VOLUNTARY INDUSTRY STANDARDS

AND THEIR RELATIONSHIP TO

GOVERNMENT PROGRAMS

Licensing Programs Division

Office of Commercial Space Transportation

U.S. Department of Transportation

January 1993
VOLUNTARY INDUSTRY STANDARDS 

AND THEIR RELATIONSHIP TO GOVERNMENT PROGRAMS

Table of Contents

Section Page

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Potential Relationship of Voluntary Industry Standards to Commercial

Space Regulatory Regime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Extent of Standardization in Commercial Space Launch Industry . . . . . . . . . 1

OCST Undertakes Study of Voluntary Standardization . . . . . . . . . . . . . . . . 1

What OCST Learned From Its Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Next Steps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Organization of this Paper . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2. WHAT ARE VOLUNTARY INDUSTRY STANDARDS AND HOW DO THEY

WORK? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

The Importance of Standardization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Defining Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

The Benefits/Problems Associated With Standards . . . . . . . . . . . . . . . . . . . 8

The Standards Development Process in the U.S. . . . . . . . . . . . . . . . . . . . . 10

International Standardization Activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Relationship of Voluntary Industry Standards to Government Programs . . . . 14

Economic Aspects of Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

3. COMPARISON OF SELECTED INDUSTRY STANDARDIZATION PROGRAMS . . . 17

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Common Aspects of Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Significant Differences Among Programs . . . . . . . . . . . . . . . . . . . . . . . . . . 24

RESEARCH CONTACTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

BIBLIOGRAPHY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

APPENDIX: ANALYSIS OF SPECIFIC INDUSTRY STANDARDS PROGRAMS . . . . . . . . . A-1
VOLUNTARY INDUSTRY STANDARDS

AND THEIR RELATIONSHIP TO GOVERNMENT PROGRAMS

1. INTRODUCTION

Potential Relationship of Voluntary Industry Standards to Commercial Space Regulatory

Regime

The Office of Commercial Space Transportation (OCST), in developing its program for

ensuring that commercial space operations adequately protect public safety and the

environment, confronts the challenge of devising an effective means for accomplishing this

objective while simultaneously nurturing a healthy and internationally competitive commercial

space industry. In meeting this challenge, OCST has emphasized flexibility and the use of

innovative approaches, rather than simply relying on the traditional "command-and-control"

regulatory strategy that characterizes many Federal regulatory programs in the health, safety,

and environmental arenas.

An important aspect of OCST's flexibility in its safety regulatory approach is its interest

in taking advantage of the potentially complementary role of voluntary industry safety

standards. While OCST has the authority to employ an exclusively regulatory strategy in

fulfilling its mission, or -- at the other extreme -- deferring in large part to voluntary standards

as the means to protect public safety and the environment, there are numerous intermediate

points along the spectrum. The real question is: To what extent, and how, should OCST

integrate voluntary standards within its regulatory regime? Answering the "to what extent"

dimension of this question requires an assessment of the breadth and qualitative adequacy of

private standards in the commercial space industry. The "how" aspect focuses on the best

means of integrating voluntary standards, whether it be by implicit reliance on such standards

or formal incorporation of standards into OCST rules.

Extent of Standardization in Commercial Space Launch Industry

Examining these policy questions led OCST to review the state of voluntary

standardization in the commercial space launch industry. What the Office found is that,

although modern launch vehicles and systems embody standards developed for certain

common technologies in the aviation, aerospace, and electronics industries, there are very few

standards set for aspects of commercial space (e.g., vehicle/payload interfaces) that have an

important impact on the commercial viability of the industry. It is apparent that the commercial

space launch industry has not perceived the economic advantages that such standards can

provide. This situation in part may be due to the fact that until recently there was no

commercial space "industry," per se. Historically, launch operators did not operate in a truly

commercial market; their products and services were subject to extensive customer (U.S. Air

Force and NASA) specification. 

OCST Undertakes Study of Voluntary Standardization

Before addressing the important policy issues identified above, OCST decided to step

back and conduct a brief examination of how other federal agencies interact with voluntary

industry standardization programs. Such an understanding, it was thought, would inform

OCST in both promoting appropriate voluntary standardization efforts in the commercial space
launch industry and in incorporating such standards in its safety regulatory program in an

optimal fashion. This paper summarizes some of the key insights learned from the study,

providing a general understanding to OCST (and industry) as they begin to take concrete

steps to further the extent of voluntary standardization in the commercial space launch

industry. 

In undertaking its study, OCST first conducted a brief overview of voluntary

standardization programs in a wide variety of industries. Based on the results of that

overview, and with the objective of focusing project research most productively, OCST

selected five industries to receive more detailed scrutiny:

• Aerospace and Aviation;

• Automobile;

• Petrochemicals;

• Electronics; and

• Shipping.

OCST gathered information about the principal standardization organization(s) active in each

of these industries. In addition, the cross-industry coordinating role of the American National

Standards Institute (ANSI) was examined.

For each standardization body examined, a common set of information categories was

used to guide research and analysis:

• Genesis of the standards program;

• Key factors in the evolution of industry standards;

• Procedural mechanisms for development/implementation/enforcement;

• Relationship of industry standards programs to government safety standards 

programs;

• Legal issues: and

• International issues.

OCST obtained its information from interviews with staff of each standard-setting

organization. In addition, an extensive search was conducted of recent literature on the topic

of voluntary standards programs. This literature search provided a broader perspective on

industry standardization generally. In analyzing the information obtained, particular attention

was paid to identifying common factors or elements, as well as fundamental differences,

among the various industry standardization programs.

At the same time OCST's study was underway, the Office of Technology Assessment

was conducting a similar, but broader examination of the impact of standardization on U.S.

economic competitiveness. That study, entitled "Global Standards: Building Blocks for the

Future," had a significant impact on OCST thinking as the Office was considering the role of

industry standards as a complement to its safety regulatory program.
What OCST Learned From Its Study

OCST's study, although brief and preliminary in nature, yielded important insights to

guide future Office participation in voluntary standards setting. First, OCST participation in,

and support for, voluntary standardization efforts is consistent with U.S. government policy. 

Specifically, development of a regulatory regime that integrates both regulations and voluntary

standards is consistent with the underlying principles of Federal regulatory policy. Executive

Order 12291 (February 17, 1981), for example, proscribes Federal standards covering private

goods or services except where those are needlessly unsafe or product variations are

wasteful, and private standards have failed to correct the problem.

Second, OCST came to the conclusion that a role in encouraging voluntary industry

standards is consistent with OCST's mandate to promote public safety. While members of the

industry might be expected to promote industry standards out of their own economic selfinterest, OCST's interest is in fostering private actions, including voluntary standards-setting,

that furthers its own public safety objective.

Third, there are numerous and varied precedents for federal agencies both to catalyze

industry standard-setting activities and to employ voluntary standards as part of, or as a

complement to, mandatory government safety regulations or procurement standards. In many

cases, federal agencies have helped start or accelerate standard-setting efforts by private

parties, particularly in nascent industries. Once voluntary standards have been set, it is very

common for government agencies to incorporate or adopt such standards as part of, or even

in place of, new government safety standards. When Congress passed the National Traffic

and Motor Vehicle Safety Act of 1966, the Department of Commerce was directed to review

existing voluntary industry standards to determine which might appropriately be used as a

basis for interim national standards. Currently, the Consumer Product Safety Commission's

regulatory regime, for example, is extremely reliant on private standards. The Coast Guard

relies heavily on American Bureau of Shipping rules to form basic components of the federal

maritime regulatory regime.

