOE. 
73

 

Very few VCSs (none for this reporting period) are mandated through DOE rules, 

regulations, or DOE directives. However, DOE is an agent in the development and 

update of certain legislatively mandated building and appliance energy efficiency codes 

and standards. DOE more typically will cite specific VCSs as “acceptable means” for 

implementing requirements, and allow the use of equivalent alternatives. Very few, if 

any, VCSs are cited in DOE procurements (outside of prime contracts), since most 

procurements are “off-the-shelf.” 

Summary: In accordance with the reporting requirements iterated in OMB A-119, the 

following information has been developed for the OMB Annual Report and has been 

submitted to NIST to (1) report the use of voluntary consensus standards within DOE, 

and (2) report participation in standards development activities on behalf of DOE (by 

DOE staff and DOE contractor staff on behalf of DOE). 

 

DOE did not mandate the use of any government-unique standards in lieu of suitable 

voluntary consensus standards during FY 2002. DOE identified no additional voluntary 

consensus standards that have been substituted for government-unique standards. 

DOE participated in 57 VCS standards bodies. There were 681 agency employees 

participating in VCS activities. (These individuals were involved in 1,268 activities due 

to multiple participations.) DOE used 1,189 VCSs during FY 2002 – (six new ones 

added), and we are also reporting for the first time 158 legislatively mandated standards 

found in DOE regulations and developed through the DOE Office of Energy Efficiency. 

The DOE Information Technology Program also uses around 35 consortia standards 

(outside of our definition of a VCS) that we do not report. The attached Summary 

provides the results and comparisons to the previous year, with appropriate explanatory 

notes, and demonstrates how DOE fully meets the policies and requirements of P.L. 104-

113 and OMB A-119. 

1. As required by P.L. 104-113, you must highlight all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards during FY 2002. 

For each instance, you must identify the specific government-unique standard used and 

the voluntary consensus standard that was not selected. Equally as important, you must 

clearly state your agency’s rationale for such use. 

 Number of DOE standards mandated in lieu of VCSs (FY 2002) 

 0 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 Number of VCSs substituted for DOE unique standards (FY 2002) 
74

 0 

3. The number of voluntary consensus standards that your agency used during FY 2002 

based upon procedures set forth in Sections 11 and 12 of the Circular. 

 1,189 

 

 The overall count increased over FY 2001. Six new VCSs were identified as “used” from 

our annual review. We included an additional 158 VCSs listed in CFRs (derived from an 

analysis by NIST) that are primarily legislatively mandated energy efficiency standards 

for buildings and appliances developed through DOE. There are 35 about consortia 

standards used (but not included in the count), primarily by the DOE IT Standards 

Program. 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 681 

The number of individuals participating with SDOs on behalf of DOE increased by 18 

this past year. This may be related to increased interest in SDO participation generated 

by DOE Topical Committees, and by a more active DOE role with ISO/TC85. 

 

 Additional Information: Number of VCS development/management participations by 

DOE and DOE contractor personnel: 

 1,268 

 The number of participations decreased by 85 this past year. With the stringent limits on 

travel budgets and reduced staffing, DOE staff are prioritizing their participation on 

committees and working groups, maintaining participation only where the interest and 

need are highest. 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

 57 
75

Organization 

 Acronym 

Organization Name 

ACI American Concrete Institute 

AGS American Glovebox Society 

AIAA American Institute of Aeronautics and Astronautics 

AIHA American Industrial Hygiene Association 

AIIM Association for Information and Image Management 

AISC American Institute of Steel Construction 

ANS American Nuclear Society 

ANSI American National Standards Institute 

ASA Acoustical Society of America 

ASCE American Society of Civil Engineers 

ASHRAE American Society of Heating, Refrigerating 

And Air-Conditioning Engineers 

ASME American Society of Mechanical Engineers 

ASNT The American Society for Nondestructive Testing 

ASQ American Society for Quality 

ASSE American Society of Safety Engineers 

ASTM American Society for Testing and Materials (now ASTM 

International) 

AWEA American Wind Energy Association 

AWS American Welding Society 

AWWA American Water Works Association 

CAM-I Consortium for Advanced Manufacturing – International 

CIRMS Council on Ionizing Radiation Measurements and Standards 

CSI Construction Specifications Institute 

CTI Cooling Tower Institute 

EIA Electronic Industries Alliance 

HFS Human Factors Society (now Human Factors and Ergonomics 

Society) 

HPS Health Physics Society 

IAEA International Atomic Energy Agency 

ICBO International Conference of Building Officials 

ICRP International Commission on Radiological Protection 

IEA International Energy Agency 

IEC International Electrotechnical Commission 

IEEE Institute of Electrical and Electronics Engineers 

IIE Institute of Industrial Engineers 

INMM Institute of Nuclear Materials Management 

IPC The Institute for Interconnecting and 

Packaging Electronic Circuits (IPC) 

ISA The Instrumentation, Systems, and Automation Society 
76

ISO International Organization for Standardization 

ITI Information Technology Industry Council 

NACE National Association of Corrosion Engineers 

NACLA National Council of Laboratory Accreditation 

NBBPVI The National Board of Boiler & Pressure Vessel Inspectors 

NCRP National Council on Radiation Protection and Measurements 

NCSL National Conference of Standards Laboratories 

NEMA National Electrical Manufacturers Association 

NFPA National Fire Protection Association 

NIRMA Nuclear Information and Records Management Association Inc. 

NSC National Safety Council 

NSF NSF International 

PMI Project Management Institute 

RIA Robotics Industry Association 

SAE Society of Automotive Engineers 

SES Standards Engineering Society 

SFPE Society of Fire Protection Engineers 

SIA Security Industry Association 

SPRI Single Ply Roofing Institute 

UL Underwriters Laboratories 

WRC Welding Research Council 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. Specifically, you should be prepared to answer the following questions: 

(Note: Questions will be structured on theWeb entry database to accept either “Yes/No” 

or multiple-choice responses.) 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards, or (3) both first time and continued uses of 

standards? 

 DOE reports both initial and continued uses of standards. 

b. Does your agency report (1) the total number of standards it uses or (2) each 

instance where the agency uses (i.e., references) a standard? 

 

 DOE reports the total number of standards in use. 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 

 Multiple uses and multiple versions count only as a single standard “use.” 

. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 
77

 Yes, DOE reports use for both guidance and compliance. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

No - Consortia and other standards uses are documented and tracked, but not 

reported. 

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

DOE finds the current version of OMB A-119 adequate and has no recommendations for 

revision. Issues of clarification and documentation are readily handled through ICSP 

coordination with OMB. 

 

8. Any conformity assessment activities in which your agency has been involved in the 

reporting period as described in the Federal Register, Vol. 65, No. 155, Thursday, 

August 10, 2000, Guidance on Federal Conformity Assessment Activities 

 No Report – this is essentially unchanged from the previous year. 

9. No response. 

10. No response. 
78

Department of Health and Human Services 

1. As required by P.L. 104-113, you must highlight all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards during FY 2002. 

For each instance, you must identify the specific government-unique standard used and 

the voluntary consensus standard that was not selected. Equally as important, you must 

clearly state your agency’s rationale for such use. 

 5 

Government Standards Voluntary Standards Explanation 

National Standard Format ANSI X12 837 The NSF is used widely across 

the health care payment 

industry and has become a 

defacto national standard. 

However, the Centers for 

Medicare and Medicaid 

Services (CMS) have directed 

their contractors to 

discontinue use of the NSF 

standard and replace it with 

ANSI X12 837 by the 

beginning of FY 2003. 

FR Notice dated June 17, 

1994, tentative Final 

Monograph for Heath Care 

Antiseptic Drug Products; 

proposed Rule 

ASTM Standard E1115: 

Test Method for Determining 

Surgical Hand Scrub 

Formulations 

Sensitivity and bias of the 

ASTM standard has not been 

established. 

FR Notice dated June 17, 

1994, tentative Final 

Monograph for Heath Care 

Antiseptic Drug Products; 

proposed Rule 

ASTM Standard E1173-93 

Test Method for Evaluation of 

Pre-Operative Skin 

Preparation 

Sensitivity and bias of the 

ASTM standard has not been 

established. 

FR Notice dated June 17, 

1994, tentative Final 

Monograph for Heath Care 

Antiseptic Drug Products; 

proposed Rule 

ASTM Standard E1174-00 

Test Method for the 

Evaluation of the 

Effectiveness of Health Care 

Personnel or Consumer Hand 

Wash Formulations 

Sensitivity and bias of the 

ASTM standard has not been 

established. 
79

FDA guidelines on aseptic 

processing published in 1987. 

ISO Standard 13408-1 

Defining general requirements 

for aseptic processing of 

health care products. 

The ability of these ISO 

requirements is limited to only 

portions of aseptically 

manufactured biologics and 

does not include filtration, 

freeze-drying, sterilization in 

place, cleaning in place, or 

barrier-isolator technology. 

There are also significant 

issues related to aseptically 

produced bulk drug substance 

that are not included in the 

document. 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 1 

 Voluntary Standard Government Standard 

 ISO 17025 Varieties of FDA Laboratory Standards 

3. The number of voluntary consensus standards that your agency used during FY 2002,

 based upon procedures set forth in Sections 11 and 12 of the Circular. 

 616 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 515 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

 The following list of voluntary consensus standards bodies in which there is agency 

participation is based upon: 

 The ANSI accredited standards developers list, and 

 The National Resource for Global Standards (NSSN) list. 

 3A-Sanitary Standards Committee (3-A) 

 Acoustical Society of America (ASA) 

 American Association of Blood Banks (AABB) 
80

 Underwriters Laboratory (UL) 

6. Description of how your agency currently reports its use of voluntary consensus 

standards. Specifically, you should be prepared to answer the following questions: 

(Note: Questions will be structured on the web entry database to accept either “Yes/No” 

or multiple-choice responses.) 

a. Does your federal agency report (a) only the first-time use of standards, (b) 

continued uses of standards or (c) both first time and continued uses of standards? 

 American Conference of Governmental Industrial Hygienists (ACGIH) 

 American Dental Association (ADA) 

 American Industrial Hygiene Association (AIHA) 

 American National Standards Institute (ANSI) 

 American Oil Chemist Society (AOCS) 

 American Public Health Association (APHA) 

 American Society for Testing Materials (ASTM) 

 American Society of Agricultural Engineers (ASAE) 

 American Society of Heating, Refrigeration, and Air-Conditioning Engineers (ASHRAE) 

 American Society of Mechanical Engineers (ASME) 

 American Society of Sanitary Engineering (ASSE) 

 ASC X12 Data Interchange Standards Association 

 Association for the Advancement of Medical Instrumentation (AAMI) 

 Association of Official Analytical Chemists (AOAC) 

 Codex Alimentarius 

 College of American Pathologists (CAP) 

 Commercial Refrigerator Manufacturers Association (CRMA) 

 Health Level Seven (HL7) 

 Health Physics Society (HPS) 

 Industrial Safety and Equipment Association (ISEA) 

 Institute of Electrical and Electronics Engineers (IEEE) 

 International Electrotechnical Commission (IEC) 

 International Organization for Standardization (ISO) 

 International Society for Measurement & Control (ISA) 

 Lead Industries Association, Inc. (LIA) 

 National Association of Photographic Manufacturers (NAPM) 

 National Committee for Clinical Laboratory Standards (NCCLS) 

 National Council for Prescription Drug Program (NCPDP) 

 National Electrical Manufacturers Association (NEMA) 

 National Fire Protection Agency (NFPA) 

 National Fire Protection Association (NFPA) 

 National Institute of Standards and Technology (NIST) 

 National Sanitation Foundation (NSF) 

 Organization of Economic Cooperation and Development (OECD) 

 RESNA (RESNA) 

 Society of Automotive Engineers (SAE) 
81

 Both first time and continued uses. 

b. Does your agency report (a) the total number of standards it uses or (b) each 

instance where the agency uses (i.e., references) a standard? 

 The total number of standards used. 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 Yes, multiple editions. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

 Yes. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 Yes. 

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

U.S. Food and Drug Administration 

The policy and recommendations contained in Circular A-119 are consistent with FDA's 

framework for standards management as announced in the Federal Register on 

October 11, 1995, and enhanced by the Food and Drug Administration Modernization 

Act (FDAMA). Resource constraints oblige the agency to focus attention on the highest 

priority activities and to strive to make its participation in those activities very effective. 

FDA participates in 601 standards development activities within 29 voluntary consensus 

standards bodies. 

For FDA, voluntary consensus standards are most relevant for medical devices, where 

they are used extensively in the agency's regulatory work, and where the majority of the 

agency's standards activities are centered. Voluntary consensus standards are less 

relevant in the areas of human and veterinary pharmaceuticals, biological products and 

food, where such standards are generally not available nor being developed, and where 

standards of other national or international organizations such as the U.S. Pharmacopeia 

(USP), the World Health Organization (WHO), the Food and Agriculture Organization 

(FAO), the Organization for Economic Cooperation and Development (OECD), and the 
82

International Conference on Harmonization of Technical Requirements for Registration 

of Pharmaceuticals for Human Use (ICH) predominate. 

The central purpose for FDA involvement in the development and use of standards is to 

assist the agency in fulfilling its domestic public health and regulatory missions. The 

agency participates widely in the development of standards, both domestic and 

international, and adopts or uses standards when this action enhances its ability to protect 

consumers and increases the effectiveness or efficiency of its regulatory efforts. Further, 

using standards, especially international ones, is a means to facilitate the harmonization 

of FDA regulatory requirements with those of foreign governments, and thus to improve 

domestic and global public health protection. Therefore, FDA encourages participation 

in the development of standards as a useful adjunct to regulatory controls. 

The FDA has been involved in standards activities for more than 20 years. In January 

1977, the agency promulgated a final regulation now found at 21 CFR 10.95 covering 

participation by FDA employees in standards development activities outside the agency. 

This regulation encourages FDA participation in standards activities that are in the public 

interest, and specifies the circumstances under which FDA employees can participate in 

various types of standards bodies. The agency built upon that rule with a final policy 

statement published in the Federal Register on October 11, 1995, entitled International 

Harmonization; Policy on Standards. It provides the agency's overall policy on 

development and use of standards for all product areas regulated by the agency. 

Center for Devices and Radiological Health (CDRH) 

The Food and Drug Administration Modernization Act of 1997 (FDAMA) allows the 

agency to recognize voluntary consensus standards established by international and 

national standards development organizations that may be used to satisfy identified 

portions of device pre-market review submissions or other requirements. CDRH has 

made available a standards relevant document on their web site. The document, "CDRH 

Standard Operating Procedures for the Identification and Evaluation of Candidate 

Consensus Standards for Recognition," establishes internal CDRH procedures for the 

identification and evaluation of consensus standards for recognition through publication 

of a notice in the Federal Register. 

CDRH continues to maintain a database to track the standards activities of its employees, 

has established, and uses searchable ROM databases of voluntary consensus standards to 

facilitate reference to current voluntary consensus standards by agency reviewers. 

CDRH continues to participate in Steering Committee and Study Group Activities of the 

Global Harmonization Task Force (GHTF), an intergovernmental consortium to foster 

medical device regulatory harmonization. During FY 2002, FDA published draft 

guidance on a pilot program that will be used to evaluate the feasibility of using the 

Summary Technical Document (STED) and an Essential Principles Document instead of 

standard CDRH procedures for certain premarket submissions. 
83

Finally, the GHTF has a Memorandum of Understanding with TC 210, the ISO 

Committee responsible for many aspects of device standards. 

Center for Drugs Evaluation and Research (CDER)/Center for Biologics Evaluation 

and Research (CBER) 

Voluntary consensus standards are less applicable to pharmaceutical and biological 

products. CDER and CBER therefore have limited involvement in such activities, but do 

participate on relevant committees of a number of voluntary consensus standards bodies. 

CDER's and CBER's major involvement in standards setting activities is with USP, ICH, 

OECD, and WHO. Numerous employees are involved in the standards development 

activities of the USP, a private, voluntary, not-for-profit national standards setting body 

of health care professionals, recognized authorities in medicine, pharmacy, and allied 

sciences. USP publishes and revises the United States Pharmacopeia and the National 

Formulary (NF), the legally recognized compendia of drug standards in the United States. 

Both CDER and the CBER participate in the ICH. This ongoing project, begun in 1989, 

has been undertaken by government agencies responsible for regulation of 

pharmaceuticals and by industry trade organizations. The European Union, Japan, and 

the United States bring together regulatory authorities and experts from the 

pharmaceutical industry in the three regions to discuss scientific and technical aspects of 

new product registration. The work products, created in working groups of experts from 

the regulatory agencies and industry, consist of a series of consensus guideline 

documents to harmonize pharmaceutical testing guidelines. During FY 2002, FDA 

worked on the implementation of the harmonized Common Technical Document (CTD). 

This document will become the standard format for marketing application submissions of 

pharmaceutical products. 

FDA officials also participate in a consensus standards development activity sponsored 

by the Council for International Organizations of Medical Sciences that is aimed at 

standardizing the safety-related terminology used in adverse experience reporting. 

FDA actively participates with the WHO in developing international standards for 

ensuring the quality of pharmaceutical and biological products, and the OECD on good 

laboratory practices for animal studies. 

Although FDA's work with USP is specifically excluded from reporting under Circular 

A-119, and ICH, OECD, and WHO do not meet the definition of voluntary consensus 

standard bodies under the Circular, substantial agency resources are devoted to the 

development of standards with these organizations. This work is the core part of FDA's 

overall standards activities for pharmaceutical and biological products. 
84

Center for Food Safety and Applied Nutrition (CFSAN)/Center for Veterinary 

Medicine (CVM) 

The principal international standards activities in the areas of food and veterinary 

medicine fall under the activities of the Codex Alimentarius Commission of the FAO and 

the WHO, as well as the Office of International Epizootics (for veterinary medicine). 

FDA experts from CFSAN, CVM, and other parts of the agency are actively involved in 

Codex Alimentarius activities, and in activities of methods validation organizations on 

which Codex Alimentarius relies, such as ISO, the Association of Official Analytical 

Chemists (AOAC) International, and the International Dairy Federation (IDF). CFSAN 

has provided the U.S. Delegate or Alternate Delegate to 80 percent (17 out of 21) of the 

technical committees and task forces and provided technical experts to assist on the work 

of developing more that 90 Codex standards and guidelines. CVM has also provided 

numerous technical experts to assist on Codex task forces, especially those related to the 

Codex Committee on Residues of Veterinary Drugs and Foods (CCRVDF). Currently, 

the Director of CVM serves as the chair of the CCRVDF. 

Voluntary consensus standards have limited relevance to food and veterinary medicine 

products. However, since the standards activities of multilateral organizations such as the 

WHO, FAO, the World Trade Organization, and the OECD are important in these areas; 

CFSAN and CVM are actively engaged in standards and policy development with these 

organizations. CFSAN is also engaged in standards review in the International 

Organization for Standardization in Microbiology. 

CVM is active in a harmonization initiative similar to the ICH for human 

pharmaceuticals, that is, developing harmonized requirements for the registration of 

veterinary pharmaceuticals and biological veterinary medicinal products. It is known as 

VICH, for Veterinary ICH. Agency employees participate on numerous committees that 

are drafting VICH guidelines related to veterinary pharmaceuticals. Through VICH, 

CVM has developed 30 guidelines for the registration of veterinary pharmaceuticals. 

International/Treaty Standards-Related Activities 

FDA takes part in a variety of international standards activities that fall under treaty 

organizations, and thus are not reportable under the provisions of Circular A-119. These 

standards activities are nonetheless important to the agency in fulfilling its public health 

regulatory mission. Some of these are referred to above, i.e. WHO, FAO, and OECD. 

The agency participates in international trade discussions within the WTO, specifically 

with committees on the Agreement on Technical Barriers to Trade (TBT), and the 

Agreement on the application of Sanitary and Phytosanitary (SPS) Measures; with the 

implementation of the counterpart committees of the North American Free Trade 

Agreement (NAFTA); and with the negotiation of an upcoming trade agreement by 2005, 

for the Free Trade Area of the Americas where sanitary and phytosanitary measures fall 

within the scope of the negotiations. In addition, FDA is participating in negotiations 
85

with Chile on a free trade agreement. FDA is engaged in these negotiations to ensure that 

the agency's requirements are preserved and its regulatory practices can remain focused 

on fulfilling the agency's mission to protect the public health while being supportive of 

emerging, broader U.S. government obligations and policies. FDA has participated in 

several initiatives that are part of the Asia Pacific Economic Cooperation (APEC) forum. 

FDA topics have included food safety, food labeling, bulk drugs, standards for latex 

gloves and condoms, and medical device regulation. 

8. Any conformity assessment activities in which your agency has been involved in the 

reporting period as described in the Federal Register, Vol. 65, No. 155, Thursday, 

August 10, 2000, Guidance on Federal Conformity Assessment Activities. 

U.S. Food and Drug Administration 

The CDRH has liaison with the ANSI Accreditation Committee, the ANSI International 

Conformity Assessment Committee, ANSI Board Committee on Conformity Assessment, 

and ASTM Committee E-36 on Conformity Assessment. The Center uses suppliers' 

declaration of conformity as described in ISO/IEC Guide 22 in its standards recognition 

program and has developed an MRA with the European Union on mutual recognition of 

each other's conformity assessment procedures related to manufacture and marketing of 

medical devices. 

CVM inspects drugs manufacturers for compliance with current Good Manufacturing 

Practices (cGMP) requirements and inspects laboratories that provide pivotal animal 

studies for drug approvals for compliance with Good Laboratories Practices. 