Fourth, voluntary standardization is a common, almost ubiquitous phenomenon in U.S.

industry. A number of industries in the U.S., including aerospace and aviation, have

established formal standardization programs governing the manufacture of products. The

objectives and format of such standards vary widely. In many cases, these standards predate the development of direct Federal safety regulation. In some cases, industry standards

have been relied upon substantially by federal agencies in place of regulation, or as the partial

basis for mandatory federal safety standards, as well as in the development of procurement

specifications.

Fifth, such standardization efforts have often played a critical role in advancing (or

even making possible) the commercial viability of various U.S. industries. Voluntary standards

have played an especially important role in the growth and evolution of the transportation

sectors of the U.S. economy. For example, a modern system of railroads, and the vast

economic benefits provided by such a system, would not have been possible without early

efforts to develop uniform standards covering track gauges and the interoperability of brakes

and couplings. These standards made possible the interchangeability of the rolling stock of

the nation's many different railroad lines. The economic importance of a standard railroad

gauge is difficult to overestimate. Most of the country followed the example of northeastern
railroads in converting to a four foot eight inch gauge; economic growth in the South, however,

was stymied substantially until that region's railroad companies followed suit in 1886, the year

the South -- economically speaking -- "joined the Union."1

 Interestingly, at the present time,

the absence of a uniform gauge for freight trains among European countries has made it

difficult for U.S. package delivery services and their European competitors to duplicate on the

continent the success of United Parcel Service and others in this country. 2

The important economic contribution standards could make was also recognized early

by leaders in the automotive industry. The earliest standardization efforts among automakers

date to 1910. By 1921, the Society of Automotive Engineers (SAE), a previously existing

organization that took on the role of standards-setter for the industry, had already published

224 sets of standards, principally focused on the dimensions of auto parts and accessories.3

The promulgation of product standards opened the auto parts marketplace to numerous small

manufacturers and reduced the dependency of the auto assemblers on a few suppliers. The

importance of SAE's standards increased greatly as automotive technology progressed and

the complexity of automobiles as engineering systems increased.

Voluntary standardization efforts have proven no less important in the aviation and

space fields than they had earlier in the railroad and automotive industries. Several private

organizations, including the Aerospace Industry Association (AIA) and SAE have played

leading roles in establishing standards in the aviation industry. More recently, the American

Institute of Aeronautics and Astronautics (AIAA) has become active in this arena. There has

been a greater degree of standardization in aviation than in the space industry, largely due to

the relative newness of space technologies. In addition, space systems incorporate many

technologies pioneered in aviation, taking advantage of previously developed standards.

Space standards can be expected to increase in importance with the increasing

commercialization of the space industry. Increased systems complexity, taking the industry

well beyond technologies applied in aviation or even the Federal space program, will

necessitate the development of new standards. In addition, as the volume of commercial

space launches grows, the economic importance of standards in lowering production costs

and insuring the interoperability of vehicles and equipment will grow. Finally, as the

commercial space industry becomes both more international and cost-competitive, the

harmonization of standards among participant countries will become a significant issue. 

Continued expansion of U.S. space equipment exports, which grew three-fold from 1987 to

1991 (when they were valued at $2.5 billion dollars), will depend in part on American ability to

influence, as well as conform to, international standards. (The importance of standards to the

international competitiveness of U.S. industry generally is emphasized in the recent OTA

report.)

Finally, there is a role for OCST in helping create a framework or mechanism that will

accelerate the pace of voluntary standardization in the commercial space launch industry. 

 

 

1Martin, Albro. Railroads Triumphant. Oxford: Oxford University Press, 1992, p. 46.

 

2Washington Post, May 12, 1992, p. C1.

 

3Hemenway, David. Industrywide Voluntary Product Standards. Cambridge, MA:

Ballinger, 1975.
The industry itself has already begun to become more cognizant of how their economic

interests can be served in the standardization process; OCST can serve its safety objective by

fostering momentum in this direction. What is required is to create an institutional framework,

working with established standards-setting organizations, within which commercial space

standardization can be encouraged and reinforced.

Next Steps

Because OCST believes that its safety regulatory objective would be greatly advanced

by promoting the commercial space launch industry's own efforts to develop voluntary

standards, the Office made a decision to actively encourage voluntary safety standardization

efforts in the commercial space launch industry. In reaching this decision, OCST came to

believe such a role is entirely consistent with the Office's statutory charter to promote public

safety.

Having reached this decision, OCST has committed to two key next steps:

• To distribute its report to the standards-setting organizations examined in its

study, to provide them the opportunity to provide feedback regarding important

factual issues as well as findings and conclusions; and

• To reach out proactively to existing voluntary standards-setting organizations to

explore what specific needs there are for voluntary standards in the commercial

space launch industry and how OCST can best help create the framework or

infrastructure to meet those needs.

Organization of this Paper

This paper summarizes the findings of OCST's study in three principal sections:

• Section 2 provides an overview of voluntary industry standards and how they

operate. This discussion defines and categorizes various types of standards;

identifies some of the benefits and potential problems resulting from

standardization; outlines the process by which standards are established;

discusses the relationship between voluntary industry standards and

government programs; sketches the increasingly important international context

in which U.S. standards programs operate; and discusses key economic and

legal aspects of standards.

• Section 3 provides a comparative analysis of the industry standards programs

researched in this study, summarizing the key commonalities and differences

discovered among those programs.

• For those readers interested in more detail, the Appendix presents a summary

of the information obtained from the standards-setting organizations researched

in this project. A brief write-up is provided for each of these standardization

programs. These summaries illustrate the point that there are many models

that can be adapted in undertaking voluntary standardization in the commercial

space industry.
2. WHAT ARE VOLUNTARY INDUSTRY STANDARDS AND HOW DO THEY WORK?

The Importance of Standardization

As has been noted in the railroad and automotive industries, standards provide one of

the fundamental underpinnings of a modern economy. They ensure that parts or products

made in one factory by one manufacturer will function together with complementary products

made by other manufacturers as part of a technological system.

The relationship between standards and mass production was self-reinforcing. Further

advances in precision manufacturing required the development of machine tools and

precision gauges, which in turn further drove the need for standards and standard

measures.4

Standards are particularly important in so-called "high technology" systems, which are typified

by a large number of parts and precise performance specifications. As summarized in a

recent Office of Technology Assessment report:

Standards development today occupies the attention of a large and growing community

of professionals worldwide. In the U.S. alone, over 400 private organizations had, as of 1987,

promulgated over 30,000 standards covering all manner of products and services.5

 Standardsetting organizations include professional societies, trade associations, and groups solely

focused on standards-related issues. Several Federal agencies, most notably the National

Institute for Standards and Technology (NIST), actively follow or encourage private

standardization developments. There is also a Standards Engineering Society, which

publishes a journal covering a broad range of standards-related topics. Internationally, the

harmonization of product and service standards has played an important role in negotiations

as diverse as European economic integration ("EC '92"), the General Agreement on Tariffs

and Trade (GATT), and the proposed U.S.-Mexico free trade pact.