The Office of Regulatory Affairs (ORA) actively participates with the National 

Cooperation for Laboratory Accreditation (NACLA). An ORA official is a member of 

the NACLA Executive Board of Directors and has the role of participating in the 

NACLA Recognition Committee for Accrediting Bodies who apply for mutual 

recognition. Other FDA officials participate with NACLA in the evaluation of 

accrediting bodies under ISO/IEC 58 and ISO/IEC 17025 and sit on NACLA technical 

committees. 

ORA officials are also involved with Codex Alimentarius activities, especially in the area 

of pesticide residues, which relies on methods development by ISO and AOAC. Other 

activities include participation and the coordination of federal-state conferences to 

develop uniformity in the reporting of food testing results. The ISO/IEC 17025 standard 

is the foundation in this coordination effort. 

ORA laboratories are finalizing and implementing the new quality system in preparation 

for accreditation to ISO 17025. 

CBER laboratories that conduct official product testing are in the process of becoming 

ISO 17025 accredited. CBER has conducted initial staff training and is in the process of 
86

writing a Laboratory Quality Assurance Manual centrally documenting Center policies 

and procedures related to the official testing of regulated biological products. CBER is 

implementing a quality management software tool to assist in the effort, and has quality 

insurance managers to coordinate the implementation of an ISO 17025-based quality 

system. 

In addition to the formal reporting obligations under OMB Circular A-119, it should be 

noted that the overwhelming majority of CBER’s standards setting activities with outside 

organizations are with groups that do not meet all of the requirements of the OMB 

Circular A-119 definition of a voluntary consensus standards body. CBER interactions 

with these organizations have resulted in development of several standards that affect a 

variety of products CBER regulates. These groups include the International Conference 

on Harmonization (ICH), the Global Harmonisation Task Force (GHTF), the Pan 

American Health Organization (PAHO), the World Health Organization (WHO), the 

United States Pharmacopoeia (USP), the International Society for Blood Transfusion 

(ISTB), and the United States Adopted Names Council (USAN). CBER also collaborates 

with the National Institute for Biological Sciences and Controls (NIBSC), a United 

Kingdom Institute, to develop standards and reference materials for biological products. 

These materials are often presented to WHO for their consideration as international 

standards. 

In addition, CBER has recently initiated activities with a variety of organizations that 

may result in the development of standards mostly for cellular therapies and tissue 

products. These organizations include the American Society for Reproductive Medicine 

(ASRM), the American Association of Tissue Banks (AATB), and the Eye Bank 

Association of America (EBAA). 

CBER has also participated in a collaborative effort with other U.S. governmental and 

nongovernmental organizations including the National Institute of Standards and 

Technologies, the National Cancer Institute, and the College of American Pathologists in 

developing a reference material and guidance to test for the presence of HER2 gene 

protein. Consistent methodology for detecting HER2/neu gene protein is necessary for 

treatment of breast cancer with the therapeutic monoclonal antibody, trastuzumab 

(Herceptin). 

CBER also organized an Adenovirus Reference Materials Working Group that developed 

an adenoviral virus reference material. This material was developed in a unique 

collaborative effort with donations from multiple organizations and institutions. The 

reference material is used to define the particle unit and infectious units for adenovirus 

vectors used in gene therapy. 

CBER supports the concept of working within our agency, with other government 

agencies, the private sector, and other governments to avoid duplication in standards 

setting activities. Within FDA, they coordinate with other Centers in the development of 

"Guidance to Industry" documents. FDA also coordinates activities with other agencies, 
87

such as the Environmental Protection Agency, the U.S. Fish and Wildlife Service, the 

Consumer Product Safety Commission, the Drug Enforcement Agency, and the National 

Institute of Standards and Technology. 

Finally, a majority of standards setting activities are focused on interactions with national 

and international standards setting bodies such as USP, ICH, OECD, WHO, and the Pan 

American Health Organization (PAHO). An innovative approach to harmonizing 

international standards is being undertaken with PAHO. The primary mission of PAHO 

is to strengthen national and local health systems and improve the health of the peoples of 

the Americas. In the Americas, there is a need to promote harmonization to facilitate the 

availability of safe, effective, and good quality pharmaceuticals and thereby protect 

public health. The regulation of pharmaceuticals and the harmonization of technical 

standards have emerged as an important component of the economic integration. As a 

result, a Pan American Network for Drug Regulatory Harmonization (PANDRH) with 

biennial Pan American conferences was established. The mission of the Network is 

accomplished by conferences that promote regulatory harmonization for all aspects of 

quality, safety, and efficacy of pharmaceutical products as a contribution to the quality of 

life and health care of the citizens of the countries of the Americas. 

Harmonization in this context is understood to be the search for common ground within 

the framework of recognized standards, taking into account the existence of different 

political, health, and legislative realities among the countries of the region. A steering 

committee was formed to enable progress between conferences by coordinating, 

promoting, facilitating, and monitoring harmonization processes in the Americas. A 

major aspect of PANDRH is to provide training to the regulatory agencies of the 

Americas. It is felt that training to the same standards will eventually lead to harmonized 

standards. 

Centers for Medicare and Medicaid Services (CMS) 

Although CMS was involved in a limited number of conformity assessment activities to 

assure adherence by their contractors to the national health care payment standards, it is 

anticipated that these activities will increase significantly in future years. In addition, 

CMS participated in interagency efforts to harmonize health care standards 

implementation activities under HIPAA with other federal agencies, including the 

Department of Defense, the Veterans Administration, and state Medicaid agencies. They 

also conducted a review of private sector certification services available that could assist 

in establishing a mechanism to better certify the use of health care standards by 

contractors. CMS contracted with an IV & V company, Claredi, to conduct certification 

reviews to evaluate compliance of the Medicare contractor implementation of HIPAA 

transaction standards in FY 2002. CMS also directed each of their contractors to conduct 

extensive internal testing of the programming for those implementations. 

CMS is also participating with the National Forum for Health Care Quality Measurement 

and Reporting in the endorsement of standards for performance measures of quality 
88

among various providers. This effort brings together all stakeholders to make a 

determination founded in a membership-driven consensus process and an evidence base 

for the subject matter. The various endorsements will occur over the next two years. 

Agency for Healthcare Research and Quality (AHRQ) 

The Agency for Healthcare Research and Quality (AHRQ) is the government’s leading 

agency in the development and deployment of evidence-based research on health care 

quality and costs. One key area of this work is AHRQ’s support for voluntary consensus 

standards use in the health care field. As the leading agency sponsoring research on 

health care quality that will support clinical, health care system, and public policy 

decision makers, AHRQ regularly is involved in evaluating health care standards across 

the spectrum of patient care. AHRQ’s Evidence-Based Practice Centers (EPCs) is a 

program of 13 centers across the country and in Canada that are available for public and 

private partners seeking to research disease conditions and standards of care for those 

conditions. Numerous EPC reports have been used as crucial inputs of evidence in larger 

consensus-based standards processes. AHRQ’s National Guidelines Clearinghouse is a 

public resource for evidence-based clinical practice guidelines. NGC is sponsored by 

AHRQ in partnership with the American Medical Association and the American 

Association of Health Plans. The NGC is nationally recognized archive for numerous 

standards, including voluntary consensus standards. 

9. Examples or case studies of your agency’s standards successes, if you so choose. 

U.S. FDA/CDRH 

 Ignition Test for Medical Oxygen Regulators 

Oxygen regulators are devices used with high-pressure gas cylinders to control the 

pressure and flow of oxygen to patients. A rare, but serious, risk associated with these 

devices is flash fires and explosions, which have resulted in dozens of serious injuries 

and one death. To reduce the prevalence and severity of these types of incidents, FDA, in 

conjunction with NIOSH, initiated development of an ignition test for medical oxygen 

regulators. In the spring of 1999, initial research supporting the development of the test 

was undertaken in partnership with the NASA White Sands Test Facility and a private 

research firm (Wendell Hull & Associates). These facilities were consulted because they 

have specialized equipment, test facilities, and fire safety provisions that FDA does not 

have for performing this type of ignition testing. Their staff, along with FDA staff, health 

care workers, oxygen regulator manufacturers, and other technical experts participated in 

development of a standard incorporating the ignition test through a committee of the 

American Society for Testing and Materials (ASTM). The initial research was completed 

and a provisional standard developed and approved in October 2000, approximately 1 1⁄2 

years after the initial research began. Validation testing showed that damage produced 

from the laboratory simulation test is consistent with that observed in clinical use for 

problematic regulator designs. This shows that the test can be used to prevent unsafe 
89

designs from entering the market in the future. Key members of industry have already 

used the test to assess the safety of their products and incorporated design improvements 

accordingly. In addition, the agency has used the test to evaluate proposed design 

changes for regulators that were recalled because of problems with fires. Testing of one 

problematic model showed that the firm’s proposed retrofit will not completely resolve 

the fire hazards associated with their device. In addition to benefiting FDA, the test 

method will benefit the space program because it will help ensure use of safe oxygen 

regulators during spaceflight. Eventually, the test method may have applicability to other 

types of regulator technology, such as welding and scuba regulators. 

 U.S. FDA/CFSAN 

 Laboratory Certification: 

 The Grade A Milk safety laboratory certification program relies on-site inspection as well 

as annual proficiency testing evaluation forms developed through common agreement by 

all parties are used to review records, facilities, and analysts’ performance of tests. The 

proficiencies cover the range of testing for which the laboratories are certified and the 

results are evaluated statistically. This program has enhanced public health protection 

by: 

 ● verifying analysts’ abilities to perform testing successfully; 

● improving the quality of the work performed by the analysts, analysts’ 

knowledge, and the credibility of results; 

● more rapidly and accurately identifying pathogens leading to earlier and more 

successful treatment; and 

 ● keeping drugs out of the milk supply. 

 Retail Food Establishment Food Manager’s Certification Program: 

 Via participation in the Conference for Food Protection (CFP), we are involved in a 

certification / accreditation program. The CFP now owns copyrighted Food Manager 

Certification Standards that are administered by ANSI under contract with the CFP. An 

FDA employee sits on an ANSI/CFP accreditation committee to ensure those standards 

are administered consistent with CFP's intent. This is the culmination of over 20 years of 

work to arrive at legally defensible national standards to which all the stakeholders have 

agreed; meaningful certification; a basis for reciprocity among the 3,000+ regulatory 

agencies in the United States; a single process for industry; and a straightforward method 

of fulfilling the FDA model Food Code. 

 Agency for Healthcare Research and Quality (AHRQ) 

 During the past year, AHRQ has put special effort into monitoring its compliance with 

the National Technology Transfer and Advancement Act (NTTAA). In the spring of 

2003, AHRQ staff invited senior NTTAA officials from the National Institute of 

Standards and Technology to brief relevant AHRQ staff members on compliance issues 
90

with NTTAA. This briefing has led to increased awareness and tracking of AHRQ’s 

principal support for voluntary consensus standards setting, which comes through the 

Agency’s support for the National Quality Forum (NQF). The NQF is a not-for-profit 

membership organization created to develop and implement a national strategy for health 

care quality measurement and reporting. AHRQ is a charter member of the NQF and 

provides funding for the NQF through a contract and small conference grants. The NQF 

is the first, and only, organization in U.S. health care, that brings together a membership 

of provider, purchaser, consumer, and research and quality improvement organizations to 

develop consensus on health care standards. During this past year, AHRQ funding 

helped support the development of five sets of voluntary, consensus-based standards for 

quality measurement. Work continues on some of these measure sets and will be 

completed (and reported on) in FY 2003. These standards for quality measurement were 

in the following areas: 

 ● Diabetes care 

 ● Nursing home performance 

 ● Hospital performance 

 ● Safe practices for better healthcare 

 ● Cancer care 

 ● Translating Research into Practice (TRIP) initiative is in its second iteration 

 

 Center for Disease Control (CDC) 

 To new to the process to provide good case studies. The agency is very involved in the 

voluntary standards process and has been for a number of years. See 

http://intranet.cdc.gov/nedss/WhatIsNEDSS.htm for an example of a current system 

using voluntary consensus standards. 

10. Comments. 

 For a regulatory agency such as FDA, neither a categorical nor a transactional 

designation correctly describes how we use these standards. Six hundred and one (601) 

is the total number of voluntary consensus standards listed by FDA as of the end of the 

current reporting period that can be referenced by applicants for market approval of 

medical devices. Applicants can reference these standards in lieu of submitting data to 

meet approval requirements. For the Department, the total number of standards 

recognized is 616 and includes standards used by the Centers for Medicare and Medicaid 

Services. 
91

Department of Housing and Urban Development 

1. Number of government unique standards used in lieu of voluntary standards . 

 2 

Government Standard Voluntary Standard Explanation

28 CFR 200.93 5 ANSI A119.1 N HUD Building-Product 

Standards & Certification 

Programs.

28 CFR 3280 ANSI A119.1 and 

NFPA 501C 

HUD-Unique Manufactured 

Home Construction & Safety 

Standards.

2. Number of voluntary consensus standards substituted for government unique standards. 

 1 

Voluntary Standard Government Standard

NFPA 501 45 CFR 3280 

3. Number of voluntary consensus standards used in FY 2001. 

 300 

4. Number of agency employees participating in voluntary consensus standards activities. 

 10 

5. Number of voluntary consensus standards bodies in which there is agency participation. 

 5 

 American Society of Testing and Materials (ASTM) 

 Federal Geographic Data Committee (FGDC) 

 International Committee for IT Standards (INCITS), (formerly the National Committee 

of IT Standards [NCITS], also, formerly known as Computer Business Equipment 

 Manufacturers Association [CBEMA]) 

 The International Standards Organization (ISO) 

 The National Fire Protection Association (NFPA) 
92

6. How do you report your use of standards? 

 a. No response. 

 b. No response. 

 c. No response. 

 d. No response. 

 e. No response. 

7. Provide an evaluation of the effectiveness of Circular A-119 policy and recommendations 

for any changes. 

This policy continues to be effective in replacing federal standards with public-domain 

standards. This has resulted in more timely, up-to-date, and technically accurate 

standards. The Department of Housing and Urban Development (HUD) suggests 

Circular A-119 use stronger language to encourage agencies to be more active in 

determining which standards are applicable to the agency's activities and when standards 

are identified, motivate the agency to be more assertive in enforcing their use. 

 

8. Provide the conformity assessment activities in which the agency has been involved. 

All of HUD's 25 conformity assessment (CA) programs, under the HUD BuildingProducts Standards & Certification Programs, comply with the ISO guidelines & 

procedures. These are the same standards used by ANSI and other nationally recognized 

third-party certification agencies. 

9. Recent examples or case studies of standards successes. 

I. Office of Policy Development and Research 

Department/Agency U.S. Department of Housing and Urban Development (HUD) 

 Office of Policy Development & Research 

 451 Seventh Street, SW 

 Washington, DC 20410 

 Phone: (202) 755-4370 

 Fax: (202) 708-5873 

 URL address: http://www.hud.gov/progdesc/pdrindx.cfm 

The HUD Office of Policy Development & Research (PD&R) has recently completed an 

assessment of HUD’s own Minimum Property and Technical Suitability of Products 

program. This major study recommends that the Department extend its reliance on 

voluntary standards in two ways. First, the study recommends that HUD totally abandon 
93

the MPS for single-family housing in all aspects totally relying on the model codes, 

especially the ICC & IRC codes and remove all remaining references to the MPS in HUD 

regulations. This would clarify the reality of HUD not using its own standards in any 

way or shape. Second, the study recommends that HUD abandon its own “Technical 

Suitability of Products” program relying instead on the National Evaluation Service to 

review all innovative or other products that do not meet the prescriptive standards of the 

model codes. This major study is now under review by the Assistant Secretary for 

Housing. If adopted, this major reform will further strengthen our reliance on the 

voluntary and private consensus process in lieu of HUD developed standards and criteria. 

Second, HUD’s Partnership for Advancing Technology in Housing (PATH) is continuing 

to encourage private industry to develop standard XML definitions for use in Internet 

based home construction commercial transactions. These will be used among specific 

home construction entities. One of the group's objectives is to improve the speed of 

construction in order to make houses more affordable. Sharing the same technical 

language and being able to speak quickly and accurately is a big challenge. Applying 

information technology seemed to be one solution. However, the group did not know 

how to implement it. 

The first industry–based group from the timber manufacturing industry approached 

PATH to assist them in convening hearings and task groups to develop such a common 

language (in this case, through XML tag sets) so that it would become an industry de 

facto "standard." PATH is now working with the window industry to develop similar 

XML tags for window industry tags will be used internally by the window industry and 

down through the distribution chain by wholesalers and homebuilders for the just in time 

ordering of products through Web-based tools. 

These efforts have stimulated the first industry-based attempts to posit these standard 

definitions (most attempts have been top-down and unsuccessful). Also, because 

government served only in a facilitation capacity, industry did all the work! We plan to 

continue this work under PATH with different groups in the construction industry; we 

currently have three lined up. 

II. MANUFACTURED HOUSING 

Department/Agency U.S. Department of Housing and Urban Development (HUD) 

 Federal Housing Administration (FHA) 

 Office of Housing 

 Office of Consumer and Regulatory Affairs 

 Manufactured Housing and Standards Division 

 HSCM Room 9152 

 451 Seventh Street, SW 

 Washington, DC 20410-8000 

 Hotline for complaints: 1-800-927-2891 

 Phone: (202) 708-6409 
94

 Fax: (202) 708-4213 

 e-mail: mhs@hud.gov 

 URL address: http://www.hud.gov/fha/sfh/mhssht3.html 

 Initiated 1976. 

 Compliance Mandatory. 

Authority National Manufactured Housing Construction and Safety Standards Act, 

P.L. 93-382, 42 U.S.C. 5407. 24 CFR Part 3280. 

Aim: To reduce the number of personal injuries and deaths, cost of insurance, 

and property damage resulting from manufactured home accidents and to 

improve the quality and durability of manufactured homes. 

Benefits: Uniform nationwide certification program has accomplished the stated 

purposes of the Act and improved interstate commerce in manufactured 

housing. 

Methodology: As required by the Manufactured Housing Improvement Act of 2000, 

HUD is now relying on a private consensus committee administered by 

the National Fire Protection Association (NFPA) to develop new 

regulations for revising HUD’s Manufactured Housing Standards. As 

required by law, this change moves towards greater reliance on a formal 

consensus committee. In the past, HUD consulted with an Advisory 

Committee, which had a very limited role. By law, this new committee 

must follow ANSI standards and apply to ANSI for accreditation. In 

addition, this consensus committee is developing, for the first time, model 

installation standards that must be completed this year. The consensus 

committee held its second full meeting in December 2002, and established 

its structure and committees. The installation subcommittee is making 

good progress using NFPA 225 Model Installation standards as its initial 

starting document. 

 Term: Indefinite term . 

 Reciprocity: Other federal agencies and state agencies. 

Standards, Codes: Agency references standards prepared by others and or regulations 

incorporates requirements in the Federal Manufactured Home 

Construction Safety Standards (24 CFR Part 3280). Enforcement is in 

accordance with Procedural and Enforcement Regulations (24 CFR Part 

3282). 
95

 Keywords: Design approval; housing requirements; inspection; manufactured 

 housing; product safety. 

10. Comments. 

 HUD's ten participants in Standards Developing Organizations (SDO's) are from HUD's 

Office of Policy, Research, and Development(R); Office of Healthy Homes & LeadHazard Control (L); Office of Housing-Federal Housing Commissioner (H); and Office 

of the Chief Information Officer (Q). 

 Following are some acronyms used in this and similar reports: 

 STANDARDS-RELATED ACRONYMS 

 ACRONYM DESCRIPTION 

A-119 OMB's Circular that posits presidential-mandated standards activities for 

 U.S. Government Agencies 

ACM Association of Computing Machinery 

ASC Accredited Standards Committee 

ANSI American National Standards Institute 

ASME American Society of Mechanical Engineers 

ASQC American Society for Quality Control 

ASTM American Society for Testing & Materials 

ATIS Alliance for Telecommunications Industry Solutions 

CA Conformity Assessment 

CCITT Comite Consultatif International Telegraphique et Telephonique (now 

 ITU- T) 

CD Committee Draft 

CE European Community (mark), an icon required for products sold in the 

 European Union (Dubbed an 800-lb gorilla) 

CE Consumer Electronics 

CEN European Committee for Standardization (Comite European de 

 Normalisation) 

CENELEC Comite European de Normalisation ELECtrotechnique [European 

 Committee for Electrotechnical Standardization] 

CS Central Secretariat 

DIN Deutsches Institut fur Normung (German Standardization Institute) 

DIS Draft International Standard Dresden Agreement (See the definition in the 

 ANSI NSS brochure 

EC European Commission 

ECI Environmental Condition Indicator 

EFTA European Free Trade Association 

EIA Electronics Industries Association 

ENV European Pre-standard 
96

EPE Environmental Performance Evaluation 

ETSI European Telecommunications Standards Institute 

EU European Union 

FDIS Final Draft International Standard 

FTCA Federal Trade & Communications Act 

GATT General Agreement on Tariffs & Trade 

GMC (ANSI's) Government Member Council 

ICSP InterAgency Committee for Standards Policy 

IEC International Electro-technical Commission 

IEEE Institute of Electronic & Electrical Engineers 

INCITS International Committee on Information Technology Standards 

IPC Institute for Interconnecting & Packaging Electronic Circuits 

IPR International Property Rights 

IS International Standard 

ISO International Organization for Standardization (Fr) 

ITI Information Technology Industry (Council) 

ITU-T International Telecommunication Union- (Standardization Division), 

 formerly CCITT 

JTC/1 Joint (ISO/IEC) Technical Committee (for Information Technology) 1 

LCA Lifecycle Assessment 

MPI Management Performance Indicator 

NC National Committee 

NCITS (EN cites) National Committee for Information Technology Standards 

 [obsolete; see INCITS] 

NEMA National Electrical Manufacturers Association 

NIST National Institute of Standards & Technology 

NP New Work-Item Proposal 

NSS National Standards Strategy (ANSI) 

NSSN National Standards System Network (An email-based source for Global 

 Standardization: www.ansi.org) 

NTTAA National Technology Transfer & Advancement Act (PL 104-113) 

OPI Operational Performance Indicator 

OSI (ISO) Open Systems Interconnection 

PCMCIA Personal Computer Memory Card International Association 

PrEN Preliminary European Standard 

PL Public Law 

RI Regulatory Interface 

SAE Society of Automotive Engineers 

SAGE (ISO) Strategic Advisory Group on the Environment 

SC Subcommittee 

SDO Standards Developing Organization 

SES Standards Engineering Society 

SI International System of Units 

SME Subject Matter Expert 

SSM Strategic Standardization Management 
97

TA Technical Advisor 

TAG Technical Advisory Group 

TC Technical Committee 

TMB (ISO) Technical Management Board 

TSP Proposal for a New Field of ISO Technical Activity (Fr) 

USITACS United States International Telecommunications Advisory Committee for 

 Standardization (DOS) 

USNC United States National Committee 

VA Vienna Agreement (See the definition in NSS) 

WD Working Draft 

WG Working Group 

WTO World Trade Organization 

Questions regarding HUD's standards may be directed to David Engel (202-708-4370, 

ext 5724) or e-mail: David_Engel@hud.gov. 
98

Department of the Interior 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

2 

(a) The Federal Geographic Data Committee (FGDC) Content Standard for Digital 

Geospatial Metadata (CSDGM) 

Use of the Federal Geographic Data Committee (FGDC) Content Standard for 

Digital Geospatial Metadata (CSDGM) was mandated by OMB Circular A-16 

(revised) and precludes the use of voluntary private sector standards as a 

replacement. The Federal Geographic Data Committee (FGDC) is committed to 

using voluntary consensus standards, such as those developed through ISO and 

ANSI, consistent with OMB Circular A-119. FGDC is a strategic member of the 

OpenGIS Consortium (OGC). 

(b) Bureau of Reclamation (BOR) Standard Specification for Corrugated 

Polyethylene Drainage Tubing 

Most BOR construction contracts reference industry standards in the actual 

construction specifications. A prior provision that listed myriad standards was 

removed because the FAR requires that standards be listed with their most current 

approval dates, and this rendered provision maintenance impracticable. 

Government-unique specifications would be incorporated into solicitations 

through one of four provisions prescribed at FAR 11.204. 

 §11.204 Solicitation provisions and contract clauses. 

(a) The contracting officer shall insert the provision at 52.211-1, Availability 

of Specifications Listed in the GSA Index of Federal Specifications, 

Standards and Commercial Item Descriptions, FPMR Part 101-29, in 

solicitations that cite specifications listed in the Index that are not 

furnished with the solicitation. 

(b) The contracting officer shall insert the provision at 52.211-2, Availability 

of Specifications Listed in the DoD Index of Specifications and Standards 

(DoDISS) and Descriptions Listed in the Acquisition Management 

Systems and Data Requirements Control List, DoD 5010.12-L, in 

solicitations that cite specifications listed in the DoDISS or DoD 5010.12-

L that are not furnished with the solicitation. 

 

(c) The contracting officer shall insert a provision substantially the same as 

the provision at 52.211-3, Availability of Specifications Not Listed in the 

GSA Index of Federal Specifications, Standards, and Commercial Item 
99

Descriptions, in solicitations that cite specifications that are not listed in 

the Index and are not furnished with the solicitation, but may be obtained 

from a designated source. 

(d) The contracting officer shall insert a provision substantially the same as 

the provision at 52.211-4, Availability for Examination of Specifications 

Not Listed in the GSA Index of Federal Specifications, Standards, and 

Commercial Item Descriptions, in solicitations that cite specifications that 

are not listed in the Index and are available for examination at a specified 

location. 

2. Number of voluntary consensus standards substituted for government-unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 616 

4. Number of agency employees participating in voluntary consensus standards activities. 

 300 

5. List of voluntary consensus standards bodies in which there was agency participation. 

 19 

 American Petroleum Institute (API) 

American Concrete Institute (ACI) 

American Institute of Steel Construction (AISC) 

American National Standards Institute (ANSI) 

American Society for Testing and Materials (ASTM) 

American Welding Society (AWS) 

Ground Water Protection Council (GWPC) 

International Organization for Standardization (ISO) 

National Association of Corrosion Engineers (NACE) 

Petrotechnical Open Software Corporation (POSC) 

American Society of Photogrammetry and Remote Sensing (ASPRS) 

American Society of Civil Engineers (ASCE) 

American Society of Mechanical Engineers (ASME) 

American Society for Testing and Materials (ASTM International) 

American Concrete Institute (ACI International) 

Institute of Electrical and Electronic Engineers (IEEE) 

American Water Works Association (AWWA) 

Inter-Organizational Resource Information Coordinating Council (IRICC) 
100

State Historic Preservation Offices (SHPO) 

6. How agencies report their use of standards. 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards or (3) both first time and continued uses of standards?

 Both first time and continued use. 

b. Does your agency report (1) the total number of standards it uses or (b) each 

instance where the agency uses (i.e., references) a standard? 

 Both. 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 Both. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

 Yes. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 Yes. 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

Since its issuance, Circular A-119 has worked in a straightforward manner to encourage 

the use of voluntary consensus standards and DOI has as a result increased its 

participation in voluntary standards groups, both domestic and international. The nature 

of the scientific research the DOI performs makes the use of voluntary consensus 

standards a required tool. 

The DOI has attempted to enlist support for the development of its data standards (where 

no voluntary consensus standards exist) both from other agencies and from the public. 

The recognition of interagency efforts in promoting standards seems to be lost in this data 

call. Assistance from the ICSP or NIST may be needed to support these efforts. 

While the guidance in the OMB Circular A-119 appears to be sufficient in the terms of 

outlining the basic functions and responsibilities of federal agency standards activities, 
101

some simplification and clarification of the reporting process appears necessary. Many 

of the definitions provided in the circular reference each other without fully defining the 

word or its implication in operational activities. 

While every attempt was made to provide complete information for this report, DOI as 

well as other agencies may be unaware of the standards they use. It might be useful to 

provide information on the availability of standards and how they can be used. 

8. Conformity assessment activities in which agencies were involved. 

 No report. 

9. Examples or case studies of standards successes. 

 The Department of the Interior submitted one case study of standards success. Interior 

reported that the Minerals Management Service of the Department streamlined its 

financial reporting system thereby increasing productivity and reducing the cost of 

reporting with an electronic reporting solution. 

10. Additional comments. 

 None. 
102

Department of Justice 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 None reported. 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards. 

None. 

3. The number of voluntary consensus standards that your agency used in FY 2002 based 

upon procedures set forth in Sections 11 and 12 of the Circular. 

72 

4. Number of agency employees participating in voluntary consensus standards activities 

during FY 2002. 

5 

5. Name and acronym of voluntary consensus standards bodies in which your agency 

participated during the reporting period. 

 Global Justice Information Network (GLOBAL) 

 Office of Law Enforcement Standards (OLES) of the National Institute of Justice (NIJ) 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

Does your federal agency report: 

(1) Only the first-time use of a standard Yes 

(2) Continued uses of standards No 

(3) Both first-time and continued use of standards No 

Does your agency report: 

(1) The total number of standards it uses Yes 

(2) Each instance where the agency uses a standard No 

Does your agency report multiple editions of a single standard as: 

(1) As one standard used Yes 

(2) As multiple standards used No 

Does your agency report standards that it uses for 

(1) Guidance purposes Yes 
103

(2) Compliance purposes No 

Does your agency report use of standards from non-ANSI 

accredited standards developers including industry 

consortia? 

Yes 

7. An evaluation of the effectiveness of circular A-119 policy and any recommendations for 

changes to the Circular. 

Circular A-119 policy compliance reporting has improved with the emphasis placed on 

understanding the difference between the one-time versus multiple uses of standards. It 

allows greater visibility into the magnitude of voluntary consensus standard utilization. 

8. Identify conformity assessment activities in which your agency has been involved. 

The Office of Science and Technology of the National Institute of Justice (NIJ) in 

collaboration with the National Institute of Standards and Technology (NIST) continues 

to sponsor the Office of Law Enforcement Standards. OLES (a) develops methods for 

testing equipment performance; (b) develops methods for examining evidentiary 

materials; (c) develops standards for equipment and operating procedures; (d) develops 

standard reference materials; and (e) performs other scientific and engineering research 

as required by the criminal justice and public safety communities. This interagency 

cooperative effort results in improvements in the quality and consistency of various 

conformity assessment requirements and processes at the federal, state, and local levels. 

9. Provide any examples of case studies or standards successes. 

The Department sponsors the Global Justice Information Network (GLOBAL) to 

promote interoperability among federal, state, and local law enforcement and public 

safety agencies. This effort currently focuses in two areas (a) data standardization and 

(b) technology standards. The data standardization effort uses commercial technology to 

define information “tags” that allow an organization to completely and unambiguously 

identify information for exchange. By providing a central registry of standard data 

schema, organizations at all levels can build systems to interoperate by implementing 

these data standards. The technology standardization effort provides a registry that 

contains references to voluntary consensus standards in use by organizations at the 

federal, state, and local level. It allows organizations to gain insight into the extent that 

particular standards are being employed by others so that they can make sound decisions 

as to which standards they choose to use when implementing systems. This effort allows 

the standards direction to be “market” driven as it provides visibility into the use of 

standards but does not mandate usage. 

10. No comment. 
104

Department of Labor 

1. As required by P.L. 104-113, you must highlight all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards during FY 2002. 

For each instance, you must identify the specific government-unique standard used and 

the voluntary consensus standard that was not selected. Equally as important, you must 

clearly state your agency’s rationale for such use. 

DOL did not issue any government-unique standards in lieu of voluntary consensus 

standards during FY 2002. It did, however, issue four (4) standards that were based on 

national consensus standards, including the following: 

OSHA: (1) Exit Routes and Signs 

 (2) Signals and Barricades 

MSHA: (1) Electric Motor-Driven Mine Equipment and Accessories and High-

 Voltage Longwall Equipment Standards for Underground Coal 

 Mines 

(2) Hazard Communication 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 0 

3. The number of voluntary consensus standards that your agency used during FY 2002, 

based upon procedures set forth in Sections 11 and 12 of the Circular. 

 200 

Note: The number of standards used has greatly increased from last year because we are 

now counting the number of consensus standards used to support issuance of Section 

5(a)(1) (General Duty clause of the OSH Act) violations. In most cases, the consensus 

standard used is a more current version of a consensus standard that has been 

incorporated by reference in the OSHA standards or a consensus standard addressing an 

area not specifically covered by an OSHA standard. 

4. The number of agency employees participating in voluntary consensus standards 

 activities during this period. 

 60 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 
105

American Conference of Governmental Industrial Hygienists (ACGIH) 

American Industrial Hygiene Association (AIHA) 

American Institute of Mining Engineers (AIMME) 

American National Standards Institute (ANSI) 

Acoustical Society of America (ASA) 

American Society of Mechanical Engineers (ASME) 

American Society for Testing and Materials (ASTM) 

Commercial Vehicle Safety Alliance (CVSA) 

Federal Laboratory Consortium (FLC) 

International Electrotechnical Committee (IEC) 

Institute of Electrical, Electronic Engineers (IEEE) 

International Society for Measurement and Control (ISA) 

National Fire Protection Association (NFPA) 

Society of Automotive Engineers (SAE) 

Underwriters’ Laboratories (UL) 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

 

a. Does your federal agency report (1) only the first-time use of standards, 

continued uses of standards or (3) both first time and continued uses of 

standards? 

 b. DOL reports first time use only. 

c. Does your agency report (1) the total number of standards it uses or (b) 

each instance where the agency uses (i.e., references) a standard? 

 DOL reports the total number used. 

d. Does your agency report multiple editions of a single standard as one 

standard used or as multiple standards used? 

 DOL is counting multiple editions as multiple uses. 

e. Does your agency report standards that it uses for guidance purposes (as 

opposed to, or in addition to, standards used for compliance purposes)? 

 DOL is only counting standards used for compliance purposes, none of the 

uses reported were used for guidance purpose. 

f. Does your agency report use of standards from non-ANSI-accredited 

standards developers including industry consortia? 
106

 DOL does not report non-ANSI accredited standards developers. 

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

 Highly effective, no recommendations for changes are made by DOL. 

8. No comment. 

9. No comment. 

10. No comment. 
107

Department of State

The Department of State has a major policy role in telecommunications standards as obligated by 

international treaty, and coordination roles in other areas. The Bureau of Economic and Business 

Affairs (EB) represents the Department of State on the Interagency Committee on Standards 

Policy (ICSP), the Government Member Council, and the Information Infrastructure 

Standardization Panel (IISP) and its steering committee at the American National Standards 

Institute (ANSI). The Department is not involved in the actual development of technical 

standards. 

 

The Department represents the United States of America administration under the treaty 

obligations found in the Convention of the International Telecommunication Union (ITU), 

Minneapolis, 1998, and the Inter-American Telecommunication Commission (CITEL) of the 

Organization of American States (OAS). The Department of State, through the EB 

Communications and Information Policy Deputate (CIP), provides the forum for development of 

positions and contributions for presentation at ITU and CITEL meetings where international 

telecommunication recommendations (voluntary standards) and telecommunication 

standardization policies are written. The Department authorizes and/or hosts public meetings 

under the Federal Advisory Committee Act, where advice on telecommunication standardization 

and policy issues is offered by the private sector telecommunications industry. The Department 

also bases its decisions on advice from other public sector agencies (DoD, the National Institute 

of Standards and Technology [NIST], the National Telecommunications and Information 

Administration [NTIA], the National Aeronautics and Space Administration [NASA], and the 

Federal Communications Commission [FCC]). The Department coordinates, leads, and/or 

accredits United States delegations to ITU and CITEL technical and policy meetings. 

 

More than 100 U.S. corporations are participating members of the ITU; more than 30 are 

associate members of CITEL’s permanent Consultative Committee, under the sponsorship of the 

State Department. Those companies and interested government agencies participate and play 

major roles in the ITU and CITEL Study Groups and Working Parties that actually write the 

standards. Within that process, a great deal of interaction takes place with other standards setting 

organizations, such as the International Organization for Standardization (ISO), ANSI, ANSIaccredited Committee T1, and the Telecommunications Industry Association. 

 

In addition to accrediting and supporting delegations to the ITU and CITEL, the Department’s 

International Organization Affairs Bureau (IO) accredits and funds participation by relevant 

specialized agencies (the Departments of Agriculture, Commerce, Transportation, and NIST) and 

private sector groups in the deliberations of the Economic Commission for Europe (ECE) 

Working Party on Standardization, especially where they have a direct bearing on U.S. 

commercial interests. While the standards developed in the ECE are not officially adopted for 

use in the United States they serve as guides for adjusting product design and are widely taken 

into account in manufacturing plans. 
108

Department of Transportation 

1. As required by P.L. 104-113, you must highlight all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards during FY 2002. 

For each instance, you must identify the specific government-unique standard used and 

the voluntary consensus standard that was not selected. Equally as important, you must 

clearly state your agency’s rationale for such use. 

RSPA had no instances to report where government-unique standards were used in lieu of 

voluntary consensus standards. 

FRA - There were no instances where FRA used government-unique standards in lieu of 

voluntary consensus standards. 

 

USCG – None. 

FMCSA - 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. 

MARAD – None. 

FTA – None. 

FHWA (ITS) – None. 

NHTSA – None. 

FAA - FAA sets standards in numerous areas pertaining to aviation. FAA’s policy is to 

use voluntary consensus standards where available. In certain cases, such as Capability 

Maturity Model (CMM) standards, FAA modifies them for its own internal use (FAA’s 

system is called the Integrated Capability Maturity Model [iCMM]). We are not aware of 
109

an instance where FAA uses government-unique standards in lieu of voluntary consensus 

standards. 

2 Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period as a result of an agency 

review under section 15b(7) of the Circular. 

RSPA – None. 

FRA – None. 

USCG – None. 

MARAD – None. 

FMCSA – None. 

FTA – None. 

FHWA – None. 

NHTSA – None. 

FAA – None. 

3. The number of voluntary consensus standards that your agency used during FY 2002 

based upon procedures set forth in Sections 11 and 12 of the Circular. 

RSPA’s Office of Hazardous Materials Safety has used approximately 120 voluntary 

standards and its Office of Pipeline Safety has used approximately 70 voluntary standards 

based on the procedures set forth in Sections 11 and 12 of the Circular. 

FRA has used two voluntary consensus standards under Section 11 of the circular. 

USCG – None. 

FMCSA - The following six standards have been adopted in place of government-unique 

standards: Underwriters Laboratories, Inc. (49 CFR 393.95), American Society for 

Testing and Materials (49 CFR 393.102), National Association of Chain Manufacturers 

(49 CFR 393.102), Web Sling and Tiedown Association (49 CFR 393.102), Wire Rope 

Technical Board (49 CFR 393.102), and the Cordage Institute (49 CFR 393.102). 

MARAD – None. 

FTA – None. 
110

FHWA – The ITS Standards Program does not itself use or require use of standards. 

However, the Program has cooperative agreements with five standards development 

organizations (SDOs) and supports the development and deployment of almost 100 

voluntary consensus standards that they are producing. The standards are for intelligent 

transportations systems deployed by state, regional, and local transportation agencies, as 

well as by private-sector organizations. 

NHTSA – Five. 

Air Brake Systems (66-FR-64154, December 12, 2001), amended the truck air brake 

system standard to clarify the test procedures. NHTSA adopted portions of an SAE 

standard. 

Tires (67-FR-10050, March 5, 2002), Notice of Proposed Rulemaking responded to the 

Transportation Recall Enhancement, Accountability, and Documentation Act of 2000, 

requiring a revised, updated tire standard. The proposal models part of the new standard 

on an existing SAE standard. 

Low Speed Vehicles (67-FR-46149, July 12, 2002), Notice of Proposed Rulemaking 

responded to petitions on low-speed vehicles to be equipped with safety warning labels 

and conspicuity features. The proposal uses of various SAE and American Society of 

Agricultural Engineers (ASAE) voluntary standards. 

Moving Barrier Tires (66-FR-51629, October 10, 2001), NHTSA issued a notice of 

proposed rulemaking to update the Federal Motor Vehicle Safety Standards (FMVSS) on 

side impact protection and fuel system integrity by requiring that radial tires of certain 

specifications, rather than bias ply tires, be used on the moving barriers specified in those 

standards. One of the two tire types under consideration came from a SAE recommended 

practice, J972 “Moving Rigid Barrier Collision Tests.” 

Advanced Air Bags (66-FR-65376, December 18, 2001), NHTSA issued a final rule that 

responded to petitions for reconsideration of the May 12, 2000, FMVSS No. 208 final 

rule on advanced air bags. In that final rule we incorporated out-of-position tests that 

were originally developed by the International Standards Organization (ISO) as part of 

the proposed low-risk deployment test requirements using the small female dummy on 

the driver-side and the 3-year-old and 6-year-old dummies on the passenger-side. This 

notice made amendments to those test procedures in response to the petitions for 

reconsideration. 

 

FAA – See following list. 

 

iCMM, ISO 9001:2000 and Revised Management Plan for Explosives Detection System 

Certification Testing 
111

ISO (various series) 

CMM (various series) 

IEEE 1074-1997 “IEEE Standard for Developing Software Life Cycle Processes” 

IEEE 1016-1998 “IEEE Recommended Practice for Software Design” Descriptions” (sets 

the standard for documenting designs for software, either via paper or software 

documentation tools) 

Mil Std. 1472 

 

MIL-E-1H (or latest version) 

Boff Engineering Data Compendium 

SAE G10 HF group 

“Human factors issues in free flight” (ARD-50057) 

“Minimum human factors standards for air traffic services provided via data 

communications utilizing the ATN, Builds 1 and 1A” (RTCA/DO-256) 

 

ANSI z39.5, z39.18 

ANSI standard “Guide to Human Performance Measurement” G-035-1992 

ANSI/HFS 100-1988, The American National Standard for Human Factors Engineering 

of Visual Display Terminal Workstations 

MARC 21, The Project Management Institute (PMI) Project Management Body of 

Knowledge (PMBOK) standard gives an outline to follow for projects, including 

software, engineering, construction, etc. 