The promulgation of standards, however, is by no means a recent preoccupation. 

Certain standards, such as common languages, calendars, and systems of weights and

measures, provide the foundation for civilization itself. The development of modern product

standards traces back to the Industrial Revolution in Great Britain. In one of the earliest

examples of a standard, the British in 1841 settled on a common screwthread, called the

"British Standard Whitworth Thread." In the U.S., a competing screwthread standard was set

in the 1860s.6

 

 

4U.S. Congress, Office of Technology Assessment: Global Standards: Building Blocks

for the Future. TCT-512. Washington, D.C.: U.S. Government Printing Office, March 1992, p.

40.

 

5Breitenberg, Maureen A.: "The ABC's of Standards-Related Activities in the United

States." Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards,

May 1987, p. 1.

 

6Hemenway, David. Industrywide Voluntary Product Standards. Cambridge, MA: 

Ballinger, 1975, p. 3.
The persistence of different standards for basic industrial parts has created significant

problems. In the case of screwthreads, incompatibility between U.S. and British screws

prevented the interchanging of the two allies' tank parts in North Africa during World War II,

thereby immobilizing significant numbers of vehicles at critical times. This particular problem

was rectified in 1948 with the adoption of an International Screwthread Standard.7

One of the longest-standing debates over international standards concerns the choice

of measurement systems. The contestants are the Metric System, devised during the French

Revolution, and the so-called "Customary System." Although the rest of the developed world

has long-since implemented the Metric System, the Customary System remains predominant

in the U.S. And this despite the formal Congressional adoption of the Metric System in 1884,

and several more recent pro-Metric Executive and Congressional proclamations.

Among the most taken-for-granted examples of domestic standards is the color of

traffic lights. Until 1927, when the American Association of State Highway Officials, the

National Safety Council, and the National Bureau of Standards collaborated to standardize the

meaning of the colors green, yellow, and red as used in traffic lights, there was no color

consistency from city to city, state to state. This situation obviously presented significant

hazards as Americans became more mobile and increasingly undertook cross-country trips.8

Defining Standards

Standards have been defined in one survey of the topic as "...guidelines which are

accepted for current use through authority, custom, or general consent."9

 The National

Standards Policy Advisory Committee has defined standards as, "A prescribed set of rules,

conditions, or requirements concerning definitions of terms; classification of components;

specification of materials, performance, or operations; delineation of procedures; or

measurement of quantity and quality in describing materials, products, systems, services, or

practices."10

At the most general level, standards can be classified as either "natural" or "organized"

standards.11 The former, often referred to as "de facto" standards, evolve through informal

 

 

7

ibid., p. 4.

 

8Breitenberg, Maureen A.: "The ABC's of Standards-Related Activities in the United

States." Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards,

May 1987, p. 3.

 

9Reddy, N. Mohan and Cort, Stanton G.: "Industrywide Technical Product Standards." R &

D Management, 19, 1, 1989, p. 14.

 

10Breitenberg, Maureen A.: "The ABC's of Standards-Related Activities in the United

States." Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards,

May 1987, p. 1.

 

11The focus of this report is on standards widely adopted for use in industry. Thus, by

definition, "standards" established by individual companies for their own use in manufacturing

and procurement are not discussed here.
means, as a specific technology or practice becomes widely adopted. This process is often

driven by the overwhelming technical superiority of a particular product or by the market

dominance of its producer. The DOS operating system and the architecture of the IBM

Personal Computer are recent examples of this type of informal standard.

Organized standards, also referred to as "de jure," are more the topic of this study. 

These standards arise through formal, consensus-oriented efforts, typically coordinated by

organizations devoted to standards setting. De jure standards include both those promulgated

by government and those established voluntarily by industry. One estimate is that 80 percent

of standards for industrial and intermediate (as opposed to consumer) products in the U.S. are

voluntary in origin.12

Voluntary standards fall into several basic categories in terms of their purpose or the

function they serve:

• Nomenclature/symbolic standards, which aim to standardize the language used

in describing and using emerging technologies;

• Simplification standards, which seek to reduce product variety, especially

differences in product dimensions;

• Uniformity/interchangeability standards promoting the compatibility of individual

products to function as part of an industrial or technological system; and

• Performance/quality standards, which seek to improve product reliability,

durability, efficiency, safety, and environmental performance by setting

minimum thresholds.

Another category of standards, those covering testing, inspection, and certification

procedures, are somewhat different in nature; they concern the means by which compliance

with the other types of standards is determined. Certification standards, often in the form of

licensure requirements, are also the type of standard most applied to services, as opposed to

products.

The Benefits/Problems Associated With Standards

Advocates of industry standards have advanced many arguments for such voluntary

product norms. Principally, standards are said to:

• Promote lower product costs;

• Lower entry barriers to market participation;

• Improve product performance;

• Reduce consumers' transactions costs; and

 

 

12ibid., p. 14.
• Accelerate the diffusion of technology.

By reducing product diversity, manufacturers are able to realize economies of scale in

production. Users of a standardized product, in turn, are able to reduce their costs by limiting

their inventories. Users are not reliant on one or a few producers of a unique product; they

can obtain additional inventory from many producers. By in effect defining what a marketable

product is, standards make it possible for more firms, particularly smaller firms, to get into a

market. Increased market participation increases price competition.

Quality or performance standards set a minimum threshold or floor that products must

exceed. Although the performance dimensions of concern vary by industry and product, this

type of threshold helps eliminate "substandard" products.

Consumers, whether they be individuals or firms, often rely on standards -- reflected

in the presence of a seal, logo, or some other symbol -- to very efficiently convey important

information about a product. They can tell at a glance that the product in question meets the

standards relevant to their use or application; they do not have to waste scarce time

conducting a detailed investigation of the product's performance specifications. Reliance on

standards reduces the importance of brand names -- another traditional buyer's "crutch" in

evaluating competing products. The purchase decision tends to turn on price alone. In this

way, products in effect become commodities, driving prices down.

The process by which standards typically are set, involving the development of

consensus among producers, users, and others concerned with a particular product, involves

a great deal of sharing of information that otherwise would be kept proprietary. This process

accelerates the diffusion of technical knowledge.

Although most of the literature surveyed by OCST in this project is devoted to

examining these benefits of standards, and the processes by which standards are arrived at,

standards and standardization programs do pose potential problems that must be considered

in any survey of the field. Critics of voluntary industry standards argue they may:

• Provide an opportunity for industrial collusion or restraint of trade;

• Establish unnecessarily high performance requirements;

• Create barriers to market entry;

• Freeze or retard technological innovation; and

• Reduce consumer choices.