ANSI/ASQC, Quality System-Model for Q9001-1994 Quality Assurance in Design, 

Development, Production, Installation, and Servicing 

ANSI/ISO/ASQC Q9001-1994, Quality Systems-Model for Quality Assurance in Design, 

Development, Production, Installation, and Servicing 

ANSI/ISO/ASQC Q9002-1994, Quality Systems-Model for Quality Assurance in 

Production, Installation, and Servicing 

ANSI/ISO/ASQC Q9003-1994, Quality Systems-Model for Quality Assurance in Final 

Inspection and Test 
112

FAA-E-2892B, WAAS Functional and Performance Specification 

FAA-D-2494B, Technical Instruction Book Manuscript: 

Electronic, Electrical, and Mechanical Equipment, Requirements for Preparation of 

Manuscript and Production of Books 

FAA-E-2749A, Radio Communications Links 

FAA-E-2786, Data Multiplexing Network (DMN) Equipment Specification 

FAA-G-1375C, Spare Parts-Peculiar for Electronic, Electrical and Mechanical 

Equipment 

FAA-G-2100F, Electronic Equipment, General Requirements 

FAA-D-2706, Theory of Operations, Examinations, Preparation, and Validation of 

FAA-D-2781, Preparation of Validation for Performance Exams 

ANSI-STD-X3.159-1987, C Programming Language 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 

RSPA – 43 

FRA - 8 

FMCSA – 17 

MARAD – 10 

FHWA -12 

FTA – 6 

NHTSA – 20 

FAA – 60 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

Air Movement and Control Association (AMCA) 

American Association of State Highway and Transportation Officials (AASHTO) 
113

American Boat and Yacht Council (ABYC) 

American Bureau of Shipping (ABS) 

American National Standards Institute, Inc. (ANSI) 

American Petroleum Institute (API) 

American Public Transportation Association (APTA) 

American Railway Engineering and Maintenance-of-Way Association (AREMA) 

American Society for Testing and Materials (ASTM) 

American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) 

American Society for Nondestructive Testing (ASNT) 

American Society of Mechanical Engineers (ASME) 

Association of American Railroads (AAR) 

Canadian General Standards Board Tank Car Committee 

Compressed Gas Association (CGA) 

Cordage Institute (CIA) 

Expansion Joint Manufacturers Association (EJMA) 

Factory Mutual Engineering and Research (FMER) 

Fluids Control Institute (FCI) 

Groupe deTravail Brussels 1958 (GTB) 

Illuminating Engineering Society of North America (IES) 

Institute of Electrical and Electronics Engineers (IEEE) 

Institute of Transportation Engineers (ITE) 

International Association of Drilling Contractors (IADC) 

International Atomic Energy Agency (IAEA) 

International Cargo Gear Bureau (ICGB) 

International Civil Aviation Organization (ICAO) 

International Commission on Illumination (ICI) 

International Electrotechnical Commission (IEC) 

International Maritime Organization (IMO) 

International Organizations for Standardization (ISO) 

International Society for Measurement and Control (ISA) 

International Telecommunication Union Radiocommunication Bureau (ITU-R) 

ITS America (ITS) 

Lloyd’s Register of Shipping (LR) 

Manufacturers Standardization Society of the Valve and Fittings Industry (MSS) 

NACE International (NACE) 

National Board of Boiler and Pressure Vessel Inspectors 

National Electrical Manufacturers Association (NEMA) 

National Fire Protection Association (NFPA) 

North American Transport of Dangerous Goods Standard (NATDGS) Working Group 

Oil Companies International Marine Forum (OCIMF) 

Organization for Economic Cooperation and Development (OECD) 

Radio Technical Commission for Maritime Services (RTCM) 

Society of Automotive Engineers (SAE) 

Technology and Maintenance Council (TMC) 

The American Association of Motor Vehicle Administrators (AAMVA) 
114

The Commercial Vehicle Safety Alliance (CVSA) 

The National Safety Council (NSC) 

Transportation Research Board (TRB) 

Tubular Exchange Manufacturers Association (TEMA) 

Underwriters’ Laboratories, Inc. (UL) 

United Nations Committee on the Transport of Dangerous Goods 

United Nations Economic Commission for Europe (ECE) 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. Specifically, you should be prepared to answer the following questions: 

(Note: Questions will be structured on the web entry database to accept either “Yes/No” 

or multiple-choice responses.) 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards or (3) both first time and continued uses of standards? 

b. Does your agency report (1) the total number of standards it uses or (b) each 

instance where the agency uses (i.e., references) a standard? 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

RSPA–In reporting the total number of standards that it uses, RSPA has counted 

each standard once, not each instance where a standard is referenced, or each 

edition of a standard. RSPA is reporting the standards that are incorporated in its 

regulations. RSPA has reported both first time and continued use of voluntary 

standards. Thus, new standards are included in this overall total. The total 

number is increased to reflect newly added standards or reduced to reflect 

standards that have been dropped, as appropriate. 

FRA–reports only the first time a standard is referenced in a given Part of 49 

CFR, the total number of standards used in proposed rules or final rules that were 

published during the reporting period, multiple editions of a single standard as 

one standard, FRA reports standards used for compliance purposes, and use of 

standards from industry associations which are not (to our knowledge) ANSI 

accredited. 

MARAD is not a user. 
115

FTA - First time and continued use, reports the total number of standards it uses, 

multiple editions of a standard used are reported as one standard used, standards 

used for guidance purposes are reported, and uses non-ANSI accredited standards 

organizations. 

FHWA - Reports first time and continued use, reports the total, multieditions are 

considered as one, standards for guidance are reported, and non ANSI-accredited 

developed are used. 

NHTSA - Reports only the number of new uses of standards. Counts all 

references to a particular standard as a single count. Multiple editions are counted 

as one standard. Some standards are from non-ANSI developers. 

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

RSPA, FRA, FMCSA, MARAD, FTA, FHWA, NHTSA, and FAA have no 

recommendations to change OMB Circular A-119 at this time. 

8. Any conformity assessment activities in which your agency has been involved in the 

reporting period as described in the Federal Register, Vol. 65, No. 155, Thursday, 

August 10, 2000, Guidance on Federal Conformity Assessment Activities. 

FRA’s conformity assessment activities are visible internationally through expanded 

efforts in the area of safe, uniform international transport of hazardous materials by 

participation in the Canadian General Standards Board Tank Car Committee and the 

ASME Transportation Pressure Vessel Committee, as well as continuing to participate in 

the North American Transport of Dangerous Goods Standard (NATDGS) Working 

Group and the AAR Tank Car Committee, as reported last year. Participation in the six 

voluntary consensus standards bodies listed above, as well as in numerous committees 

and sub-committees of those bodies, gives FRA access to the developmental stages of 

private sector conformity assessment standards to make sure the agency viewpoint is 

considered in the development of their standards. 

 

FMCSA–The FMCSA has used, or proposed, voluntary consensus standards agreed to by 

the Commercial Vehicle Safety Alliance’s Information Systems Committee to determine 

what data elements should be collected and coded into State and national inspection and 

crash files. The decisions agreed to by this committee affect State enforcement 

personnel, the trucking industry, and anyone using the safety data. As called for in 

Section 225 of the Motor Carriers Safety Improvement Act of 1999 (Public Law 106-159, 

113 Stat. 1748), the FMCSA has worked with the National Highway Traffic Safety 

Administration and the States to adopt the Commercial Vehicle Analysis Reporting 

System (CVARS). Since the beginning of calendar year 2001, an average of one staff 

member has participated in meetings with a number of states to gauge their commitment 

to participating in this new crash data collection approach. Although still in the pilot 
116

stage, the FMCSA asked states to ensure that certain crash data are reported in an 

accurate, timely, and complete manner. 

9. Examples or case studies of your agency’s standards successes, if you so choose. 

FRA - An example that has benefited both the agency and the private sector is FRA’s 

work with the AAR Locomotive Committee to develop a standard for design, inspection, 

and maintenance of Remote Control Locomotives and Remote Control Transmitters. The 

payoff for this joint effort is to make the industry self-regulating to reduce or eliminate 

the need for federal regulation of this burgeoning technology. 

10. Comments.

While the U.S. Coast Guard had adopted some industry standards in its regulations for 

many more years, in 1968 we made sweeping incorporations by reference of industry 

standards in our machinery and electrical regulations. At the same time, we started to be 

involved in standards organizations - at one time participating in over 200 standards 

committees. With the reduction in personnel and travel funds, we have pared down our 

involvement to the more important committees. During this time we have promoted the 

formation of several standards committees, most notably the ASTM F25 Committee on 

Ships and Marine Technology where we have developed a number of standards that have 

replaced CG regulations and Navy MILSPECS. We have involved the international 

community in this committee and have taken a leadership role in ISO TC 8 Ships and 

Marine Technology. We are the U.S. voting representative and the CG is the Secretariat 

for three of the Subcommittees. We have actively supported the adoption of ISO 

standards at the International Maritime Organization for inclusion in the SOLAS and 

MARPOL Conventions. We are also promoting development of ISO standards so, one 

day, we can accept foreign approved Life Saving Appliances (life jackets, lifeboats, etc) 

and have U.S. Approved LSA's accepted overseas. 

In the past, we have also worked with our Naval Engineering Office to adopt industry 

standards in lieu of MILSPECS for CG vessels. We understand that our Deepwater 

project is going all out to use industry standards where at all possible. 

Our training consists of on–the–job–training. We find the best way to understand 

industry standards and their organizations is to participate in them and have an 

experienced mentor to offer guidance. We find this works with industry folks as well. In 

the past when an industry person looks at the instructions on developing a standard, they 

say it is too hard and never call back. Now, when they call and ask about developing a 

standard, we say great, you are in charge of the drafting group, put together an outline of 

the standard, and send it to me in two weeks. We then send to their competitors and 

interested government people and tell them we are developing a standard, do you want to 

participate. The competitors always say yes, it’s amazing. 

Participating on a Standards Committee provides leadership, management, and 

scientific/engineering training to our young engineering graduates that they could never 
117

get in a classroom or years of working in one office. Also, I can't tell you the number of 

times I have had to call a materials or welding expert when our field inspectors call with 

various problems from leaking steam boilers on 50 - 75 year old passenger steamboats to 

welding the latest thermally controlled rolled steel for a chemical tanker. This kind of 

"free" advice could never (be obtained) no matter how many government support 

contracts we have. Participating on a Standards Committee is a way of multiplying our 

limited human resources - The ASME Boiler and Pressure Vessel Committee alone 

provides over $1M of volunteer labor annually. This Code forms the basis of our 

Machinery and Piping regulations and is adopted throughout 46 CFR Parts 52, 53, 54, 

and 56. 
118

Department of the Treasury 

1. As required by P.L. 104-113, identification of all instances when the agency used 

government-unique standards in lieu of voluntary consensus standards. For each instance 

identify the specific government-unique standard used and the voluntary consensus 

standard that was not selected. Clearly state the rationale for such use. 

 4 

U.S. Customs continues to support two government unique standards; Customs and Trade 

Automated Interface Requirements (CATAIR) (Amendment 1, April 1996, Amendment 

2, December 1996, Amendment 3, September 1997, and Amendment 4, 1998), and 

Customs Automated Manifest Interface Requirements (CAMIR) (Amendment 1, April 

1997, and Amendment 2, July 1998). CATAIR is used by the Customs brokerage 

industry, and CAMIR is used by some parties in the transportation sector. Voluntary 

consensus standards used by Customs include the ANSI ASC X12 syntax and the United 

Nations EDIFACT record sets. This industry standard is being used for the receipt of 

electronic invoices from FedEx and Citibank for the FleetCard program. It is also being 

used by the Automated Export System trade users to transmit their data to Customs. 

U.S. Customs policy requires that the management of Information Technology (IT) 

Investments conform to the requirements of the Investment Management Process (IMP) 

System Description, Version 2.1, dated March 15, 2000. This requirement has been 

developed in response to a key goal of the Clinger-Cohen Act. The goal is that agencies 

have processes and information in place to help ensure that IT projects are being 

implemented at acceptable costs, within reasonable and expected time frames, and are 

contributing to tangible, observable improvements in mission performance. The IMP 

uses the government-unique standard: "Assessing Risks and Returns: A Guide for 

Evaluating Federal Agencies' IT Investment decision-making," General Accounting 

Office (GAO/AIMD-10.1.13), in lieu of voluntary consensus standard ISO/IEC Software 

Process Improvement and Capability determination (SPICE, 15504). 

U.S. Customs requires that systems documentation be prepared in conformance with its 

Systems Development Life Cycle (SDLC) procedures. The requirement is based on the 

need to ensure enterprise wide standards in areas such as security. The SDLC uses the 

government-unique standards: “Information Systems Life Cycle Manual,” U.S. Treasury 

Department (TDP 84-01), in lieu of voluntary consensus standard ISO/IEC, IEEE 

Information Technology - Software Life Cycle Processes (12207), and the Software 

Capability Maturity Model Software Engineering Institute (SEI/SW-CMM, Version 1.1), 

in lieu of voluntary consensus standard ISO/IEC International Quality Standard (9001). 

2. Identification of voluntary consensus standards that have been substituted for 

government-unique standards because of an agency review under section 15b (7) of the 

Circular. 
119

 0 

No voluntary consensus standards have been substituted for government-unique 

standards because of agency review of existing standards. The maintenance of the 

government unique standards within Customs applications, the CATAIR and CAMIR 

formats, are at the request of the participating industry groups that use those standards. 

Bureaus reported following the Software Engineering Institute (SEI) Carnegie Mellon 

University's Capability Maturity Model (CMM). 

3. The number of voluntary consensus standards that the agency has used during FY 2002 

based on the procedures set forth in sections 11 and 12 of the Circular. 

 334 

 U.S. Customs Service has used three voluntary consensus standards since October 1, 

1999. The IRS Standards volume is a component of the IRS Enterprise Architecture. 

There are 235 standards contained within the Enterprise Architecture. The PRIME 

Contractor must follow the Enterprise Architecture for all project development and 

acquisitions often reference the Enterprise Architecture standards profile with 

approximately 235 standards. Depending on the nature of the individual project or 

acquisition, many of the standards may not apply. The Bureau of the Public Debt 

reported the use of 96 voluntary consensus standards. The remaining Treasury bureaus 

reported that an unknown number of voluntary consensus standards were used because of 

implementing commercial-off-the-shelf hardware and software. 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 66 

There are 8 members of the NCBFAA ABI Automation Committee, 50 people participate 

in Task Group 9, 2 people participate in SEI and DC SPIN, 1 person participates on the 

ANSI Standard 43.3-1993 sub-committee for non-medical X-Ray and Sealed Gamma 

Ray sources, 1 person participates on sub-committee of the American National Standards 

Institute revising the ANSI Standard 43.17, 2 people participate in the G7 Initiative, and 

10 employees (approximately) participated in TIGERS. 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

Customs continues to participate in the National Customs Brokers and Forwarders 

Association of America (NCBFAA) Automatic Broker Interchange (ABI) Automation 

Committee standards development body. This committee established government unique 
120

standards and certification criteria for exchange of data between Customs and automated 

importers and brokers. 

Customs chairs Task Group 9 under the Transportation Subcommittee (I) of the 

American National Standards Institute (ANSI) Accredited Standards Committee (ASC), 

X12. This group develops and maintains all transaction sets and record segments in the 

Customs transaction sets. Customs participates on a sub-committee of the American 

National Standards Institute revising the ANSI Standard 43.3-1993 for non-medical XRay and Sealed Gamma Ray sources. 

Customs also participates in two voluntary consensus standards bodies: Software 

Engineering Institute (SEI) Carnegie Mellon University, and the Washington, D.C., 

Software Process Improvement Network (DC SPIN). 

Customs participates in the Group of 7 (G7) Initiative, an effort to harmonize customs 

procedures among the G7 countries: United States, United Kingdom, Germany, France, 

Canada, Japan, and Italy. Declarations and cargo reports for imported and exported 

goods are being developed. A trader will be able to use the same message structure to 

report to any of the seven countries, eliminating the need to use country-specific data 

interchanges. Messages are being developed in the only United Nations recognized data 

interchange standard, Electronic Data Interchange for Administration, Commerce, and 

Trade (EDIFACT). 

The Internal Revenue Service participates on the TIGERS (Tax Information Group for 

Electronic-communication Requirements Standardization) a working group of (ASC 12). 

The Financial Management Service (FMS) fully supports the federal requirement to use 

technology standards. In the area of electronic data interchange (EDI), FMS has 

participated in the standards development process and implemented EDI using the 

American National Standards (ANSI) Accredited Standards Committee (ASC) X12 

standard. FMS initiated EDI standards compliance with the requirements first outlined in 

the Federal Information Processing Standards 161-2, April 29, 1996. 

Development of extensible markup language (XML) standards, United Nations Centre 

for Trade Facilitation and Electronic Business (UNI/CEFACT) Electronic Business 

Extensible Markup Language (ebXML) and ANSI ASC X12, with the intention of 

implementing the most appropriate XML standard. 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. Specifically, you should be prepared to answer the following questions 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards or (3) both first time and continued uses of standards? 

 Yes for item number (3). 
121

b. Does your agency report (1) the total number of standards it uses or (b) each 

instance where the agency uses (i.e., references) a standard? 

 Yes for item number (b). 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 Yes, our agency reports multiple editions of a single standard as one standard 

used. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

 Yes. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 Various bureaus reported both yes and no for this element. 

7. An evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

The guidelines in Circular A-119 are effective. Circular A-119 has placed the focus on 

using voluntary consensus standards as opposed to the development of governmentunique standards. Wide use of voluntary consensus standards promotes the development 

of an increased number of standards compliant products facilitating the use of new 

technology and increasing flexibility to meet new requirements. No recommendations 

for changes at this time. 

8. Any conformity assessment activities in which the agency has been involved in the 

reporting period as described in the Federal Register, Vol. 65, No. 155, Thursday, 

 August 10, 2000, Guidance on Federal Conformity Assessment Activities. 

The standards that Treasury bureaus have adopted will involve conformity assessment 

activities, which include internal audit and eventual certification in conformance with 

acceptable practices. 

9. No comment. 

10. No comment. 
122

Department of Veterans Affairs 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

2. Number of voluntary consensus standards substituted for government-unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 0 

4. Number of agency employees participating in voluntary consensus standards activities. 

 14 

5. List of voluntary consensus standards bodies in which there is agency participation. 

 20 

Interagency Committee on Seismic Safety in Construction (ICSS) 

 National Institute of Building Sciences (NIBS) 

 NIBS Construction Metrication Counsel 

 NIBS Building Product Pre-Approval Program for Federal Construction 

 NIBS Whole Building Design Guide (WBDG) 

 American National Standards Institute (ANSI) A-117 Committee 

 Architecture and Transportation Barrier Compliance Board (ATBCB) 

 Federal Facilities Council (FFC) 

 Builders Hardware Manufacturers Association (BHMA) 

 American Institute of Timber Construction (AITC) ANSI/AITC A190.1 Committee 

 National Fire Protection Association National Electrical Code (NFPA 70) Committee 

 American Society of Heating and Air Conditioning and Refrigeration Engineers 

 (ASHREA) 

 American Society for Testing Materials (ASTM) 

 Joint Commission on Accreditation of Healthcare Organizations (JCAHO) 

 American National Standards Institute (ANSI) 

 American Industrial Hygiene Association (AIHA) 

 National Institute for Occupational Safety and Health (NIOSH) 

 American Society of Mechanical Engineers Safety Code for Elevators and Escalators 

 Committee (ASME A-17 Committee) 

 American Society of Hospital Engineers (ASHE) 

 Uniform Building Code (UBC) 
123

6. How does your agency report the use of standards? 

a. Does your federal agency report only the first-time use of standards, continued 

uses of standards or both first time and continued use? 

 Both first time and continued use of standards. 

b. When reporting standards use, some agencies report uses of standards. That is, 

they count the total number of instances where the agency has referenced a 

standard. For example, three separate references to a single standard are counted 

as three standards uses. On the other hand, other agencies report standards used. 

These agencies report the number of standards that the agency references. In this 

case, each standard is counted only once regardless of how many times it is 

referenced by the agency. Using these definitions, how does your agency report? 

 Uses of standards. 

c. Does your federal agency report multiple editions of a single standard as one 

standard or as multiple standards used? 

 Multiple. 

d. Does your federal agency report standards that it uses for guidance purposes (as 

opposed to compliance purposes)? 

 Yes. 

e. Does your federal agency report use of standards from non-ANSI-accredited 

standards developers including industry consortia? 

 No. 

7. Provide an Evaluation of the Effectiveness of Circular A-119 Policy and 

Recommendations for Any Changes. 

 The Veterans Health Administration accepts and conforms to standards developed by the 

Joint Commission on Accreditation of Healthcare Organization (JCAHO) for Veterans 

Affairs' (VA) health care facilities. Voluntary consensus standard requirements are 

utilized in the regulatory, contractual, and grants determinations executed by the Veterans 

Health Administration. 
124

8. Provide the conformity assessment activities in which the agency has been involved. 

 The VA does not engage in conformity assessment activities. The VA strives to use 

industry based standards and commercial off-the-self products. 

9. Provide any examples or case studies of standards successes. 

 No comment. 

10. Comments. 

 Federal regulations prescribe standards that must be used (e.g., EPA laboratory standards 

and OSHA monitoring/sampling standards). Regardless of what may be developed by 

conformity assessment, VA is not relieved of it obligation to use standards prescribed by 

regulations. When not obligated to use a prescribed regulatory or other (e.g., JCAHO) 

standard, VA organizations must retain the flexibility to use the standard that best meets 

its programmatic needs. 
125

APPENDIX B -- REPORTS OF INDEPENDENT AGENCIES AND COMMISSIONS 

This section contains the reports of the independent agency and commission reports as submitted 

by the agencies and commissions to NIST. Due to the need to have this year’s information 

submitted via e-mail rather than through NIST’s online process, many different formats were 

used by the various agencies and commissions to submit their information. Several agencies and 

commissions chose not to address the voluntary questions 7, 8, and 9. The information in this 

section reflects NIST’s effort to present in a consistent format all of the data the agencies and 

commissions chose to submit. The substantive text and numerical responses of each agency’s 

and commission’s report remains as submitted. 

The format NIST has chosen to present the submitted data is as follows: 

Name of Independent Agency or Commission 

1. Number of government-unique standards used in lieu of voluntary consensus 

standards. 

2. Number of voluntary consensus standards substituted for government-unique 

standards. 

3. Number of voluntary consensus standards used in FY 2002. 

4. Number of agency employees participating in voluntary consensus standards 

activities. 

5. List of voluntary consensus standards bodies in which there was agency 

participation. 

6. How agencies report their use of standards. 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for 

any changes. 

8. Conformity assessment activities in which agencies were involved. 

9. Examples or case studies of standards successes. 

10. Additional comments. 
126

Agency for International Development 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

2. Number of voluntary consensus standards substituted for government unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 0 

4. Number of agency employees participating in voluntary consensus standards activities. 

 0 

5. List of voluntary consensus standards bodies in which there is agency participation. 

 N/A 

6. The following questions relate to how your agency reports its use of standards. Please 

 consider them carefully and answer each question to the best of your ability. 

a. Does your federal agency report only the first-time use of standards, continued 

uses of standards or both first time and continued uses of standards? 

 Both. 

b. Please read the following brief explanation before responding to this question. 

When reporting standards use, some agencies report uses of standards. That is, 

they count the total number of instances where the agency has referenced a 

standard. For example, three (3) separate references to a single standard are 

counted as three standards uses. On the other hand, other agencies report 

standards used. These agencies report the number of standards that the agency 

references. In this case, each standard is counted only once regardless of how 

many times it is referenced by the agency. 

 Using the above definitions, your agency reports: 

 Standards Used. 
127

c. Does your federal agency report multiple editions of a single standard as one 

standard or as multiple standards used? 

 Multiple. 

d. Does your federal agency report standards that it uses for guidance purposes (as 

opposed to compliance purposes)? 

 

 No. 

e. Does your federal agency report use of standards from non-ANSI-accredited 

standards developers including industry consortia? 

 

 Not Applicable. 

7. Provide an evaluation of the effectiveness of Circular A-119 policy and recommendations 

for any changes. 

 USAID has no suggestions for changing Circular A-119. 

8. Provide the conformity assessment activities in which the agency has been involved. 

USAID participates in the Contractor Performance Reporting system developed and 

managed by the National Institutes for Health, including participating as a member of the 

committee that determines information requirements. This may be considered a 

conformity assessment activity since it is standardizing the way that the participating 

agencies assess contractors' performance. 

9. Provide any examples or case studies of standards successes. 

 Nothing to report. 

10. Comments. 

 N/A 
128

Consumer Products Safety Commission 

1. Number of government-unique standards used in lieu of voluntary standards. 

 0 

2. Number of voluntary consensus standards substituted for government 

 unique standards. 

 1 

 voluntary standard ASTM F977 

 government standard FR/Vol. 67, No. 90/May 9, 2002, pp 31165-31166 

3. Number of voluntary consensus standards used in FY 2002 (Transactional). 

 1 

4. Number of agency employees participating in voluntary consensus standards activities. 

 29 

5. Number of voluntary consensus standards bodies in which there is agency participation. 

 8 -- ANSI, ASME, ASTM, CSA, DASMA, NFPA, SVIA, and UL 

6. How We Report: 

 a. Report only first-time use of standards, 

 b. Report the total number of standards used, 

 c. Report multiple editions as one standard used, 

 d. Do not report standards used for guidance, 

e. Report use of standards from non-ANSI -accredited standards developers but not 

consortia. 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

During FY 2002, the Commission’s efforts to enhance voluntary safety standards 

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

There are no recommendations for changes in the Circular at this time. 

8. Conformity assessment activities in which the agency was involved. 

 No response. 
129

9. Provide any examples or case studies of standards successes. 

The CPSC staff provided technical support to the development of 14 new, revised, or 

reaffirmed voluntary consumer product safety standards, which were completed in 

FY 2002. The Commission had 28 employees directly participating in 60 voluntary 

standards development projects during FY 2002. 

10. Comments. 

The U.S. Consumer Product Safety Act (CPSA), as amended, requires the Commission to 

defer to issued voluntary standards, rather than promulgate mandatory standards, when 

the voluntary standards will eliminate or adequately reduce the risk of injury addressed 

and it is likely that there will be substantial compliance with the voluntary standards. In 

addition, the Commission is required, after any notice or advance notice of proposed 

rulemaking, to provide technical and administrative assistance to persons or groups who 

propose to develop or modify an appropriate voluntary standard. Additionally, the 

Commission is encouraged to provide technical and administrative assistance to groups 

developing product safety standards and test methods, taking into account Commission 

resources and priorities. 

 

Since its inception in 1973, the Commission has promoted the development of voluntary 

product safety standards. Policy statements in support of voluntary standards were 

published by the CPSC in 1975 and 1978. These policy statements were updated in 1988 

(16 U.S.C. 1031), and a staff directive on implementation of portions of these policy 

statements was promulgated in 1989 and updated in October 2001. 

Since the principles set forth in the OMB Circular A-119 Rev. were published, the 

Commission has consistently supported them. The CPSC Voluntary Standards 

Coordinator, who also serves as the CPSC’s Standards Executive for implementing OMB 

Circular A-119 Rev., provides general oversight for staff involvement in existing 

standards projects. The Voluntary Standards Coordinator establishes agency views on 

standards issues and decisions through Commission response to staff briefing packages 

and recommendations. These views are reflected in the Commission’s Operating Plan 

and Budget. Coordinating participation within the Commission and with others in 

voluntary standards activities is a responsibility of the Voluntary Standards Coordinator. 

Likewise, the Voluntary Standards Coordinator is responsible for meeting reporting 

requirements applicable to voluntary standards involvement of Commission staff. 
130

Environmental Protection Agency 

The Environmental Protection Agency is pleased to submit the following report on the Agency’s 

implementation of the NTTAA and the OMB Circular A-119. The reporting elements are listed 

below according to the format and guidance provided by NIST in the October 10, 2002, 

memorandum from the chair of the Interagency Committee on Standards Policy (ICSP). 

1. Use of government-unique standards in lieu of existing and potentially applicable 

voluntary consensus standards. 

 In 75 separate considerations, EPA rejected 38 different voluntary consensus standards. 

Note, however, that EPA did not develop new, government unique standards but in each 

case chose an existing EPA method. 

 The following table provides the name of the standard rejected, the name of the 

government unique standard used and the reason for the rejection. 

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

164 

ASTM D3154-00 - 

Standard Method for 

Average Velocity in 

a Duct (Pitot Tube 

Method) 

EPA 

Methods 1, 

2, 2C, 3, 3B, 

4 

This standard appears to cover EPA’s Part 

60 Methods 1, 2, 2C, 3, 3B, 4, but lacks in 

quality control and quality assurance 

requirements. Specifically, ASTM D3154-

00 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. 

 

ASTM D3464-96 

(2001) - Standard 

Test Method 

Average Velocity in 

a Duct Using a 

Thermal 

Anemometer 

EPA Method 

2 

The applicability specifications in this 

ASTM standard are not clearly defined, 

e.g., range of gas composition, temperature 

limits. In addition, 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. 
131

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 10780:1994 - 

Stationary Source 

Emissions - 

Measurement of 

Velocity and 

Volume Flowrate of 

Gas Streams in 

Ducts 

EPA Method 

2 

ISO 10780:1994 recommends the use of an 

L-shaped pitot, which historically has not 

been recommended by EPA. The EPA 

specifies the S-type design that has large 

openings that are less likely to plug up with 

dust. 

 

ISO 10396:1993 - 

Stationary Source 

Emissions: 

Sampling for the 

Automated 

Determination of 

Gas Concentrations 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ISO 10396 

does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). This standard is also very similar to 

ASTM D5835. 

 

ASTM D5835-95 - 

Standard Practice 

for Sampling 

Stationary Source 

Emissions for 

Automated 

Determination of 

Gas Concentration 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ASTM D5835-

95 does 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; (7) 

specifications for data recorders, in terms 
132

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). This standard is also 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 

EPA Method 

3A 

This standard is unacceptable as a 

substitute for EPA Methods 3A, 6C, 7E, 

10, 10A since 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 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. 

 

ISO 12039:2001 - 

Stationary Source 

EmissionsDetermination of 

Carbon Monoxide, 

Carbon Dioxide, 

and Oxygen – 

Automated Methods 

 

This ISO standard is unacceptable as 

substitute for EPA Method 3A because it 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. In 

addition, ISO 12039:2001 does not specify 

performance criteria for calibration error, 

calibration drift, or sampling system bias 

tests, as in the EPA method, although 

checks of these quality control features are 

required by the ISO standard. 
133

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 14965:2000(E) 

- Air Quality -

Determination of 

Total Nonmethane 

Organic Compounds 

- Cryogenic 

Preconcentration 

and Direct Flame 

Ionization Method 

EPA 

Methods 25, 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 10-ppm carbon. 

A method whose upper limit is 10-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

 

EN 12619 (1999) - 

Stationary Source 

EmissionsDetermination of the 

Mass Concentration 

of Total Gaseous 

Organic Carbon at 

Low Concentrations 

in Flue GasesContinuous Flame 

Ionization Detector 

Method 

EPA Method 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 40-ppm carbon. 

A method whose upper limit is 40-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

186 

ASTM D3154-00 - 

Standard Method for 

Average Velocity in 

a Duct (Pitot Tube 

Method) 

EPA 

Methods 1, 

2, 2C, 3B, 4 

This standard appears to cover EPA’s Part 

60 Methods 1, 2, 2C, 3, 3B, 4, but lacks in 

quality control and quality assurance 

requirements. Specifically, ASTM D3154-

00 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. 

 

ASTM D3464-96 

(2001) - Standard 

Test Method 

Average Velocity in 

a Duct Using a 

Thermal 

Anemometer 

EPA Method 

2 

The applicability specifications in this 

ASTM standard are not clearly defined, 

e.g., range of gas composition, temperature 

limits. In addition, 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 
134

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

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 

EPA Method 

2 

ISO 10780:1994 recommends the use of an 

L-shaped pitot, which historically has not 

been recommended by EPA. The EPA 

specifies the S-type design that has large 

openings that are less likely to plug up with 

dust. 

 

ASTM D6060-96 

(in review 2000) - 

Practice for 

Sampling of Process 

Vents with a 

Portable Gas 

Chromatography 

EPA Method 

18 

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. 

 

ISO 14965:2000(E) 

- Air Quality -

Determination of 

Total Nonmethane 

Organic Compounds 

- Cryogenic 

Preconcentration 

and Direct Flame 

Ionization Method 

EPA 

Methods 25 

and 25A 

This standard is an impractical alternative 

to EPA Method 25 and 25A because it 

does not measure solvent process vapors in 

concentrations greater than 10-ppm carbon. 

A method whose upper limit is 10-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

 

EN 12619 (1999) - 

Stationary Source 

EmissionsDetermination of the 

Mass Concentration 

of Total Gaseous 

Organic Carbon at 

Low Concentrations 

in Flue GasesContinuous Flame 

Ionization Detector 

Method 

EPA Method 

25 and 25A 

This standard is an impractical alternative 

to EPA Method 25 and 25A because it 

does not measure solvent process vapors in 

concentrations greater than 40-ppm carbon. 

A method whose upper limit is 40-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 
135

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ASTM D6348-98 - 

Determination of 

Gaseous 

Compounds by 

Extractive Direct 

Interface Fourier 

Transform (FTIR) 

Spectroscopy 

EPA Method 

320 

This ASTM standard has been reviewed by 

the EPA and comments were sent to 

ASTM. The ASTM Subcommittee D22-03 

is now undertaking a revision of ASTM 

D6348-98. 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. 

202 

ASTM D3154-00 - 

Standard Method for 

Average Velocity in 

a Duct (Pitot Tube 

Method) 

EPA 

Methods 1, 

2, 2C, 3, 3B, 

4 

This standard appears to cover EPA’s Part 

60 Methods 1, 2, 2C, 3, 3B, 4, but lacks in 

quality control and quality assurance 

requirements. Specifically, ASTM D3154-

00 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. 

 

ISO 10780:1994, 

Stationary Source 

Emissions--

Measurement of 

Velocity and 

Volume Flowrate of 

Gas Streams in 

Ducts 

EPA Method 

2 

ISO 10780:1994 recommends the use of Lshaped pitots, which historically have not 

been recommended by EPA. EPA 

specifies the use of S-type design that has 

large openings that are less likely to plug 

up with dust. 

 

ASTM D3464-96 

(2001), Standard 

Test Method 

Average Velocity in 

a Duct Using a 

Thermal 

Anemometer 

EPA Method 

2 

There is no EPA method for comparison. 

Applicability specifications are not clearly 

defined (example: range of gas 

composition, T limits). It appears to have 

the correct calibration procedures and 

specifications, but without supporting data. 

Some of the variability issues were not 

adequately addressed. The EPA cannot 

call this equivalent to EPA Method 2 

without supporting data. 
136

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ASTM D5835-95, 

Standard Practice 

for Sampling 

Stationary Source 

Emissions for 

Automated 

Determination of 

Gas Concentration 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ASTM D5835-

95 does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). This standard is also very similar to 

ISO 10396. 

 

ISO 10396:1993, 

Stationary Source 

Emissions: 

Sampling for the 

Automated 

Determination of 

Gas Concentrations 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ISO 10396 

does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). This standard is also very similar to 

ASTM D5835. 
137

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

EN 12619:1999 

Stationary Source 

EmissionsDetermination of the 

Mass Concentration 

of Total Gaseous 

Organic Carbon at 

Low Concentrations 

in Flue Gases--

Continuous Flame 

Ionization Detector 

Method 

EPA Method 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 40-ppm carbon. 

A method whose upper limit is 40-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions, which are expected to be higher.

 

ISO 14965:2000(E) 

Air QualityDetermination of 

Total Nonmethane 

Organic 

CompoundsCryogenic 

Preconcentration 

and Direct Flame 

Ionization Method 

EPA Method 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 10-ppm carbon. 

A method whose upper limit is 10-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions, which are expected to be higher.

 

ASTM D3796-90 

(Reapproved 1998), 

Standard Practice 

for Calibration of 

Type S Pitot Tubes 

EPA Method 

2 

This is a very good detailed procedure for 

calibrating Type S pitot tubes, but it is not 

a complete method alternative to EPA 

Method 2. 

 

ASME C00031 or 

PTC 19-10-1981--

Part 10, Flue and 

Exhaust Gas 

Analyses 

EPA Method 

3 

Too broad to be useful in regulatory sense. 

Covers EPA Methods 3, 6, 7, and 15 with 

variants. 

 

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 

EPA Method 

3A 

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 the standard. 
138

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

Combustion Flue 

Gas Streams 

 

ASTM E337-84 

(Reapproved 1996), 

Standard Test 

Method for 

Measuring 

Humidity with a 

Psychrometer (the 

Measurement of 

Wet- and Dry-Bulb 

Temperatures) 

EPA Method 

4 

This will only cover a small portion of 

what is acceptable for EPA Method 4. 

265 

ASTM D3154-00 - 

Standard Method for 

Average Velocity in 

a Duct (Pitot Tube 

Method) 

EPA 

Methods 1, 

2, 2C, 3, 3B, 

4 

Lacks in quality control and quality 

assurance requirements. Specifically, 

ASTM D3154-00 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. 

 

ASTM D3464-96 

(2001) - Standard 

Test Method 

Average Velocity in 

a Duct Using a 

Thermal 

Anemometer 

EPA Method 

2 

The applicability specifications in this 

ASTM standard are not clearly defined, 

e.g., range of gas composition, temperature 

limits. In addition, 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. 
139

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 10396:1993 - 

Stationary Source 

Emissions: 

Sampling for the 

Automated 

Determination of 

Gas Concentrations 

EPA Method 

3A 

But lacks in detail and quality 

assurance/quality control requirements. 

Specifically, ISO 10396 does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). 

 

ASTM D5835-95 - 

Standard Practice 

for Sampling 

Stationary Source 

Emissions for 

Automated 

Determination of 

Gas Concentration 

EPA Method 

3A 

Lacks in detail and quality 

assurance/quality control requirements. 

Specifically, ASTM D5835-95 does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). 
140

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

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 

EPA Method 

3A 

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 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. 

 

ISO 12039:2001 - 

Stationary Source 

EmissionsDetermination of 

Carbon Monoxide, 

Carbon Dioxide, 

and Oxygen - 

Automated Methods 

EPA Method 

3A 

This ISO standard is unacceptable as 

substitute for EPA Method 3A because it 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. In 

addition, ISO 12039:2001 does not specify 

performance criteria for calibration error, 

calibration drift, or sampling system bias 

tests, as in the EPA method, although 

checks of these quality control features are 

required by the ISO standard. 

 

ASTM D4323-84 

(1997) - Standard 

Test Method for 

Hydrogen Sulfide in 

the Atmosphere by 

Rate of Change of 

Reflectance 

EPA Method 

15 

This standard is not acceptable as an 

alternative to EPA Method 15 since it only 

applies to concentrations of H2S from 1 

ppb to 3 ppm without dilution, which is 

likely to be lower than the levels at source 

conditions. In addition, many quality 

control items are missing in ASTM D4323, 

such as checks for calibration drift and 

sample line losses. The calibration curve is 

also determined with only one point, as 

opposed to a multi-point curve of EPA 

Method 15. 
141

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ASTM D6060-96 

(in review 2000) - 

Practice for 

Sampling of Process 

Vents with a 

Portable Gas 

Chromatography 

EPA Method 

18 

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. 

 

ASTM E1211-97 - 

Standard Practice 

for Leak Detection 

and Location Using 

Surface-Mounted 

Acoustic Emission 

Sensors 

EPA Method 

21 

This standard will detect leaks but not 

“classify” the leak as VOC, as in EPA 

Method 21. In addition, in order to detect 

the VOC concentration of a known VOC 

leak, the acoustic signal would need to be 

calibrated against a primary instrument. 

Background noise interference in some 

source situations could also make this 

standard difficult to use effectively. 

 

ISO 14965:2000(E) 

- Air Quality -

Determination of 

Total Nonmethane 

Organic Compounds 

- Cryogenic 

Preconcentration 

and Direct Flame 

Ionization Method 

EPA 

Methods 25, 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 10-ppm carbon. 

A method whose upper limit is 10-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

 

EN 12619 (1999) - 

Stationary Source 

EmissionsDetermination of the 

Mass Concentration 

of Total Gaseous 

Organic Carbon at 

Low Concentrations 

in Flue GasesContinuous Flame 

Ionization Detector 

Method 

EPA Method 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 40-ppm carbon. 

A method whose upper limit is 40-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 
142

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 10780:1994 - 

Stationary Source 

Emissions - 

Measurement of 

Velocity and 

Volume Flowrate of 

Gas Streams in 

Ducts 

EPA Method 

2 

ISO 10780:1994 recommends the use of an 

L-shaped pitot, which historically has not 

been recommended by EPA. The EPA 

specifies the S-type design that has large 

openings that are less likely to plug up with 

dust. 

273 

ASTM D3154-00, 

Standard Method for 

Average Velocity in 

a Duct (Pitot Tube 

Method) 

EPA 

Methods 1, 

2, 2C, 3, 3B, 

4 

This standard appears to cover EPA’s Part 

60 Methods 1, 2, 2C, 3, 3B, 4, but lacks in 

quality control and quality assurance 

requirements. Specifically, ASTM D3154-

00 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. 

 

ASTM D3464-96 

(2001), Standard 

Test Method 

Average Velocity in 

a Duct Using a 

Thermal 

Anemometer 

EPA Method 

2 

The applicability specifications in this 

ASTM standard are not clearly defined, 

e.g., range of gas composition, temperature 

limits. In addition, 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 

EmissionsMeasurement of 

Velocity and 

Volume Flowrate of 

Gas Streams in 

Ducts 

EPA Method 

2 

ISO 10780:1994 recommends the use of an 

L-shaped pitot, which historically has not 

been recommended by EPA. The EPA 

specifies the S-type design that has large 

openings that are less likely to plug up with 

dust. 
143

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

EN 12619:1999 

Stationary Source 

EmissionsDetermination of the 

Mass Concentration 

of Total Gaseous 

Organic Carbon at 

Low Concentrations 

in Flue Gases 

Continuous Flame 

Ionization Detector 

Method 

EPA Method 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 40-ppm carbon. 

A method whose upper limit is 40-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

 

ISO 14965: 2000(E) 

Air QualityDetermination of 

Total Nonmethane 

Organic 

CompoundsCryogenic 

Preconcentration 

and Direct Flame 

Ionization Method 

EPA 

Methods 25, 

25A 

This standard is an impractical alternative 

to EPA Method 25A because it does not 

measure solvent process vapors in 

concentrations greater than 10-ppm carbon. 

A method whose upper limit is 10-ppm 

carbon has a measurement range too 

limited to be useful in measuring source 

emissions. 