Anytime two or more firms in the same industry get together, concerns about collusive

behavior arise. Those involved in the standards-setting process potentially have an

opportunity to undercut the competitive position of nonparticipants. The Federal Trade

Commission (FTC) has devoted significant resources to examining the potential

anticompetitive effects of voluntary standards programs, and has promulgated rules

establishing procedural due process requirements for standards-setting groups. They have

been particularly concerned about the incentive firms have to "legislate in" or have "spec'd in"

their own products to the disadvantage of their competitors. The often great expense involved
in participating in lengthy and intensive standards committees can limit the participation of

smaller firms.13

Whether or not by collusive intent, standards may lock-in artificially high or excessive

performance specifications. Less expensive products that objectively meet consumers' needs

may be eliminated or hampered competitively in the marketplace. Specifications which

exceed needs can also prevent firms from entering the market, due to financial or technical

constraints; the presence of fewer firms in the market drives prices up.

Standards may also create a performance ceiling, effectively removing the incentive for

firms to innovate. Depending on the degree of consumer reliance on a particular standard,

the development of entirely new ways of meeting a consumer need (possibly by an entirely

different industry) may be stymied. Standards which specify the design features of a product

(as opposed to performance parameters) particularly inhibit the development of innovative,

cheaper ways of meeting a need. Timing is also important: The premature specification of a

standard can retard useful innovation.

Whatever the factors driving standardization, the effect typically is to reduce the variety

of alternative products in the marketplace. Whatever the other benefits the consumer may

reap from standardization, maximization of choice in itself is a value.

The Standards Development Process in the U.S.

Standards development, by its nature, is a collective process undertaken by voluntary

organizations. The first standard-setting organization in this country was the United States

Pharmacopial Convention, which was established in 1829 to set uniform standards for drugs.14

As previously noted, presently there are a large number of standards-setting organizations in

the U.S. (Some of the most important of these organizations are discussed in the Appendix

below.) That number is multiplied when focusing on the increasing development of

international or "harmonized" standards.

Compared to other developed nations, America's standardization structure is highly

decentralized. Although there have been proposals to establish a Federal agency to

coordinate private standardization activities, the American National Standards Institute (ANSI),

a private body, remains the predominant coordinating body in the U.S. standards development

process. ANSI provides the framework and process through which most U.S. standardization

activity takes place. Although ANSI does not itself set standards, it reviews the

standardization work of its member organizations and designates as "American National

Standards" those voluntary codes and specifications that meet the Institute's consensus and

other process requirements. The National Institute for Standards and Technology (NIST)

(formerly known as the National Bureau of Standards), the leading Federal agency involved in

standardization activities across many industry sectors, is principally an observer of private

efforts and does not play a strong controlling or coordinative role.

 

 

13Federal Trade Commission, Bureau of Consumer Protection. Standards and

Certification: Final Staff Report. Washington, D.C., April 1983, p. 22.

 

14U.S. Congress, Office of Technology Assessment: Global Standards: Building Blocks for

the Future. TCT-512. Washington, D.C.: U.S. Government Printing Office, March 1992, p. 46.
"Grass-roots" standard-setting activity takes place within a wide variety of organizations

that tend to fall within several basic categories:

• Engineering and professional societies (such as the American Society of

Mechanical Engineers (ASME) and SAE); 

• Trade associations (such as the American Petroleum Institute);

• General membership organizations (such as ASTM);

• Consortia, which are particularly active in the information and communications

industries; and

• Third-party certifiers (such as Underwriters Laboratories).

U.S. standard-setting organizations vary in terms of the scope and extent of their activities and

influence. Among the broadest and most important is the American Society for Testing and

Materials (ASTM), which manages the development of standards in a variety of industries and

disciplines. In addition, other organizations including laboratories (such as Underwriters Labs)

and industrywide research consortia are active in the standards field.

There is a great degree of similarity among standards-setting organizations in the basic

processes they employ. One authority on voluntary standards programs has identified five

procedural aspects common to most standard-setting organizations:

• Committees and subcommittees are "balanced" to ensure that they are not

dominated by any one economic interest;

• Standards are approved by a "consensus," meaning more than a simple

majority, but not necessarily unanimity;

• Negative or "no" votes on proposed standards are handled quite formally,

usually requiring explanations which are reviewed by the standards-setting

committee and judged in terms of technical justification and persuasiveness;

• Procedures are written out, meetings are open to the public, and meeting

participation is not limited in any significant way; and

• Appeal mechanisms are available within the organization to make sure

procedures are followed and all points of view treated appropriately.15

Although consensus and openness underlie the standards-setting activities in virtually

all industries, there apparently are two different "models" about what constitutes "openness." 

These different approaches are summarized in a recent Office of Technology Assessment

report:

 

 

15Hamilton, Robert W. "Prospects for the Nongovernmental Development of Regulatory

Standards," in American University Law Review, 455 Winter 1983, pp. 462-4. 
[ASTM] insists that true consensus requires the participation of all interested parties,

even if this requires subsidizing some groups. On the other hand, [ANSI] as well as

others argue that due process requires only that the process be open so all have an

opportunity to participate. They contend that willingness to pay is an essential

measure of interest in the process.16

This disagreement reveals friction within the U.S. standardization community. Although

virtually all of the major industry-specific standards-setting organizations in the U.S. are

members of ANSI, and follow basic procedural norms that ANSI has helped shape, ANSI's

role as leader of U.S. standardization efforts is self-designated and not unanimously accepted. 

ASTM, because its standardization program spans many industries and because it directly

develops standards (as opposed to ANSI's coordinative role), does not consider itself

subordinate to ANSI. And many groups which, like ASTM, belong to ANSI, do not forward all

or even many of their standards to ANSI for the latter's imprimatur as "American National

Standards." Even in the international arena, where ANSI derives much of its authority as the

lead U.S. representative to the International Standardization Organization (ISO), ASTM and

other U.S. standards-setters often work directly with their industry counterparts in other

countries. 

Committees do the standard-setting work in most organizations. Committees are

formed to draft the standard and develop a consensus. Drafts are circulated to interested

parties for review and comment. Subsequent drafts address the comments until a consensus

has been reached. The purpose of this iterative approach is similar to the purpose of the

Federal Administrative Procedure Act (APA), to ensure due process by giving parties that are

potentially affected by a rule or standard an opportunity to comment prior to implementation. 

However, the process differs from the Federal rulemaking procedures in that the standardsetting organizations attempt to reach a consensus position where a Federal agency may

proceed with a rule in the face of strong opposition.

The need for consensus in part derives from the method of implementation. Unless a

voluntary industry standard has been adopted or in some other way been incorporated in a

government regulation or procurement specification, firms are not legally compelled to follow

standards. However, as discussed below, in some cases, market forces may place such a

high premium on standards compliance that standards enjoy virtually 100 percent compliance.

The iterative, consensus-based nature of the standards-setting process can be very

time-consuming. It is unusual for standards to take less than a full year to develop from start

to finish, with much longer gestation periods common -- up to seven years in some extreme

cases. Overall, "the nongovernmental standards-development schedule approximates that of

an administrative agency establishing its own regulatory standard under the APA."17

International Standardization Activity

 

 

16U.S. Congress, Office of Technology Assessment: Global Standards: Building Blocks for

the Future. TCT-512. Washington, D.C.: U.S. Government Printing Office, March 1992, pp.