 

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 

EPA Method 

3A 

This standard is unacceptable as a 

substitute for EPA Methods 3A, 6C, 7E, 

10, 10A since 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 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. 
144

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ASTM D5835-95, 

Standard Practice 

for Sampling 

Stationary Source 

Emissions for 

Automated 

Determination of 

Gas Concentration 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ASTM D5835-

95 does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only) 

 

ISO 10396:1993, 

Stationary Source 

Emissions: 

Sampling for the 

Automated 

Determination of 

Gas Concentrations 

EPA Method 

3A 

Similar to EPA Methods 3A, 6C, 7E, 10, 

ALT 004, CTM 022, but lacks in detail and 

quality assurance/quality control 

requirements. Specifically, ISO 10396 

does 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; (7) 

specifications for data recorders, in terms 

of resolution (all types) and recording 

intervals (digital and analog recorders, 

only). 
145

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 12039:2001, 

Stationary Source 

Emissions 

Determination of 

Carbon Monoxide, 

Carbon Dioxide, 

and Oxygen 

Automated Methods 

EPA Method 

3A 

This ISO standard is unacceptable as 

substitute for EPA Method 3A because it 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. In 

addition, ISO 12039:2001 does not specify 

performance criteria for calibration error, 

calibration drift, or sampling system bias 

tests, as in the EPA method, although 

checks of these quality control features are 

required by the ISO standard. 

376 

ASTM D3154 -91 

(1995) -Standard 

Method for Average 

Velocity in a Duct 

(Pitot Tube Method) 

EPA Method 

1, 2, 2c 3, 

3b, 4 

Appears to cover EPA’s Part 60 Methods 

1, 2, 2c, 3, 3b, 4, but lacks in quality 

control and quality assurance requirements. 

 

ISO 9096:1992 -

Determination of 

Concentration and 

Mass Flow Rate of 

Particulate Matter in 

Gas Carrying Ducts 

- Manual 

Gravimetric 

Method. 

EPA Method 

1, 2, 5 

Some portions of this method relate to EPA 

Methods 1 & 2. This method will not 

produce particulate matter measurements 

like EPA Method 5 (example: there is no 

temperature control on the filter that is 

exposed to ambient levels). There is no 

EPA Method to compare this to. EPA 

cannot approve this method without 

supporting data. 

 

ISO 10155:1995 - 

Stationary Source 

Emissions 

Automated 

Monitoring of Mass 

Concentration of 

Particles – 

Performance 

Characteristics, Test 

Methods, and 

Specifications. 

EPA 

Performance 

Specification 

11 

This international standard is only 

applicable on a site-specific basis by direct 

correlation with the manual method ISO 

9096 (which does not produce particulate 

matter measurements like EPA Method 5). 

This appears to be a particulate matter 

(PM) CEMS performance specification 

similar to EPA Performance Specification 

(PS) 11, but does not contain detailed 

RATA procedures. In addition, EPA does 

not have a final performance specification 
146

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

to compare this to. 

 

ASTM D3464-96 - 

Standard Test 

Method Average 

Velocity in a Duct 

Using a Thermal 

Anemometer 

EPA Method 

2 

There is no EPA Method to compare this 

to. Applicability specifications are not 

clearly defined (example: range of gas 

composition, T limits). It appears to have 

the correct calibration procedures and 

specifications, but without supporting data. 

Some of the variability issues were not 

adequately addressed. EPA cannot call this 

equivalent to EPA Method 2 without 

supporting data. 

 

ASTM D3796 - 98 - 

Standard Practice 

for Calibration of 

Type S Pitot Tubes 

EPA Method 

2 

This is a very good detailed procedure for 

calibrating Type S pitot tubes, but it is not 

a complete method alternative to EPA 

Method 2. 

 

ISO 10780:1994 – 

Stationary Source 

Emissions – 

Measurement of 

Velocity and 

Volume Flowrate of 

Gas Streams in 

Ducts 

EPA Method 

2 

This standard recommends the use of Lshaped pitots, although it contains 

procedures for the use of S-shaped pitots, 

as in EPA Method 2. ISO 10780 has good 

detail, but has significant deficiencies, e.g., 

1) the distance between each leg of the 

pitot to its face-opening plane can be up to 

10 times the external tubing diameter vs. 

1.5 times as specified in EPA Method 2; 

and 2) no direct calibration procedures are 

provided for an S-shaped pitot. 

 

ASME C00031 or 

PTC 19-10-1981 - 

Part 10 Flue and 

Exhaust Gas 

Analyses 

EPA Method 

3, 6, 7, 15 

Too broad to be useful in regulatory sense. 

Covers Methods 3, 6, 7, and 15 with 

variants. 
147

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 10396:1993 - 

Stationary Source 

Emissions: 

Sampling for the 

Automated 

Determination of 

Gas Concentrations 

EPA Method 

3a, 6c, 7e, 

10, ALT 

004, CTM 

022 

Duplicates Method 3a, 6c, 7e, 10, ALT 

004, CTM 022. Lacks in detail and quality 

assurance and quality control requirements. 

Similar to ASTM D5835. 

 

ASTM D5835-95 - 

Standard Practice 

for Sampling 

Stationary Source 

Emissions for 

Automated 

Determination of 

Gas Concentration. 

EPA Method 

3a, 6c, 7e, 

10, ALT 

004, CTM 

022 

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

004, CTM 022. Lacks in detail and quality 

assurance and quality control requirements. 

Very similar to ISO 10396. 

 

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 

EPA Method 

3a, 6c, 7e, 

10, 10a 

Too general. This standard lacks in detail 

and quality assurance/quality control 

requirements. Appendices with valid 

quality control information are not a 

required part of this method. 

 

ASTM E337- 84 

(Reapproved 1996) - 

Standard Test 

Method for 

Measuring 

Humidity with a 

Psychrometer (the 

Measurement of 

Wet- and Dry-Bulb 

Temperatures) 

EPA Method 

4 

This will only cover a small portion of 

what is acceptable for EPA Method 4. 
148

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 7934:1998 - 

Stationary Source 

Emissions - 

Determination of the 

Mass Concentration 

of Sulfur Dioxide - 

Hydrogen 

Peroxide/Barium 

Perchlorate/ Thorin 

Method 

EPA Method 

6 

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. 

 

ISO 11632:1998 - 

Stationary Source 

Emissions - 

Determination of the 

Mass Concentration 

of Sulfur Dioxide - 

Ion 

Chromatography 

EPA Method 

6 

No comparable EPA method that includes 

ion chromatography. Sampling procedure 

similar to EPA Method 6, but lacks in 

detail and QC procedures, such as 

calibration checks and leaks tests. 

 

CAN/CSA Z223.21-

M1978 Method for 

the Measurement of 

Carbon Monoxide: 3 

- Method of 

Analysis by NonDispersive Infrared 

Spectrometry 

EPA Method 

10, 10a 

In general, this standard lacks in detail and 

quality assurance/quality control 

requirements. In specific, this 

 

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 

EPA Method 

12, 29, 306, 

306a 

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 
149

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979) 

 

ASTM E1741-95 

Standard practice 

for Preparation of 

Airborne Particulate 

Lead Samples 

Collected During 

Abatement and 

Construction 

Activities for 

Subsequent 

Analysis by Atomic 

Spectrometry 

EPA Method 

12, 29 

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 E1741-95 

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 D4358 

and ASTM E1979.) 

 

ASTM E1979-98 - 

Standard Practice 

for Ultrasonic 

Extraction of Paint, 

Dust, Soil, and Air 

Samples for 

Subsequent 

Determination of 

Lead 

EPA Method 

12, 29 

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 E1979-98 

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 
150

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

media, and this further negates their use as 

Method 29 equivalent methods. (Same 

comment as provided for ASTM D4358 

and ASTM E1741.) 

 

ASTM D4323-84 

(1997) - Standard 

Test Method for 

Hydrogen Sulfide in 

the Atmosphere by 

Rate of Change of 

Reflectance 

EPA Method 

15 

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. 

 

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 

EPA Method 

25a 

This standard is limited because it does not 

apply to solvent-using processes vapors or 

concentrations >40 ppm carbon. 

Specifications for probe temperature are 

only 20o

C above flue gas as compared to 

EPA Method 25a which specifies greater 

than or equal to 110o

C. 

 

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 - 

EPA Method 

26, 26a 

Part 3 of this method cannot be considered 

equivalent to Method 26 or 26A. The 

sample absorbing solution (water) would 

be expected to capture both HCl and 

chlorine gas, if present, without the ability 

to distinguish between the two. Methods 

26 and 26A use an acidified absorbing 

solution to first separate HCl and chlorine 

gas so that they can be selectively 

absorbed, analyzed, and reported 

separately. In addition, the efficiency of 

absorbing the chlorine gas fraction would 

be expected to vary as the pH of the 
151

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

Part 3: Adsorption 

Solutions Analysis 

and Calculation 

Ratified European 

Text 

absorbing solution changed. 

 

CAN/CSA Z223.26-

M87 - Measurement 

of Total Mercury in 

Air Cold Vapour 

Atomic Absorption 

Spectrophotometeric 

Method 

EPA Method 

29, 101, 

101a 

Method is only applicable to background 

and near ambient levels of mercury (5 - 

5,000 ng/m3) and for low volume air 

sampling. QA is limited and/or not well 

documented. 

 

ASTM D6216 - 98 - 

Standard Practice 

for Opacity Monitor 

Manufacturers to 

Certify 

Conformance with 

Design and 

Performance 

Specifications. 

EPA 

Performance 

Specification 

1 

The EPA is incorporating ASTM D6216 

(manufacturers certification) by reference 

into EPA Performance Specification 1, 

Sect. 5 & 6 in another rulemaking. ASTM 

D6216 does not address all the 

requirements specified in PS-1. 

 

ISO 7935:1992 - 

Stationary Source 

Emissions - 

Determination of the 

Mass Concentration 

of Sulfur Dioxide - 

Performance 

Characteristics of 

Automated 

Measuring Methods 

EPA 

Performance 

Specification 

2 (for the 

sulfur 

dioxide 

portion only)

This standard lacks in detail and quality 

assurance/quality control requirements. 

Method is missing calibration drift 

requirements and specifications for 

placement of CEMS. Limited 

concentration range of applicability. 
152

Rule # Voluntary Standards 

Rejected 

Government 

Standards 

Used 

Explanation 

 

ISO 10849:1996 - 

Determination of the 

Mass Concentration 

of Nitrogen Oxides - 

Performance 

Characteristics of 

Automated 

Measuring Systems 

EPA 

Performance 

Specification 

2 (for the 

nitrogen 

oxide 

portion only)

This standard lacks in detail and quality 

assurance/quality control requirements. 

Method is missing calibration drift 

requirements and specifications for 

placement of CEMS. Limited 

concentration range of applicability. 

 

ASTM C1111- 98 

(1998) - Standard 

Test Method for 

Determining 

Elements in Waste 

Streams by 

Inductively Coupled 

Plasma-Atomic 

Emission 

Spectrometers 

SW846-

6010b 

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 

SW846-

6010b 

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. 

520 

ISO 14520, Gaseous 

Media & Fixed Fire 

Extinguishing 

None N/A 

2. Voluntary consensus standards substituted for government unique standards. 

 2 

 EPA used ASTM D6420-99 standard as a substitute for EPA Method 18 in two separate 

rules, for two separate applications. 
153

3. Number of voluntary consensus standards used in this reporting period. 

 9 

During this period, nine different voluntary consensus standards were used in 15 separate 

decisions. In decisions where the same standard appears in more than one application, but for 

essentially the same purpose, the use of the standard was counted only once. 

4. Number of employees participating in voluntary consensus organizations. 

 42 

 During this period there were 42 EPA employees actively participating in voluntary 

standards activities. Some of these, plus three others from the Agency, also participated 

in standards activities in the “C” category below in response to question five. 

5. EPA employees participate in the following standardization organizations: 

 A. U.S. National Standardization and Conformity Assessment Organizations: 

ACRONYM BODY

 ANSI American National Standards Institute 

 RAB Registrar Accreditation Board 

 B. Standards Development Organizations: 

ACRONYM BODY

 ACS American Chemical Society 

 AOAC Association of Analytical Communities International 

 ASTM ASTM International 

 ASME American Society of Mechanical Engineers 

 ASQ American Society for Quality 

 AWWA American Water Works Association 

 ISO International Organization of Standardization 

 IEC International Electrotechnical Committee 

 NFPA National Fire Protection Association 

 NSF International National Fire Protection Association International 

 (No acronym) Standard Methods 

 WEF Water Environment Federation 

 W3C World Wide Web Consortium 

C. Other private sector and government organizations with activities in standards and 

conformity assessment: 

 
154

ACRONYM BODY

 NELAC National Environmental Laboratory Accreditation Council 

 MARLAP Multi-Agency Radiological Laboratory Analytical 

 Protocols 

 FGDC Federal Geographic Data Committee 

 EDSC Environmental Data Standards Council 

 APBF American Petroleum Business Federation 

 APHA American Pharmoecopia Association Eco-RBCA 

 Open-GIS Open GIS Consortium. 

6. Description of how EPA reports use of standards: 

a. EPA reports each time a separate regulatory decision involves use of a technical 

standard and thereby triggers consideration of using an existing voluntary 

standard. 

b. The use of standards varies according to the purpose of a given regulation. It may 

be that a regulation in one part of the Agency would use an edition of a standard 

that is separate from the use of the same standard, different edition, in another part 

of the Agency. In the event that such a situation would occur, the two would be 

counted as two separate uses of the same standard. It is not known that this 

situation has occurred, but there is no policy to prevent it from occurring. 

c. EPA has not ‘counted’ standards used for guidance purposes, but would consider 

doing so in cases where the guidance is deemed a regulatory activity. The 

Agency has typically included such uses in the annual reports under the “other 

activities” section. EPA would welcome discussion of this question within the 

Interagency Committee for Standards Policy. 

d. The majority of voluntary standards used by EPA are from ANSI-accredited 

organizations, and EPA, as a member of ANSI, values the accreditation role of 

ANSI, the U.S. national standards body. However, since the focus of the Agency 

is on the use of standards developed outside the government-unique processes, 

EPA does not prohibit the use of standards developed in consortia, and EPA 

would count such standards in the “number of standards used” category for annual 

reporting purposes. 

7. (See comment below.) 

8. Not applicable. 

9. EPA has a number of good case studies from various offices throughout the Agency. 

These and examples from other years will be posted on the new EPA voluntary standards 

Web site soon to be available. 

 
155

10. Comments. 

EPA appreciates the accomplishments and efforts of NIST in coordinating federal 

obligations under the NTTAA and OMB Circular. NIST performs a particularly helpful 

role as chair of the Interagency Committee on Standards Policy (ICSP), and in providing 

written and oral guidance on the preparation of the annual reports to OMB and Congress. 

With a view toward making the annual report on federal adherence to the NTTAA 

possibly more useful to the federal agencies themselves, to standards development 

organizations with which agencies work, and to the public, EPA offers the following 

brief comment for consideration by all stakeholders as appropriate. 

It is almost overwhelmingly compelling, and understandably so, to want to compile 

standards-related data from across the federal agencies and enumerate the data in tables. 

As strong as that urge is, tables may not reflect an accurate or useable ‘picture’ for all 

types of data. In that case, it is helpful to understand why -- what data may be suitable 

for tabulation and what information should be presented in another format. 

If there is any thought to either revising the Circular or providing additional guidance on 

reporting, it may be beneficial to take a fresh look at the intent of the law and how it 

impacts not only federal agencies but other stakeholders as well, specifically: standards 

development organizations (SDOs) and the public. Given the language of the NTTAA 

itself, what kind of information would be useful and useable for these groups? For 

example: what information is most helpful to standards organizations? SDOs could be 

surveyed, possibly using ANSI as a mechanism for that. It is conceivable that SDOs may 

find numbers-only information not very useful and would prefer another format to 

determine if there are common or reoccurring reasons why VCSs are not used, so that 

committees have better knowledge of agencies needs. 

On the other hand, it may be most helpful for SDOs to continue to have tabulated 

numbers of agency participants as an indicator of how well the SDOs are doing 

themselves in reaching out to potential federal actors. 

EPA is not suggesting a specific answer, and is posing this consideration with the sense 

that a revision of the Circular itself may not be needed to accomplish a fresh look at the 

matter. 

In any event and in keeping with the mission of EPA, the Agency remains committed to 

working cooperatively with NIST and the other ICSP members in implementation of the 

NTTAA and OMB Circular. 
156

Federal Communications Commission 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

2. Number of voluntary consensus standards substituted for government-unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 0 

4. Number of agency employees participating in voluntary consensus standards activities. 

 5 

5. List of voluntary consensus standards bodies in which there is agency participation. 

 7 

6. How does your agency report the use of standards? 

a. Does your federal agency report only the first-time use of standards, continued 

uses of standards or both first time and continued use? 

 Both first time and continued use of standards. 

b. When reporting standards use, some agencies report uses of standards. That is, 

they count the total number of instances where the agency has referenced a 

standard. For example, three separate references to a single standard are counted 

as three standards uses. On the other hand, other agencies report standards used. 

These agencies report the number of standards that the agency references. In this 

case, each standard is counted only once regardless of how many times it is 

referenced by the agency. Using these definitions, how does your agency report? 

 No comment. 

c. Does your federal agency report multiple editions of a single standard as one 

standard or as multiple standards used? 

 Multiple. 
157

d. Does your federal agency report standards that it uses for guidance purposes (as 

opposed to compliance purposes)? 

 Yes. 

e. Does your federal agency report use of standards from non-ANSI-accredited 

standards developers including industry consortia? 

 Yes. 

7. Provide an evaluation of the effectiveness of Circular A-119 policy and recommendations 

for any changes. 

 The policies of Circular A-119 are clearly stated for application to the activities of the 

FCC, and the Commission recognizes the benefit of using voluntary consensus standards 

when applicable. 

8. Provide the conformity assessment activities in which the agency has been involved. 

 None. 

9. Provide any examples or case studies of standards successes. 

 No comment. 

10. Comments. 

 The Web-based procedure for reporting works well. 
158

Federal Emergency Management Agency 

 No report. 
159

Federal Trade Commission 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

2. Number of voluntary consensus standards substituted for government-unique standards. 

 0 

3. Number of voluntary consensus standards used in FY 2002. 

 0 

4. Number of agency employees participating in voluntary consensus standards activities. 

 0 

5. List of voluntary consensus standards bodies in which there is agency participation. 

 Not applicable. 

6. How does your agency report the use of standards? 

a. Does your federal agency report only the first-time use of standards, continued 

uses of standards or both first time and continued use? 

 Not applicable. 

b. When reporting standards use, some agencies report uses of standards. That is, 

they count the total number of instances where the agency has referenced a 

standard. For example, three separate references to a single standard are counted 

as three standards uses. On the other hand, other agencies report standards used. 

These agencies report the number of standards that the agency references. In this 

case, each standard is counted only once regardless of how many times it is 

referenced by the agency. Using these definitions, how does your agency report? 

 Not applicable. 

c. Does your federal agency report multiple editions of a single standard as one 

standard or as multiple standards used? 

 Not applicable. 
160

d. Does your federal agency report standards that it uses for guidance purposes (as 

opposed to compliance purposes)? 

 Not applicable. 

e. Does your federal agency report use of standards from non-ANSI-accredited 

standards developers including industry consortia? 

 Not applicable. 

7. Provide an evaluation of the effectiveness of Circular A-119 Policy and 

recommendations for any changes. 

 See response to question 10. 

8. Provide the conformity assessment activities in which the agency has been involved. 

 See response to question 10. 

9. Provide any examples or case studies of standards successes. 

 See response to question 10. 

10. Comments. 

The Federal Trade Commission is an independent agency of the United States 

Government charged with enforcing competition and consumer protection laws. The 

Commission’s only contact with voluntary consensus standards and the organizations that 

produce them is in connection with the enforcement of the Federal Trade Commission 

Act, which prohibits unfair methods of competition and unfair or deceptive acts or 

practices affecting commerce. The Commission does not promulgate its own standards 

or engage in other standards activities pertinent to OMB Circular A-119. 
161

General Services Administration 

1. As required by P.L. 104-113, you must highlight all instances where the agency used 

government-unique standards in lieu of voluntary consensus standards during FY 2002. 

For each instance, you must identify the specific government-unique standard used and 

the voluntary consensus standard that was not selected. Equally as important, you must 

clearly state your agency’s rationale for such use. 

 2 

 A. Government Standard A-A1925 

 Voluntary Standard ASTM E488 

Rationale This government-unique standard (A-A-1925) is 

prepared maintained by the Defense Logistics 

Agency (DLA). Both the DLA and the General 

Services Administration (GSA) procure products 

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

product continuity across the federal marketplace, 

we must cite the same standard (A-A-1925) as 

DLA. 

 B. Government Standard KKK-1822E 

 Voluntary Standard ASTM F-2020-1 

Rationale The GSA’s use of the ASTM standard is under 

review. The GSA has requested the Ambulance 

Manufacturers Division (AMD) to perform a 

technical review of the ASTM standard. The final 

AMD report should be completed by the third 

quarter of 2003. 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 19 

 Government standard Voluntary standard

 A-A-3053 ASTM D4317 

 A-A-2336 MPI 5 or 7 

 A-A-2962 MPI 51, 47, 48 or 49 
162

 A-A-3067 MPI 8, 9, or 94 

 A-A-2246 MPI 138, 141, 114 or 139 

 A-A-3108 MPI 28 

 FED-STD-751 ASTM D6193 

 PPP-B-636 ASTM D1974 

 PPP-B-636 ASTM D5118 

 MIL-25135 SAE/AMS 2644 

 A-A-870 ASTM D3306 

 A-A-870 ASTM D4340 

 A-A-870 ASTM D4985 

 A-A-895 ASTM D456 

 O-S-571 ASTM D458 

 O-S-576 ASTM D928 

 O-T-236 ASTM D4081 

 O-C-114 ASTM E1229 

 A-A-1106 UL 154 

3. The number of voluntary consensus standards that your agency used during FY 2002, 

based upon procedures set forth in sections 11 and 12 of the Circular. 