12-3.

 

17ibid., p. 464.
Increasingly, the focus of standardization activity is at the international level. As the

volume and complexity of world trade grows, the importance of harmonized product standards

-- and the cost of unharmonized standards -- also grows. Firms manufacturing products for

sale internationally face the daunting task of designing their product to meet all applicable,

and often conflicting, national standards for each intended market. The result is higher

product costs and reduced competitiveness. National standards, whether set voluntarily by

industry or by governments, can be a powerful form of non-tariff barrier. By contrast, uniform

or harmonized national standards provide a "level playing field" for domestic and imported

products, allowing all firms to compete on the basis of product performance.

The potential role of national standards in affecting the flow of international trade is

recognized in the General Agreement on Tariffs and Trade (GATT), which has as one of its

components the Agreement on Technical Barriers to Trade (also known as the "Standards

Code"). This code established the first international requirements concerning the procedures

used in developing and implementing standards.18

Harmonization of standards has been an important aspect of the "EC '92" European

integration process as well as the growing North-South trade dialogue. In Europe, for

example, a goal of harmonizing approximately 10,000 standards has been set, with the

objective of significantly reducing product manufacturing costs. Standardization negotiations

have been intensive, with each country jockeying to have their own national standard adopted

as the EC standard.

The acceleration of international standardization activities has been particularly

pronounced since the mid-1970s. One survey, for example, estimates that more international

standards were developed in the period 1977-87 than during the previous 30 years.19 A

number of international organizations are involved in these activities, notably including the

International Organization for Standardization (ISO), the International Electrotechnical

Commission (IEC), the Consultative Committee on International Telephony and Telegraphy of

the International Telecommunications Union (ITU), the European Committee for

Standardization (CEN), the Pacific Area Standards Congress (PASC), and the Pan American

Standards Commission (COPANT).

The role of the ISO in the globalization of standards is especially important. The work

of ISO, which is carried on by over 20,000 experts, from all parts of the world, serving on

approximately 2,300 technical groups, had resulted in over 6,000 international standards by

1987.20

 

 

18Breitenberg, Maureen A.: "The ABC's of Standards-Related Activities in the United

States." Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards,

May 1987, p. 2.

 

19Reddy, N. Mohan: "Voluntary Product Standards: Linking Technical Criteria to Marketing

Decisions." IEEE Transactions on Engineering Management, Vol. EM-34, No. 4, November

1987, p. 236.

 

20Breitenberg, Maureen A.: "The ABC's of Standards-Related Activities in the United

States." Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards,

May 1987, p. 2.
ANSI is the principal U.S. point of contact with ISO; this international role, in fact, is a

source of much of ANSI's domestic influence. Typically, ANSI is represented on ISO

committees by technical professionals drawn from its member, standard-setting organizations. 

AIAA, for example, represents U.S. interests on ISO Technical Committee 20 (TC 20), which

sets international standards for aircraft parts and equipment.

The U.S. serves as the secretariat for TC 20, a role which typically affords heightened

influence over the standardization process. Accordingly, the over 200 standards documents

produced by TC 20 embody a substantial amount of U.S. technology; this, in turn, typically

translates into commercial advantage for U.S. firms. TC 20 recently has been considering

space vehicle standardization proposals, with AIAA taking a lead U.S. role.21

Despite considerable American influence in TC 20 efforts, generally speaking U.S.

firms and standard-setting organizations are not as active in the international arena as are

their counterparts in Europe. One researcher estimated in 1987 that the U.S. had adopted

about 20 percent of formulated ISO standards, as compared to a 65 percent adoption rate for

our major trading rivals -- Britain, Germany, France, and Japan. This discrepancy implies

significant potential economic vulnerability.22

Certification -- the evaluation of products to determine compliance with standards --

becomes important in assessing the impact of conflicting national standards. At present, for

example, there are no U.S. labs qualified to test products to certify their conformance to

European standards. This requires that American products be shipped to one of several

approved European labs for this purpose.23

Relationship of Voluntary Industry Standards to Government Programs

A complex relationship exists between voluntary industry standards and government

agencies. As previously noted, the U.S. standardization system is more decentralized than

that of other developed countries, with considerably less involvement by national-level

government agencies.

In some cases, however, Federal agencies have been involved in catalyzing industry

standardization efforts. Agency representatives on the standard-setting committees of many

private standardization organizations is one important way that Federal influence is brought to

bear. More significantly, Federal agencies have in some cases played instrumental roles in

the standardization process. The War Industries Board, for example, provided a significant

impetus to standards-setting during World War I, with the objective of simplifying products to

conserve materials and rationalize production processes. In another example, Herbert Hoover

helped midwife product dimension standards in the lumber industry. As in the lumber

 

 

21French, James E.: "Standards Affect the Pace of International Business." Aerospace

America, October 1991, pp. 52-4.

 

22Reddy, N. Mohan: "Voluntary Product Standards: Linking Technical Criteria to Marketing

Decisions." IEEE Transactions on Engineering Management, Vol. EM-34, No. 4, November

1987, p. 236.

 

23Los Angeles Times, June 22, 1991, Section D, p. 2.
example, government involvement of this type has usually come in industries characterized by

low concentration among both producers and consumers, making cooperation on standards

difficult for firms to initiate on their own.24

More recently, the Federal government's role in encouraging or directly fostering

industry standardization activities has been led by the National Institute of Standards and

Technology (NIST), formerly the National Bureau of Standards. NIST administers the

Department of Commerce's Voluntary Product Standards (VPS) program. Under the auspices

of this program, NIST staff serve as the secretariat for the development of voluntary standards

for selected industry products, including softwood lumber, construction and industrial plywood,

and glass bottles for soft drinks. The cost of these activities is paid for by proponent trade

associations or other groups. NIST also serves as an appeal mechanism for manufacturers

contesting the decisions of an important private standards setter, Underwriters Laboratory

(UL). UL is frequently asked by manufacturers to test products for conformance to UL-set

standards; by agreement with UL and such manufacturers, NIST considers any protests or

appeals filed by manufacturers whose products fail UL tests.

NIST operates the National Center for Standards and Certification Information, which

provides information on U.S. and international standardization programs. NIST is a member

of the International Organization for Standardization Network (ISONET), providing access to

an extensive database on foreign national standards. NIST also maintains an extensive

collection of reference materials on U.S. voluntary standards and government procurement

specifications.

Currently, the relationship between government agencies and industry standardization

principally involves government procurement procedures and regulatory programs. In the

procurement arena, government agencies at all levels find themselves in the same position as

individual and corporate consumers -- relying on industry standards in their purchasing

decisions. A 1970 General Services Administration report found more than 4,000 private

industry standards referenced in Federal procurement documents.25 The organizations

profiled in the Appendix below provide numerous examples of private standards referenced or

otherwise incorporated into Department of Defense (DoD) procurement specifications. For

example, approximately 500 Aerospace Industry Association standards have been

incorporated by DoD in its procurement program. In recent years, DoD has put increasing

emphasis on the use of existing industry standards, wherever possible seeking to increase

quality and cost-effectiveness in its procurement programs.26 The extent of government

reliance on private standards is probably even greater at the state and local level, where even

fewer resources exist to permit an independent evaluation of competing products.

 

 

24Hemenway, David. Industrywide Voluntary Product Standards. Cambridge: Ballinger,

1975, p. 22. 

 

25Federal Trade Commission, Bureau of Consumer Protection: Standards and Certification:

Final Staff Report. Washington, D.C., April 1983, pp. 28-9.

 

26DoD Directive 4120.20, "Development and Use of Non-Governmental Specifications and

Standards," March 28, 1988.
In the regulatory sphere, government agencies often in effect convert "voluntary"

private standards into mandated requirements through incorporation or adoption by reference

of those standards in public regulations. A study performed for the Administrative Conference

of the United States in 1978 documented that a majority of the then-applicable Federal, state,

and local regulatory standards and codes were derived from preexisting voluntary codes,

rather than original governmental action.27

Examples of Federal incorporation or adoption of voluntary standards abound. By

1978, for instance, the Occupational Health and Safety Administration (OSHA) had adopted or

referenced over 265 ANSI-approved "National Standards" in its worker safety regulations.28

Technical standards developed by SAE committees have been used by the Federal Aviation

Administration (FAA) and the National Highway Traffic Safety Administration (NHTSA). 

Standards developed by ASME have been incorporated into regulations issued by DOT, EPA,

OSHA, and the Nuclear Regulatory Commission (NRC).

Federal agency involvement in the development of voluntary industry standards, as

well as their use of the products of voluntary standardization activities, is guided by Circular A119, originally issued by the Office of Management and Budget in 1980. This document

encourages Federal agency support of, and participation in, voluntary standardization activities

when the voluntary organizations involved follow basic due process procedures.

One Federal agency, the Consumer Product Safety Commission (CPSC), has built the

entire structure of its regulatory program around voluntary standards. In its early days, the

CPSC often deferred promulgating mandatory product standards in cases where industry took

preemptive standardization action; the threat of mandatory standards became a significant

impetus to such voluntary efforts. The 1981 amendments to the Consumer Product Safety

Act articulated a statutory preference for such standards by requiring the CPSC, before

implementing a mandatory standard, to find that any proposals to develop alternative voluntary

standards would not adequately reduce the risk of injury from a particular class of products.29

This reliance of the CPSC on voluntary standards has led to close cooperation between the

agency and various standardization groups. The CPSC has provided financial assistance to

some private standards-setters and has suggested various procedural reforms, including

increased representation of consumer interests, to improve the quality of standards

established in the private sector.

When a Federal agency incorporates a standard or code by reference, it must cite a

particular edition or version. If the code subsequently is updated by the standard-setting

organization, the update is not automatically included in the Federal rule; the agency must go

through notice-and-comment rulemaking to update the reference accordingly. This process

must be completed before a revised standard can be adopted as a Federal regulation. Such

 

 

27Study cited in Hamilton, Robert W. "Prospects for the Nongovernmental Development of

Regulatory Standards," in American University Law Review, 455 W, 1983, p. 459.

 

28ibid., p. 28.

 

29Klayman, Elliot. "Standard Setting Under the Consumer Product Safety Amendments of

1981 -- A Shift in Regulatory Philosophy," in 51 George Washington Law Review 96,

November 1982, pp. 100-1.
changes ordinarily are not controversial, given the consensus-based approach employed in

the voluntary standards-setting process.

At the state and local level, reliance by public regulatory agencies on private standards

is even greater. The "National Electric Code" developed by the National Fire Protection

Association, and the "Boiler and Pressure Vessel Code" developed by ASME, both have been

widely adopted by states and localities. Observing this heavy reliance of all levels of

government on ASTM-set standards, one Federal Court went so far as to call ASTM "...an

essential arm, or branch, of government...."30

Economic Aspects of Standards

The potentially powerful economic impact of standards has been noted previously. It is

these economic effects that provide the incentive for standardization activities in the first

instance. The promise of lower production costs, increased product compatibility, and

reduced consumer transaction costs has proven very attractive in many industries. The

precedential examples of the role of standards in the growth of numerous industries,

particularly in the transportation sector, are frequently cited. At the same time, critics of

standardization also focus most of their concern on potential negative economic impacts,

including product cost increases, excessively high (and, thus, expensive) performance

requirements, barriers to market entry, and reduced consumer choice.

Sorting out the real economic effects of standards can only be done on a case-by-case

basis, taking many factors unique to each product and its market into account. As a general

proposition, however, it is clear that standards, once they are promulgated, can have a

powerful effect on marketplace behavior. As an FTC staff report noted, "...where reliance on a

particular standard or seal is significant, noncompliance becomes so competitively

disadvantageous from the point of view of producers that voluntary standards become

mandatory."31

The process by which particular standards are set provides an interesting opportunity

to observe variations of microeconomic behavior on the part of firms. As previously noted,

many firms invest considerable amounts of money and staff time in aggressive participation on

standards-setting committees with the objective of legislating in their technology and, thus,

gaining a competitive advantage. On the other hand, standards are a good example of a "free

good." All firms in an industry can employ a standard, whether or not they helped create the

standard; therefore, at least for small firms or firms that do not expect to gain a competitive

edge, there is little economic incentive to participate in the standard-setting process.

Another interesting economic aspect of standards concerns the degree of residual

variation and differentiation they permit producers. Standards can be seen as the intersection

of the common knowledge of producers and the common needs or performance requirements

of consumers. In this view, standards in effect define a "core" product. Individual standards

will permit greater or lesser degrees of product variation, as producers seek to comply with a

 

 

30U.S. v. Johns-Manville, et al. (1964), quoted in ibid., pp. 10-11.

 

31Federal Trade Commission, Bureau of Consumer Protection: Standards and Certification:

Final Staff Report. Washington, D.C., April 1983, p. 34
standard (to obtain the marketing benefits compliance provides), while at the same time

attempting to differentiate their product from competitors', which also comply with the

standard. They often are able to do this, since few standards satisfy every requirement of all

consumers of a product. In participating in the standard-setting process, firms must decide

what technical information they are willing to share, and what they will maintain as proprietary.

3. COMPARISON OF SELECTED INDUSTRY STANDARDIZATION PROGRAMS

Introduction

This section provides a summary comparison of thirteen of the fourteen standardssetting organizations researched by OCST in this project. (ANSI is not included because, as

a standards-coordinating body, it is different in kind from the other groups, which actually set

standards themselves.) The points of comparison include the procedural characteristics of

each standardization program, the nature and scope of the organizations' programs, key

factors in the evolution of their standards, the degree of their interaction with government

agencies, and other aspects of standardization discussed in Section 2. The Appendix to this

report provides a profile of each of the fourteen standards organizations, and can be

consulted for more information about any specific program. Key points from these profiles are

summarized in Exhibit 1 at the end of this section.

Common Aspects of Programs

The most striking commonality among the programs researched in this project

concerns the process used to develop and implement standards. The consensus-oriented,

broadly representative approach promoted by ANSI clearly provides the process paradigm for

voluntary standardization organizations throughout U.S. industry. Even the one organization

that does not belong to ANSI, the Truck Trailers Manufacturers Association (TTMA),

subscribes to the ANSI methodology. In part this is due to the protection that a broad

consensus approach can provide against antitrust and other legal challenges.