 81 

 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 44 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

 23 

American Society for Testing and Materials (ASTM) 

American National Standards Institute (ANSI) 

Business and Institutional Furniture Manufacturers Association (BIFMA) 

Underwriters Laboratories (UL) 

Hardwood Plywood and Veneer Association (HPVA) 

Aerospace Industries Association (AIA) 

American Society of Mechanical Engineers (ASME) 

National Institute for Building Sciences (NIBS) 

Performance Review Institute (PRI) 

National Aerospace and Defense Contractors Accreditation Program (NADCAP) 

Society of Automotive Engineers (SAE) 

Society for Protective Coatings (SSPC) 

International Standards Organization (ISO) SC29/TC10 Hand Tools Committee 
163

American Gas Association (AGA) 

Automotive Lift Institute (ALI) 

Builders Hardware Manufacturers Association (BHMA) 

National Fire Protection Association (NFPA) 

The Maintenance Council of American Trucking Associations (TMC/ATA) 

Ambulance Manufacturers Division, National Truck Equipment Associations 

 (AMD/NTEA) 

National Fire Protection Association [1901] (NFTA) 

National Fire Protection Association – National Electrical Code (NFTA-NEC) 

American Society for Mechanical Engineers (ASME) Safety Standards for Portable 

 Lifting Devices (PALD) 

American Society of Refrigerating and Air-Conditioning Engineers (ASHRAE) 

National Building Codes 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. Specifically, you should answer the following questions. (Note: Questions 

will be structured on the web entry database to accept either “Yes/No” or multiple-choice 

responses.) 

 The GSA reports: 

 a. both first-time and continued use of standards, 

 b. the total number of standards used, 

 c. multiple editions of a single standard as one standard used, 

 d. no response, and 

e. the use of standards from non-ANSI-accredited standards developers including 

industry consortia. 

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

 None. 

8. Any conformity assessment activities in which your agency has been involved in the 

reporting period as described in the Federal Register, Vol. 65, No. 155, Thursday, 

August 10, 2000, Guidance on Federal Conformity Assessment Activities. 

 Yes. They are as follows: 
164

 ISO SC 10 TC 29

 The U.S. Technical Advisory Group (TAG) is responsible for determining the U.S. 

position on IEC/ISO standards pertaining to technical committee or subcommittees in 

addition to the review of policy matters. The standards include hand tools and 

accessories for safety requirements relating to the elements of design, use, and selection 

of performance, tolerances, and outline configurations including, but not limited to, 

wrenches, pliers, screwdrivers, shears, punches, chisels, hammers, and toolboxes. The 

standards will include the development of requirements, the consideration of various 

types and classes of hand tools and accessories required for specified classes of service, 

and the tests needed to determine conformance with the service classification 

requirements. 

 ASME, American Society of Mechanical Engineers, B107 Main Committee

 GSA Hardware SuperStore is a member of the ASME B107 main committee relating to 

hand tools and actively participates in the development of non-government procurement 

and safety standards. This committee is actively is actively involved in maintaining and 

improving standards to assure customer requirement are maintained. 

 Tool Fastener Working Group

To discuss the standardization and end use relationship between fasteners and hand tools. 

By active participation from: the GSA, the Federal Supply Service (FSS) Hardware 

SuperStore, the Defense Industrial Center, Philadelphia, non-government standards 

activities (AIA, SAE, and ASME), fasteners and tool manufactures, designers, and end 

users. Fastener and hand tools are an integrated system where the goal of this group is to 

improve the performance of fastener systems by evaluating at the tool-fastener interface, 

in addition to creating a review committee to evaluate and improve non-government 

standards. 

 Green Seal

Green Seal is an independent, non-profit “third party certification” organization devoted 

to the creation of scientific evaluation criteria for environmentally preferred products. 

These criteria are then used to provide credible objective, and unbiased product review. 

6FEE continues to provide suppliers with the option of certifying their products with 

Green Seal. Also, a list of relevant Green Seal standards and Green Seal recommended 

products is maintained the GSA Hardware SuperStore Web page under “Environmental 

Issues.” 

http://www.greenseal.org/ 

http://r6.gsa.gov/fss/hac/ 
165

National Institute of Building Sciences (NIBS)

Master Painters Institute (MPI)

Scientific Certification Systems (SCS)

6FEE continues to provide suppliers with the option of certifying their products under the 

SCS Specification for Architectural and Anti-Corrosive Paint. This was a joint effort by 

the National Institute of Building Sciences (NIBS), the Master Painters Institute (MPI), 

ICI paint, the Department of Defense, the General Services Administration, the Chemical 

Manufacturers’ Association, and the Scientific Certification Systems. This criteria is 

based on International Organization for Standardization (ISO) Standard 14042, as 

prepared by Technical Committee ISO/TC 207, Environmental Management, 

Subcommittee SC 5, Life Cycle Assessment and has been adopted as a standard by MPI. 

In addition, a copy of this standard and a list of SCS Certified products are maintained on 

the GSA Hardware SuperStore Web page under “Environmental Issues.” 

 http://www.scs1.com. 

 http://www.hvacmall.com/listing/nibs.htm 

Clean Air Act National Emission Standards for Hazardous Air Pollutants (CAA 

NESHAP) Compliance – for Shipbuilding and Aerospace Coatings 

The Clean Air Act (40th Code of Federal Regulations, Subparts 63.741, 63.753 and 

63.780) designates “Shipbuilding and Ship Repair Facilities” and “Aerospace 

Manufacturing and Rework Facilities” as regulated emissions source categories. Clean 

Air Act rules limit the volatile organic hazardous air pollutant (VOHAP) content of 

several types of solvents, coatings, strippers, and maskants used within these industrial 

categories. Compliance is based on proper documentation that volatile organic 

compound (VOC) or VOHAP emissions were within allowable limits. For select items 

regulated by the NESHAP, the GSA Hardware SuperStore continued to collect brief 

technical data certificates that provide much of the data that U.S. EPA requires the 

coating end user to maintain at their location. These certificates were then faxed to the 

Department of Defense liaison office. Also, GSA provided input to how to structure a 

new Web site that is to offer these documents electronically in the future.

 http://www.r6.gsa.gov/fss/HAC/ 

 [Environmental Issues] 

 Hazardous Material Information Resource System (HMIS) Functional Working Group

The HMIS Functional Working Group (FWG) is chartered under the sponsorship of the 

HMIS Policy Working Group (PWG). Its role is to represent the users of hazardous 

materials information and management systems, which deal with Material Safety Data 
166

Sheets (MSDS) or related/associated technical information, and strive to ensure that the 

functional needs of those users are met. In addition, the FWG prepares recommendations 

to the PWG on issues pertaining to the functional aspects of improvements to existing or 

future DOD hazardous materials information and management systems. The core FWG 

membership consists of voting representatives from the Army, Air Force, Navy, DLA, 

and GSA. 

 http://www.dscr.dla.mil/hmirs/ 

Joint Group on Environmental Attribute (JGEnvAtt) meeting – GSA/ Department of 

Defense/ Other Federal Agency, HQ DLA, Fort Belvoir, Virginia

Summarized to attendees the latest Hardware SuperStore’s efforts in delineating those 

FSC 8010 products that meet the definition of “Low-VOC.” Interfaced with key DoD 

and EPA personnel in learning of the latest efforts to delineate products with 

environmental attributes. Gathered and brought back references on the latest, four 

approved environmental attributes, of which “Low-Volatile Organic Compound” (LowVOC) is one, February 21, 2002. 

 http://www.buygreen.dlis.dla.mil/aboutjgenvatt/group.html 

 National Defense Industrial Association/ Department of Defense 

Attended the 28th Annual Environmental Symposium and Exhibition – Department of 

Defense, Charleston, South Carolina, March 25-28, 2002: Detailed data was gathered on 

potential suppliers, and DOD/ Navy/ Marine Corps/ U.S. EPA environmental initiatives 

that affect our commodities. We learned of new environmental initiatives within the 

Department of Defense and were able to visit 110 governmental and private booth 

exhibits, and interface with an estimated 150 Department of Defense customers. 

Attended the 7th Annual Joint Service Pollution Prevention Symposium and Exhibition – 

Department of Defense, August 19-22, 2002. Created and presented a 20-minute 

presentation on how to identify and purchase “Low-Volatile Organic Compound (LowVOC)” coatings from GSA, attended by 40 people. Networked with well over 100 

customers, and visited well over 200 private companies and government agency exhibits. 

Attended 10 hours of technical sessions. 

 

 http://environment.ndia.org/ 

National Aerospace Defense Contractors Accreditation Program (NADCAP) 

NADCAP represents major prime contractors, suppliers, and government agencies in 

aerospace, defense, and related industries throughout the United States and 

internationally. NADCAP is administered by the Performance Review Institute (PRI), 
167

and independent for profit trade association affiliated with the Society of Automotive 

Engineers (SAE). Through NADCAP, PRI accredits subcontractors and suppliers to 

aerospace and industry consensus standards. Through NADCAP, PRI assures and 

enhances quality, saves valuable time and efforts and cuts direct and overhead costs by 

performing the following functions: 

● Compiling audit criteria 

● Securing acceptance of these lists as internationally recognized ASE Aerospace 

Standards 

● Auditing suppliers’ technical capabilities and conformance to applicable 

procedures and/or government agencies 

● Focusing the responsibility for quality maintenance on the supplier and 

subcontractors 

● Publishing a qualified manufacturer’s list and making it available to primes 

● Promoting the benefits of using accredited suppliers 

GSA Hardware SuperStore is a prime member of the Sealants and Coating Groups and is 

a member of Qualified Product Management Council (QPMC). 

 Society of Automotive Engineers (SAE) 

GSA Hardware SuperStore is a member of the SAE, G8 - Aerospace Coatings Committee 

and G9 Aerospace Sealants Committee and actively participates in the development of 

Aerospace Material Standards. These committees are actively involved in the 

conversions of military specifications and the development of Aerospace Material 

Standards. 

A GSA Hardware SuperStore representative serves as Chairman of the G8 Laboratory 

Accreditation Sub-Committee for development of a laboratory accreditation protocol, 

consistent with ISO and IEC accreditation standards. This standard, AS5505, May 2001, 

provides interpretation of ISO/IEC 17025 and establishes additional requirements for 

accreditation of testing laboratories for evaluating organic coatings. This step was 

necessary for the development of the Qualified Manufacturers List (QML) program for 

G8 Aerospace Coatings. 

 USDA, Forestry Service

GSA/FSS Hardware SuperStore, representative to the USDA, Forestry Service, Tree 

Marking Paint Standard Development Committee. GSA provided expert consultation for 

environmental, health, and technical issues leading to development of the FS 2400-400 

specification. 
168

Building Products Pre-Approval Program (BPPAP)

GSA/FSS Hardware SuperStore, representative to the Building Products Pre-Approval 

Program (BPPAP) Committee, National Institute for Building Sciences, Washington, 

D.C. This committee coordinates the development of non-governmental architectural and 

industrial paint and coatings Standards with the Master Painters Institute. Through this 

committee, more than 26 Federal Specifications and Commercial Item Descriptions have 

been replaced with Master Painters Institute Standards. 

The BPPAP committee, through Scientific Certifications Systems, a third party 

internationally recognized certification organization, is pursuing development of 

Environmentally Preferred Purchasing, EPP, and certification for products mandated by 

Executive Order 13101. The BPPAP reviews and approves the protocol for EPP 

certification that SCS performs. 

 

USDA Forest Service

Joint meeting (April 2002) with representatives from the USDA Forest Service Missoula 

and San Dimas Technology & Development Centers. Discussed new requirements for 

wildland fire suppression equipment and abolishing the practice of allowing third-party 

certification to NFPA standards for protective clothing and equipment. As a result, future 

GSA contractors for wildland fire fighter clothing and personal protective equipment will 

be required to be ISO registered. The requirement will be phased in over a period of 

approximately three years. 

National Fire Protection Association (NFPA) Technical Committee on Wildland Fire 

Fighting Protective Clothing and Equipment

Committee meetings in Seattle, Washington (May 2002), and Missoula, Montana 

(August 2002). As part of the revision process of NFPA Standard 1977 (Protective 

Clothing & Equipment for Wildland Fire Fighting), the government-unique requirements 

for the fire shelter will be dropped from the standard. A performance-based standard will 

be developed for inclusion in the following revision of NFPA 1977. A new government 

(Forest Service) specification for a new, improved design of the fire shelter is just now 

being implemented and it was determined that adequate performance data could not be 

developed in time for the upcoming revision of NFPA 1977. 

9. Examples or case studies of your agency’s standards successes, if you so choose. 

 None. 

10. No response 
169

International Trade Commission

 The USITC has nothing to report. We are not engaged in any regulatory activity. 
170

National Aeronautics and Space Administration 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

 0 

 NASA uses the categorical method for reporting the use of standards. 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 2 

Voluntary Standard Government Standard

ANSI/ESD S-20.20-1999 NASA-STD-8739.7 

 ANSI/AIAA S-080-1998 NSS/HP-1740.1 & HP-1740.4 

3. The number of voluntary consensus standards that your agency used during FY 2002 

based upon procedures set forth in sections 11 and 12 of the Circular. 

 86 

 NASA reports the use of standards in the categorical manner. 

4. The number of agency employees participating in voluntary consensus standards 

 activities during this period. 

 131 

5. A list by name and acronym of the voluntary consensus standards bodies in which your 

agency participated during the reporting period. 

36 

 ABMA American Bearing Manufacturers Association 

 AIA Aerospace Industries Association of America 

 AIAA American Institute of Aeronautics and Astronautics 

 AIIM Association for Information and Image Management 

 ANSI American National Standards Institute 

 ASA/ANSI Acoustical Society of America/Acoustical Society of America 

 ASAE American Society of Agricultural Engineers 

 ASM American Society of Metals 

 ASME American Society of Mechanical Engineers 

 ASNT American Society for Nondestructive Testing 
171

 ASQ American Society For Quality 

 ASTM American Society for Testing and Materials 

 AWS American Welding Society 

 CCSDS Consultative Committee for Space Data Systems 

 CEOS Committee on Earth Observation Satellites 

 CGNS Computational Fluid Dynamics (CFD) General Notation System 

 EIA Electronic Industries Alliance 

 EIA/ANSI Electronic Industries Alliance / American National Standards 

 Institute 

 ESDA Electrostate Discharge Association 

 FGDC Federal Geographic Data Committee 

 GEIA Government Electronics & Information Technology Association 

 IEC International Electrotechnical Commission 

 IEEE Institute of Electrical and Electronic Engineers 

 IEST Institute of Environmental Sciences & Technology 

 IPC Institute for Interconnecting and Packaging Electronic Circuits 

 ISO International Organization for Standardization 

 ISO/IEC International Organization for Standardization/ International 

 Electrotechnical Commission 

 ISOC Internet Society 

 ITRI Interconnection Technology Research Institute 

 NACE National Association of Corrosion Engineers International 

 NCSL National Conference of Standards Laboratories 

 NFPA1 National Fire Protection Association 

 RTCA Radio Technical Commission for Aeronautics 

 SAE Society of Automotive Engineers 

 SFCG Space Frequency Coordination Group 

 TIA Telecommunications Industry Association 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

 

a. First time use of standards. 

b. No response. 

 

c. Multiple. 

d. Yes. 

e. No. 
172

 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

 OMB Circular A-119 continues to provide stimulus for NASA's effort to improve its 

Technical Standards Management System, enhance the use of Voluntary Consensus 

Standards Products, and challenge the need for NASA-unique Technical Standards 

requirements. 

8. Conformity assessment activities in which agencies were involved. 

As an acquisition oriented agency, conformity assessment is a major element of our 

policies and procedures to assure the safety and mission success of NASA programs. 

NASA is continuously evaluating and improving our conformity assessment practices 

and procedures. 

NASA has a long-standing practice of working with other government agencies and the 

public sector to integrate best practices into our activities. NASA continues to work with 

the Department of Defense (DoD) and the aerospace industry to adopt and define 

consistent quality practices. NASA routinely utilizes other government agencies to assist 

us with contract administration services (CAS) including substantial conformity 

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

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

conformity assessment services for NASA programs. These are ongoing relationships 

that utilize the expertise and infrastructure that are resident within these agencies and 

allow NASA to limit NASA internal assessments to areas where external capabilities are 

not available. The management and monitoring processes established for these CAS 

activities provides a mechanism to continually exchange ideas and best practices related 

to conformity assessment. 

Finally, NASA is pursuing Star status in the Occupational Safety and Health 

Administration's (OSHA) Voluntary Protection Program (VPP). Participation in the VPP 

provides a mechanism for both improving internal safety practices and for utilizing the 

services of the OSHA programs to perform oversight inspections. To date, the Langley 

Research Center and the Johnson Space Center have achieved Star status and have been 

recognized by OSHA, the other NASA Centers are in various stages of preparation for 

assessment by OSHA. 

9. Examples or case studies of standards successes. 

In FY 2002, NASA further enhanced its use and support of voluntary consensus 

standards through additions to the NASA Integrated Technical Standards System 

implemented during FY 2001. The primary goals of this system were to develop a suite 

of collaborative tools to: (1) provide consolidated, Web-based access to standards for 

NASA users agency-wide; (2) augment NASA’s use, support, and adoption of non-
173

government voluntary consensus standards by highlighting their availability; (3) provide 

users with notification on changes, updates, and revisions to standards in use and; (4) 

improve application of standards by linking them with engineering lessons learned, best 

practices, and experiences. 

In FY 2002, NASA personnel downloaded more than 26,525 non-government voluntary 

consensus standards from the agency-wide Full-Text Technical Standards System. User 

attention was directed to the adopted VCSs by designating them as “NASA Preferred 

Technical Standards.” 

The newly implemented Standards Update Notification System (SUNS) is now being 

recognized as a viable tool for bringing program specifications up to date. A pilot test of 

SUNS was conducted for the Space Shuttle Solid Rocket Booster-Thrust Vector Control 

Subsystem. Of the 298 non-NASA documents included in the 14 system specifications, 

the pilot test found that only 124 were still active, but the remaining 174 were either 

canceled or inactive; replacements or superseding documents were found for 129 of the 

174. Because of this pilot, the Space Shuttle Chief Engineers Council has given its 

endorsement of the SUNS for updating external references in all Space Shuttle Program 

documents—many of which are more than 20 years old. To date, nearly 5,000 

documents from a variety of programs have been registered for update notification. 

Approximately 28 percent of these documents have been updated by the respective SDO 

suggesting the need for substantial program follow-up. User comments have suggested 

that SUNS could be even more valuable for the agency if standards developing 

organizations would provide more information on what changes were made to a 

document, and particularly whether those changes are technical or editorial in nature. 

Experience suggests that linking lessons learned to relevant technical standards has 

significant potential for enhancing and improving engineering practices by providing a 

basis for the interpretation and use of standards. 

In FY 2002, over 264 lessons learned from NASA’s Lessons Learned Information 

System (LLIS) were linked to 89 relevant NASA Preferred Technical Standards; linking 

of lessons learned has already resulted in the update of some standards. Because of 

favorable user response, this effort is now being extended; over 150 aerospace 

engineering lessons learned databases were identified which link to over 1,300 lessons 

learned listings that will be used as a basis for this extension. To date, growing use of the 

NASA Integrated Technical System and feedback from users supports the value of the 

system to their work on NASA programs/projects and research activities. This is due to 

the ready availability of the technical standards products and integration of related 

information online, reinforcing the advantages of enterprise-wide solutions and the “onestop shopping” concept. 

On the international front, NASA-led efforts resulted in publication of two significant 

standards through ISO. As a result of government/industry/international team 

cooperation, NASA-STD-3000, "Man-Systems Integration Standards," widely used as 

the Human Factors standard for space systems, has been converted and adopted by ISO 
174

for publication as ISO/PRF 17399, “Space Systems—Man-Systems Integration.” Also, 

through similar cooperation on electromagnetic interference (EMI) for spacecraft, ISO 

14302, “Space Systems—Electromagnetic Compatibility Requirements” was developed 

and published in FY 2002. Through promotion of common standards, these initiatives 

have enabled greater collaborative efforts among the NASA Centers, realized cost 

savings through eliminating duplicate standards services, and enhanced engineering 

capability by providing common, seamless access to relevant and current standards. As 

such, they have made substantive contributions toward implementing the NASA 

Administrator’s vision of “One NASA.” 

10. Comments. 

 None. 
175

National Archives and Records Administration 

1. Government-unique standards used in lieu of voluntary standards. 

 61

 A. Government standard: DOJ U.S. Marshal’s Service requirements for 

 physical security 

 Voluntary standard: None available 

Explanation: There are no established voluntary standards that 

address the appropriate levels of security for 

government facilities 

B. Government standard: NARA data standard 

 Voluntary standards (5): MARC – Machine Readable Cataloging 

 EAD – Encoded Archival Description 

APPM – Archives, Personal Papers, and 

Manuscripts 

ISAD (G) – General International Standard 

Archival Description 

ISAAR (CPF) – International Standard Archival 

Authority Record for Corporate Bodies, Persons, 

and Families 

Explanation: These standards do not meet the precise needs of 

our agency. However, we continue to bring our 

individual data elements guidance closer into line 

with these voluntary standards. 

2. Identification of voluntary consensus standards that have been substituted by your agency 

for government-unique standards during the reporting period because of an agency 

review under section 15b (7) of the Circular. 