Reflecting the consensus nature of industry standards, standards-setters substantially

rely on voluntary compliance. In the case of standards widely recognized by consumers,

market forces powerfully reinforce companies' voluntary compliance instincts. In other cases,

compliance becomes mandatory as initially voluntary standards become adopted by

government agencies in either regulations or procurement specifications.

There is also a great degree of similarity in the origins of these standardization

programs. In most cases, industry leaders begin focusing on standards in an effort to

promote the growth of an expanding and diversifying technology. The need for uniformity and

interoperability among products produced by different companies is apprehended quickly when

the lack of such interoperability becomes a significant constraint on industry growth. The

development of a common railroad track gauge has already been cited as an example of this

phenomenon.

Safety risks can also retard industrial growth. Three of the organizations researched

by OCST -- UL, the American Society of Mechanical Engineers (ASME), and the American

Bureau of Shipping (ABS) -- all owe their origins (or, in the case of ASME, the origins of its
standards program) to a desire on the part of the insurance underwriting industry to manage

risks effectively. UL was formed in 1894 by a group of insurers to reduce deaths, injuries, and

damages due to faulty consumer products. Widespread and deadly accidents involving poorly

designed and operated industrial boilers led states and insurance companies in the late 1880s

to develop their own boiler codes. ASME became involved in order to rationalize and

standardize these proliferating requirements. ABS's standards program was driven by

maritime insurers' desire to reduce shipping losses and resulting insurance claims.

The need for consistency in product quality also has been a common motivator of

standardization efforts. This concern may be focused on building the confidence of

consumers in an industry's products, or on the quality of industrial goods used in the product

manufacturing process. For example, the early concern among engineers about lack of

uniformity in the quality of railroad components, and the threat thereby posed to the growth of

the railroad industry, was an important stimulant to the creation of the American Society for

Testing and Materials (ASTM). Similarly, improving the quality of fasteners was a major

reason the Aerospace Industries Association (AIA) branched into standards-setting.

The need for interchangeability is an especially strong impetus for standardization

programs in high-technology fields. The more complex the industrial system, the greater the

number and complexity of parts, and the greater the need for parts manufactured by different

companies to be able to function together. Chemical manufacturing and petroleum refining

processes, for example, can involve huge numbers of specific chemical processes and very

complex and idiosyncratic piping and instrumentation arrangements. Transportation vehicles

such as automobiles and airplanes involve thousands, even tens of thousands of different

parts. Interoperability or interchangeability among the parts made by different suppliers

provides important planning and cost advantages to vehicle assemblers. These concerns

were very influential in the origins of the standardization efforts of both AIA and the Society of

Automotive Engineers (SAE).

Once begun, standards programs evolve largely in response to technological

developments and changes in public or consumer concerns. Both the number and focus of

standards change as technological systems become more complex. As the electronics

industry has grown and diversified, for example, so have the standards set by such

organizations as the Electronics Industry Association (EIA) and the Institute of Electronic and

Electrical Engineers (IEEE). New technical achievements such as the invention of the

transistor, the microchip, and fiber optics require new standardization activity.

Heightened public concern about the safety of products has had a powerful impact on

the evolution of standards activity. This is particularly evident in the transportation sector,

since the growth of the automotive and commercial aviation industries has been highly

dependent on consumer confidence in vehicle safety. The scope of two standardization

bodies, ASTM and Underwriters Laboratories (UL), especially have been affected by the

evolution of public concerns. ASTM has increased its activity related to energy resources,

environmental testing, and waste management as public interest in these issues has grown. 

Increased consumer and government concern about the safety of consumer products has led

to a significant expansion in the scope of UL's standardization and testing programs.
Significant Differences Among Programs

Although the overall similarities among the standards programs researched are more

significant than the differences, there is nonetheless a great degree of variety along a number

of important dimensions. These differences concern the nature of the standards-setting

organizations themselves, the breadth and extent of their programs, the extent of their

influence within their industry, the degree of involvement with both ANSI and government

agencies, and their level of international involvement.

While all but one of these groups (TTMA) are ANSI members, and all employ the ANSI

standards-development process, they vary in the extent to which they submit their standards

for ANSI review and approval as American National Standards. On the one hand, ASME

submits many of its standards to ANSI for its approval; on the other, ABS and AIA -- although

ANSI members -- do not submit their standards. Other organizations typically avoid formal

ANSI review (which can add several years to the standards approval process) unless they are

particularly anxious to have a given standard adopted internationally. In such cases, ANSI's

role as U.S. representative to the major international standards bodies gives it important

leverage.

Another obvious difference concerns the underlying nature and purpose of each

organization and the role of standards setting within their mission. Many of the organizations

researched are industry or trade associations (e.g., AIA, the American Petroleum Institute

(API), and EIA), while others are professional societies (SAE, the American Institute of

Aeronautics and Astronautics (AIAA)). In each of these cases, standards development is only

a part of what the organization does. Several other of the organizations (e.g., UL, ASTM, and

ABS) are devoted largely or entirely to standards-related activities. Even among trade

associations and professional societies there is variation in the importance of standards

activity relative to the other parts of their mission. Standards-setting is a small part of AIAA's

overall mission as compared to SAE's.

Other dimensions useful for comparison purposes are the absolute size and breadth of

each organization's standards program. Although it was not possible to obtain budget and

staff figures for every program examined, a rough comparison is possible. On one extreme is

ASTM, with a standards program budget of over $19 million in 1990. AIAA, by contrast,

devotes only $300,000 of a very large overall budget to its relatively nascent standards

program. The large size of ASTM's budget reflects the very broad scope of its activity; ASTM

sets standards in wide range of industries and disciplines. By contrast, both AIAA and AIA

focus their efforts relatively narrowly even within their industry. AIAA has chosen to

emphasize space systems standards, while AIA concentrates on aviation fastener technology. 

SAE sets an aggressive entrepreneurial example. Originally known as the Society of

Automotive Engineers, the organization now calls itself simply SAE as it has branched into

other industries, most notably its extensive aviation and aerospace standardization activity.

Standards-setting organizations vary in the extent to which they dominate their

industries. Standardization in the motor vehicle industry is dominated by SAE, with the TTMA

playing a role only with respect to truck trailers. The ABS is likewise dominant in the maritime

industry. By contrast, the aviation/aerospace, petrochemical, and electronics industries all

have several standards-setting groups which play significant roles.
All of the organizations profiled in the Appendix have working relationships with

government agencies at various levels. However, there are important differences in the

degree and nature of such interactions. These variations concern, among other things, the

extent to which their standards have been adopted by government agencies as regulatory

standards or procurement specifications, the levels of government at which such incorporation

predominantly occurs, and the extent of government representation in the standards

development process. Largely due to the relative newness of its program, AIAA has only had

three of its standards adopted or referenced by a government agency, in this case DoD

procurement specifications. By contrast, AIA -- which has been in the standards business for

approximately 70 years -- has had over 500 of its standards adopted by DoD for procurement

purposes, and has a large number of its standards adopted or incorporated into regulations by

the Federal Aviation Administration. ASTM, API, ASME, IEEE, and UL all have experienced a

great degree of influence over the regulatory and procurement activities of government

agencies at all levels. UL's electrical product standards and ASME's boiler code both have

been extensively adopted at the state and local level into building codes and standards of

practice.