 1 

 

1

 NIST Editorial Note: NIST is revising the NARA number of government-unique standards (GUSs) used in lieu 

of voluntary consensus standards (VCSs) reported to NIST. NARA reports six GUSs used in lieu of VCSs. After a 

review of the NARA report, NIST believes the total number to be one. In paragraph 1A of its report, NARA counts 

one GUS as used in lieu of a VCS where no VCSs exist. Such GUSs do not need to be reported. In paragraph 1B of 

its report, NARA reports one GUS used in lieu of five VCSs. Therefore, the total number should be one instead of 

the six reported by NARA. 
176

We adopted ANSI/ISO 3334-1991, Micrographics – ISO Resolution Test Chart No. 2 – 

Description and Use, in place of NIST – SRM 1010a, Microcopy Test Chart (ISO Test 

Chart No. 2), certified June 1, 1990. 

3. The number of voluntary consensus standards that your agency used during FY 2002 

 based upon procedures set forth in Sections 11 and 12 of the Circular. 

 9 

4. The number of agency employees participating in voluntary consensus standards 

activities during this period. 

 13 

5. List by name and acronym of the voluntary consensus standards bodies in which NARA 

participated during the reporting period. 

12 

American National Standards Institute/National Information Standards Organization 

(ANSI/NISO) 

• Z39.18 Revision Committee (Scientific and Technical Reports: Elements, 

Organization, and Design) 

Association for Information and Image Management (AIIM) 

• C22 – Committee on Evidentiary Support 

Association for Suppliers of Printing, Publishing, and Converting Technologies (NPES) 

• PDF/A Working Group (joint with AIIM) 

International Council on Archives (ICA) 

• Descriptive Standards Committee 

International Organization for Standardization (ISO) 

• Technical Committee 42, Work Group 5 – Physical Properties and Image Permanence 

of Photographic Materials 

• Technical Committee 42, Work Group 5, Task Group 2 – Stability of Black-andWhite Prints 

• Technical Committee 42, Work Group 5, Task Group 3 – Stability of Color Pictorial 

Images 
177

• Technical Committee 42, Work Group 5, Task Group 4 – Stability of Medical 

Imaging Hardcopy Output 

• Technical Committee 46, Subcommittee 11 – Archives/Records Management 

National Fire Protection Association (NFPA) 

• Technical Committee on Records Protection 

Society of American Archivists (SAA) 

• Standards Committee 

• EAD Working Group 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

 

a. Does your federal agency report (1) only the first-time use of standards, (2) 

continued uses of standards or (3) both first time and continued uses of standards? 

(3) – We report the standards cited in any regulations issued in the Fiscal Year, 

including continued use of standards in revised regulations. 

b. Does your agency report (1) the total number of standards it uses or (b) each 

instance where the agency uses (i.e., references) a standard? 

 (1) – We report the total number of standards. 

c. Does your agency report multiple editions of a single standard as one standard 

used or as multiple standards used? 

 

 N/A, but we would report as multiple standards used if the occasion arose. 

d. Does your agency report standards that it uses for guidance purposes (as opposed 

to, or in addition to, standards used for compliance purposes)? 

 Yes. 

e. Does your agency report use of standards from non-ANSI-accredited standards 

developers including industry consortia? 

 None in FY 2002; however, we have reported participation in two non-ANSIaccredited voluntary consensus standards bodies in response to question two (ICA 

and SAA). 
178

7. An evaluation of the effectiveness of Circular A-119 policy and any recommendations for 

changes to the Circular. 

 We believe the Circular is working effectively and have no recommendations for 

changes. 

8. No comment. 

9. No comment. 

10. No comment. 
179

National Communications Systems 

Within the NCS, the Chief, Technology and Programs Division, also chairs the Federal 

Telecommunications Standards Committee (FTSC). As part of these duties, the Chief is 

the focal point for telecommunications and related information system standards for the 

Office of the Manager, National Communications System (OMNCS). His telephone 

number is (703) 607-6200, and his e-mail address is fonashp@ncs.gov. 

The OMNCS provides the chair of the FTSC. This interagency committee prepares 

standards and recommendations on matters affecting national security and emergency 

preparedness (NS/EP) and in other areas of communications approved by the committee 

because of requests from members. It also provides advice to members on how to best 

represent the government’s NS/EP interests in work in industry and international 

standards committee. 

The FTSC and members of the OMNCS work extensively with voluntary standards 

organizations to ensure that government requirements are considered as the standards are 

developed. 

 

Additional reporting requirements: 

1. Number of government-unique standards used in lieu of voluntary consensus standards. 

The OMNCS had no reportable use of government-unique standards in lieu of voluntary 

consensus standards during FY 2002. 

 0 

2. Number of voluntary consensus standards substituted for government-unique standards. 

The OMNCS has not substituted any voluntary consensus standards for governmentunique standards during the reporting period. 

 0 

3. The number of voluntary consensus standards that your agency used during FY 2002 

based upon procedures set forth in sections 11 and 12 of the Circular. 

 4 
180

4. Number of agency employees participating in voluntary consensus standards activities 

during this period. 

 10 

5. The list by name and acronym of voluntary consensus standards bodies in which the 

OMNCS participated during FY 2002. Staff of the OMNCS participate in the following 

voluntary standards related committees. 

15 

The OMNCS works within the voluntary consensus standards bodies to ensure 

developing and existing consensus standards to ensure that government requirements are 

considered. 

Organizations Accredited by the American National Standards Institute (ANSI):

- Committee T1, Telecommunications, and its technical subcommittees 

 - Telecommunication Industry Association (TIA) committees TR-41, TR-45, and TR-46 

 - Institute of Electrical and Electronics Engineers (IEEE) 

 Commercial and Multi-National Organizations Not Accredited by ANSI:

 - 3rd Generation Partnership Project (3GPP) 

 - 3rd Generation Partnership Project 2 (3GPP2) 

- ATM Forum 

- Federal Telecommunication Standards Committee (OMNCS furnishes Chair and 

 Executive Secretary) 

- Internet Engineering Task Force (IETF) 

- International Telecommunication Advisory Committee and its study groups 

 (Department of State) 

 - International Telecommunication Union, Telecommunications Sector (ITU-T) 

 - Multiservice Switching Forum (MSF) 

 - Network Interconnection Interoperability Forum (NIIF) 

 - Parlay Group Inc. (for Application Programming Interfaces) 

 - Telecommunications and Internet Protocol Harmonization Over Networks (TIPHON) 

 - TeleManagement Forum 

6. How agencies report their use of standards. 

 

 a. The OMNCS reports both continued uses of standards. 

 b. The OMNCS report the total number of standards it uses. 
181

 c. The OMNCS reports multiple editions of a single standard as one standard used. 

d. The OMNCS reports standards that it uses for guidance as well as those standards 

used for compliance purposes. 

e. The OMNCS reports the use of standards form non-ANSI-accredited standards 

developers including industry consortia. 

7. Evaluation of the effectiveness of Circular A-119 policy and recommendations for 

changes to the Circular. None that this time. 

8. The OMNCS has not been involved in any conformity assessment activities. 

9. No response. 

10. No response. 
182

National Science Foundation 

No report. 
183

Nuclear Regulatory Commission 

The Nuclear Regulatory Commission (NRC) has been an active participant in the development 

and use of consensus standards since its establishment in 1975. The agency developed guidance 

in 1997 to increase its focus and emphasis on interacting with both industry groups and 

professional societies to develop new codes and standards needed to support efficient, effective, 

and consistent performance of industry activities important to safety. Consistent with Public 

Law 104-113, National Technology Transfer and Advancement Act of 1995 (P. L. 104-113), the 

NRC encourages industry to develop codes, standards, and guides that NRC can endorse and the 

industry can carry out, and the NRC has taken steps to increase the involvement of licensees and 

others in the NRC regulatory process. 

In FY 2002, NRC took several actions to increase the effectiveness and efficiency of our process 

for implementing P. L. 104-113 and OMB Circular A-119, Federal Participation in the 

Development and Use of Voluntary Consensus Standards and in Conformity Assessment 

Activities. On February 20, 2002, NRC staff met with representatives from the standards 

development organizations (SDOs) who provide codes and standards for the nuclear industry. 

The NRC has been hosting these meetings on a semi-annual basis. The purpose of these 

meetings is to foster better communication and discuss standards under development, current 

needs, and priorities. The SDOs that the Department of Energy (DOE) interacts with are, in 

many cases, the same as the NRC, and the two agencies have begun co-hosting these meetings. 

This joint format has proved to be of such benefit that the National Institute of Standards and 

Technology (NIST), who has been a participant, increased its role by hosting the July 25, 2002, 

meeting. The next meeting has been scheduled for February 2003. 

Consistent with NRC Management Directive 6.5, NRC Participation in the Development and 

Use of Consensus Standards, which was created to provide direction to the NRC staff for 

implementing P.L. 104-113 and OMB Circular A-119, Web-based training has been developed 

for NRC staff connected with the use of standards. The purpose of the training is to explain the 

requirements of P.L. 104-113 and OMB Circular A-119 in detail and provide guidance to the 

NRC staff relative to organizational responsibilities. All NRC staff involved in the development 

and use of standards and cognizant management took this training in FY 2002. 

The NRC Web site, http://www.nrc.gov/what-we-do/regulatory/standards-dev/sdo-comm.html, 

contains, among other things, the SDOs with which the agency interfaces, consensus standards 

used by the NRC, and NRC staff representatives on SDO committees. 

1. Identification of all instances when the agency used government-unique standards in lieu 

of voluntary consensus standards (for each instance include agency rationale for such use, 

as well as the specific government-unique standard used). 

0 
184

2. Identification of voluntary consensus standards that have been substituted for 

government-unique standards because of an agency review under section 15(b) (7) of the 

Circular. 

 0 

3. The number of voluntary standards the agency adopted between October 1, 2001, and 

September 30, 2002, based on the procedures set forth in sections 11 and 12 of the 

Circular. 

 8 

 A. Standards adopted. During this reporting period, the NRC adopted eight American 

Society of Mechanical Engineers (ASME) Codes. It should be noted that standards that 

have not been generically approved for use by all licensees have not been listed (i.e., 

when one licensee requests permission and receives regulatory approval to use a specific 

standard). 

 

B. Identify those instances where, consistent with interim guidance, requests were made 

in proposed rulemaking for public comment on the use of consensus standards or 

information was provided in the final rulemaking regarding public comment on the use of 

consensus standards. 

Information regarding public comment on the use of consensus standards was provided in 

the following proposed rulemaking: 10 CFR Part 50, Industry Codes and Standards, 

66 FR 40626, August 3, 2001. 

4. Number of agency employees participating in voluntary consensus standards activities. 

 144 

5. The number of voluntary consensus standards bodies in which there is agency 

participation, as well as the number of agency employees participating. 

488 

During FY 2002, NRC staff participated within 15 SDOs on a total of 488 standards 

writing, consensus, and board-level committees. 

6. A description of how your agency currently reports its use of voluntary consensus 

standards. 

 

 a. No comment. 

 b. No comment. 
185

 c. No comment. 

 d. No comment. 

 e. No comment. 

7. An evaluation of the effectiveness of Circular A-119 policy and recommendations for any 

changes. 

The policy guidelines provided in OMB Circular A-119 for participating in voluntary 

consensus standards bodies and using voluntary consensus standards are generally 

consistent with long-standing NRC practices. The NRC staff believes that these 

guidelines provide appropriate direction and encouragement for federal agencies to 

develop internal agency-wide guidelines to implement P. L. 104-113 and OMB Circular 

A-119. These guidelines also provide sufficient and reasonable flexibility for each 

agency to make an independent case-by-case determination as to the usability of a 

particular standard within that agency’s scope and responsibility. 

8. No comment. 

9. No comment. 

10. No comment. 
Standards Endorsed by NRC 

October 1, 2001 - September 30, 2002 

SDO1 

Standard Identifier Year Title 

ASME BPV 1997 ASME Boiler and Pressure Vessel Code ASME BPV 1998 ASME Boiler and Pressure Vessel Code ASME BPV 1999 ASME Boiler and Pressure Vessel Code ASME BPV 2000 ASME Boiler and Pressure Vessel Code ASME OM 1997 Code for Operation and Maintenance of Nuclear Power Plants ASME OM 1998 Code for Operation and Maintenance of Nuclear Power Plants ASME OM 1999 Code for Operation and Maintenance of Nuclear Power Plants ASME OM 2000 Code for Operation and Maintenance of Nuclear Power Plants 

Table footnotes: SDO: Standards Developing Organization ASME: American Society of Mechanical Engineers Amendment to 10 CFR 50.55a (67 FR 60520; September 26, 2002) 

186
U.S. Government Printing Office 

The GPO utilizes available voluntary standards in its many operations whenever they are 

applicable. However, some standards are unique to GPO's printing and binding 

operation. These include: 

• Quality assurance through attributes program for printing and binding 

• Quality assurance through attributes program for microforms

• Quality assurance through attributes program for composition 

• GPO guidelines for specifying quality and determining compliance of MICR, OCR, 

and OMR 

• Government paper specification standards 

• Government paper samples 

The number of voluntary consensus standards used this past year has increased since the 

last report but the number is not currently available. 

GPO employees in scientific fields (e.g. engineering, paper science, chemistry, and print 

technology) attend and participate on a voluntary basis in professional organizations that 

are involved in standards work. Some are ASTM, ANSI, AIIM, and TAPPI. The 

number of employees involved varies from year to year depending on available funds. 

The GPO has a new effort in place for FY 2003 to review all of its material and graphic 

supply procurement specifications and identify voluntary consensus standards for their 

purchase. GPO will also implement a 5-year review cycle for standards developed inhouse. 

Even though GPO is a legislative agency, the application of the OMB Circular A-119 in 

our work has saved resources by not “reinventing the wheel.” 

187
U.S. Postal Service 

A representative of the USPS Engineering Branch reported that there is no office within 

the Postal Service that develops standards applicable to any other federal agency. 

Within the Engineering Branch, the focus is to utilize commercial standards wherever 

feasible. However, they do have 1,110 internal engineering standards2

 that address 

requirements for the fabrication and/or manufacturing of postal equipment (to include 

repair parts). Those standards address such issues as material and process requirements 

to ensure uniformity in deployment of USPS equipment nationwide. A disciplined USPS 

engineering process is used to develop each standard. 

 

2

 NIST Editorial Note: NIST is not reporting the 1,110 internal engineering standards reported by the 

USPS as government-unique standards. NIST is not aware of any voluntary consensus standards that

duplicate the USPS standards. Therefore, the 1,100 USPS are not “government-unique standards used in 

lieu of voluntary consensus standards.” 

188
APPENDIX C -- LIST OF AGENCIES 

ATBCB – Architectural and Transportation Barrier Control Board 

CPSC – Consumer Product Safety Commission 

DOA/AMS – Department of Agriculture, Agricultural Marketing Service 

DOA/APHIS – Department of Agriculture, Animal and Plant Health Inspection Service 

DOA/CCC – Department of Agriculture, Commodity Credit Corporation 

DOA/FNS – Department of Agriculture, Food and Nutrition Service 

DOA/FSIS – Department of Agriculture, Food Safety Inspection Service 

DOA/GIPSA – Department of Agriculture, Grain Inspection, Packers, and Stockyard 

 Administration 

DOA/RUS – Department of Agriculture, Rural Utilities Service 

DOC/NIST – Department of Commerce, National Institute of Standards and Technology 

DOC/NOAA/NMFA – Department of Commerce, National Marine Fisheries Administration 

DOC/PTO – Department of Commerce, Patent and Trademark Office 

DOC/TA – Department of Commerce, Technology Administration 

DOE – Department of Energy 

DOE/FERC – Department of Energy, Federal Energy Regulatory Commission 

DOI – Department of the Interior 

DOI/MMS – Department of the Interior, Minerals Management Service 

DOI/OSM – Department of the Interior, Office of Surface Mining 

DOI/USFWS – Department of the Interior, U.S. Fish and Wildlife Service 

DOJ – Department of Justice 

DOL/MSHA – Department of Labor, Mine Safety and Health Administration 

DOL/OSHA – Department of Labor, Occupational Safety and Health Administration 

DOL/Public Contracts – Department of Labor, Employment Standards Administration, 

 Wage and Hour Division 

DOT/FAA – Department of Transportation, Federal Aviation Administration 

DOT/FHWA – Department of Transportation, Federal Highway Administration 

DOT/FMCSA – Department of Transportation, Federal Motor Carrier Safety Administration 

DOT/FRA – Department of Transportation, Federal Railway Administration 

DOT/NHTSA – Department of Transportation, National Highway Traffic Safety 

 Administration 

DOT/OPS – Department of Transportation, Office of Pipeline Safety 

DOT/RSPA – Department of Transportation, Research and Special Programs Administration 

DOT/USCG – Department of Transportation, U.S. Coast Guard 

Education – Department of Education 

EPA – Environmental Protection Agency 

FCC – Federal Communications Commission 

FTC – Federal Trade Commission 

HHS – Department of Health and Human Services 

HHS/Center for Medicare and Medicaid Services 

HHS/FDA – Department of Health and Human Services, Food and Drug Administration 

HHS/HCFA – Department of Health and Human Services, Health Care Facilities 

 Administration 

HHS/PHS – Department of Health and Human Services, Public Health Service 

189
HUD – Department of Housing and Urban Development 

NSF – National Science Foundation 

NRC – Nuclear Regulatory Commission 

SBA – Small Business Administration 

Treasury, BATF – Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms

U.S. Army Corps of Engineers 

USAID – Agency for International Development 

USPS – United States Postal Service 

190
APPENDIX D – TABLES AND CHARTS 

Table 1 – FY 2002 Statistics on Federal Agency Participation in Development and 

Adoption of Voluntary Consensus Standards 

FY 2002 STATISTICS ON FEDERAL AGENCY PARTICIPATION IN DEVELOPMENT AND ADOPTION 

OF VOLUNTARY CONSENSUS STANDARDS 

Number of 

Agency 

Employees 

Participating in

Voluntary 

Consensus

Standards 

Activities

Number of 

Voluntary 

Consensus

Standards Used 

Number of 

Voluntary 

Consensus

Standards 

Activities in 

Which 

Agencies 

Reported 

Participation in

2001 FY 

2002 

Change

from 

FY 

2001 

FY 

2002 

Change 

from FY 

2001 

Number of Voluntary 

Consensus Standards 

Substituted in FY 2002 

for GovernmentUnique Standards

Number of 

Government-Unique 

Standards Used in 

Lieu of Voluntary 

Consensus Standards 

in FY 2002 

1,157 3,229 512 2,959 -790 91 65 

191
Table 2 –Federal Agency Information Provided in Agency Reports 

2002 Federal Agency Information on Participation/Adoption of Voluntary

Standards Activities Required by OMB Circular A-119 

Agency

GUS 

Used 

in 

Lieu 

of 

VCS 

VCS 

Substituted 

for GUS 

VCS 

Used 

in 

2002 

Agency

Employees 

Participating 

in VCS 

Activities 

Change 

from

2001 

VCS 

Activities In 

Which There

is Agency

Participation 

Change 

from FY 

2001 

USDA 0 0 177 82 23 51 12

DOC 0 0 0 439 -1 165 -3

DOD 0 64 53 461 -79 109 54

NCS 0 0 4 10 0 15 -3

ED 0 0 17 2 0 1 0

DOE 0 0 164 681 18 57 -1

HHS 5 1 616 515 234 39 -18

HUD 2 1 300 10 0 5 0

DOI 2 0 616 300 231 19 14

DOJ 0 0 72 5 0 2 -1

DOL 4 0 200 60 -16 15 -20

DOS 0 0 0 0 -8 0 -1

DOT 1 0 212 176 -1 54 -114

TRES 4 0 334 66 -1 8 0

VA 0 0 0 14 2 20 -4

USAID 0 0 0 0 0 0 0

CPSC 0 1 1 29 -2 8 -1

EPA 38 2 9 42 -4 22 2

FCC 0 0 0 5 0 7 6

FEMA N/R N/R N/R N/R N/R N/R N/R 

FTC 0 0 0 0 0 0 0

GSA 2 19 81 44 3 24 -83

GPO 6 N/R N/R N/R 0 N/R 0

USITC 0 0 0 0 0 0 0

NASA 0 2 86 131 100 36 27

NARA 1 1 9 13 8 12 6

NSF N/R N/R N/R N/R 0 N/R 0

NRC 0 0 8 144 5 488 470

USPS 0 0 0 0 N/R 0 N/R 

TOTALS 65 91 2,959 3,229 512 1,157 342

Note: "N/R" means No Report received. 

192
Chart 1 – Number of Voluntary Consensus Standards Used 

Number of VCSs Used

5,453

2,959 2,669

3,749

1,876

543

0

1,000

2,000

3,000

4,000

5,000

6,000

1997 1998 1999 2000 2001 2002

Year

Nu

mber of VCSs Used

193
Chart 2 – Number of Voluntary Consensus Standards Activities with Employee 

Participation 

Number of VCS Activities with Employee Participation

1,157

847 885

823

869

945

0

200

400

600

800

1,000

1,200

1,400

1997 1998 1999 2000 2001 2002

Year

Nu

mber of employees

194
Chart 3 – Number of Voluntary Consensus Standards Substituted for GovernmentUnique Standards 

VCS Substituted for GUS

537

91

146

106

542

187

0

100

200

300

400

500

600

1997 1998 1999 2000 2001 2002 Year

Number of Substitutions

195
Chart 4 – Number of Government-Unique Standards Used in Lieu of Voluntary 

Consensus Standards 

GUSs Used in Lieu of VCSs

88

54 65

16

7 4

0

20

40

60

80

100

1997 1998 1999 2000 2001 2002

Year

Nu

m

b

er of GUS

s Us

e

d

196