ABS deserves special mention in any discussion of the interrelationship of voluntary

standards and government agencies. The relationship of ABS and the U.S. Coast Guard

(USCG) is more integral than that enjoyed by any of the other organizations profiled in the

Appendix with any other government agency. ABS is recognized in the U.S. code as a

government agency for purposes of ship classification. Pursuant to a Memorandum of

Understanding, ABS personnel in effect serve as representatives of the USCG in reviewing

and inspecting U.S. flag vessels. ABS serves in similar capacities for other Federal agencies,

notably including the Department of Agriculture. Reflecting this degree of interaction, ABS

governing bodies include significant Federal representation.

Although ANSI is the official U.S. representative to the ISO, IEC, and other

international standards-setting organizations, it is the ANSI membership organizations which

carry out the technical aspects of this work. The groups examined in this report vary in the

extent to which they are involved in these and other international activities. For example,

while ASTM maintains its ANSI membership in order to preserve international access, it

focuses by far most of its energies domestically. AIA and AIAA, on the other hand, are very

involved representing ANSI on ISO and IEC committees. TTMA, because it is not an ANSI

member, maintains only an informal relationship to ISO. ASME has become quite aggressive

internationally, seeking to establish chapters in other countries. Independent of their active

involvement in ANSI, ASME also has developed cooperative agreements with counterpart

organizations in other countries. Once again, however, ABS provides the most notable

example of internationalism: Paralleling many of its responsibilities on behalf of the U.S.

government, ABS has been authorized by more than 90 governments to administer provisions

of international maritime conventions for them under the auspices of the International Maritime

Organization. While other of the organizations surveyed have had their standards adopted by

other countries, none enjoys ABS's degree of extraterritorial authority.





VOLUNTARY INDUSTRY STANDARDS

AND THEIR RELATIONSHIP TO GOVERNMENT PROGRAMS

RESEARCH CONTACTS

• American National Standards Institute (ANSI)

Marilyn Hernandez (212) 642-4915

• American Society for Testing and Materials (ASTM)

Laurel O'Brien (215) 299-5400

• American Institute of Aeronautics and Astronautics (AIAA)

James French (202) 646-7439

• Aerospace Industries Association (AIA)

Lisa Balay (202) 371-8464

Don Calvert (202) 371-8462

• Society of Automotive Engineers (SAE), Air and Space Division

Sandy Dillner (412) 776-4841

Bill Wagner

• Society of Automotive Engineers (SAE), Land and Sea Division

Aleita Wilson (412) 772-7158

• Truck Trailer Manufacturers Association (TTMA)

Richard Bowling (703) 549-3010

• American Petroleum Institute (API)

Lisa Hofmann (202) 682-8147

Jim Creer (214) 748-3842

• American Society of Mechanical Engineers (ASME)

David Soukup (212) 705-7397

Karen Ciciora (212) 605-8738

• Manufacturers Standardization Society of the Valves and Fittings Industry (MSS)

Olen Thornton (703) 281-6613

• Electronics Industry Association (EIA)

Cecilia Fleming (202) 457-4900
RESEARCH CONTACTS (Continued)

• Institute of Electrical and Electronics Engineers (IEEE)

Terry deCourcelle (908) 562-3807

Michelle Curtis (908) 562-3823

• Underwriters Laboratories (UL)

Otilie Moll (516) 271-6200 x550

• American Bureau of Shipping (ABS)

Tom Tucker (212) 839-5000

Steve Arnston

Glenn McGuill
VOLUNTARY INDUSTRY STANDARDS

AND THEIR RELATIONSHIP TO GOVERNMENT PROGRAMS

BIBLIOGRAPHY OF WRITTEN SOURCES

American Institute of Aeronautics and Astronautics. The Future of Aerospace Standards. 

Washington, D.C., 1990.

American Bureau of Shipping. History of the American Bureau of Shipping. New York, N.Y.,

1991.

American National Standards Institute. Procedures for the Development and Coordination of

American National Standards. New York, N.Y., 1987.

American Petroleum Institute. Report to the Membership. Washington, D.C., 1991.

American Society of Mechanical Engineers. The Why and How of Codes and Standards. 

New York, N.Y., 1983.

American Society for Testing and Materials. 1990 Annual Report. Philadelphia, PA, 1990.

Breitenberg, Maureen A. "The ABC's of Standards-Related Activities in the United States." 

Washington, D.C.: U.S. Department of Commerce, National Bureau of Standards, May 1987.

Burgess, John. "Competing in A Diverse Market: U.S. Firms Seek Unity on Product Standards

in Europe," in Washington Post, December 2, 1991, p. A6, p. A1.

Electronics Industry Association. Manual of Organization and Procedure. Washington, D.C.,

1989.

Federal Trade Commission, Bureau of Consumer Protection. Standards and Certification:

Final Staff Report. Washington, D.C., April 1983.

French, James E. "Standards Affect the Pace of International Business," in Aerospace

America, October 1991, pp. 52-4.

Greenblatt, Sandra P. "American Society of Mechanical Engineers, Inc. V. Hydrolevel Corp.:

Vicarious Liability Equalizes the Treatment of Business Enterprises and Nonprofit Associations

Under Antitrust Laws," in 38 University of Miami Law Review 741, July 1984, pp. 741-68.

Hamilton, Robert W. "Prospects for the Nongovernmental Development of Regulatory

Standards," in American University Law Review, 455 Winter 1983, pp. 455-69.

Hemenway, David. Industrywide Voluntary Product Standards. Cambridge, MA: Ballinger,

1975.

Institute of Electrical and Electronic Engineers. A Guide to IEEE Standards Development. 

New York, N.Y., 1989.
BIBLIOGRAPHY OF WRITTEN SOURCES (Continued)

Klayman, Elliot. "Standard Setting Under the Consumer Product Safety Amendments of 1981

-- A Shift in Regulatory Philosophy," in 51 George Washington Law Review 96, November

1982, pp. 96-112.

Los Angeles Times, June 22, 1991, Section D, p. 2.

Martin, Albro. Railroads Triumphant. Oxford: Oxford University Press, 1992.

Manufacturers Standardization Society. Information Brochure. Vienna, VA, 1992.

Pearse, James N. "U.S. Participation in International Standards Activities: ANSI Testimony

Presented to the National Institute of Standards and Technology of the U.S. Department of

Commerce," in Standards Engineering, May/June 1990, p. N/A.

Putnam, Hayes and Bartlett, Inc. Impact of Private Voluntary Standards on Industrial

Innovation. Volume I: Final Report. Prepared for National Bureau of Standards, Washington,

D.C., January 1983.

Reddy, N. Mohan. "Voluntary Product Standards: Linking Technical Criteria to Marketing

Decisions," in IEEE Transactions on Engineering Management, Vol. EM-34, No. 4, November

1987, p. 236-43.

Reddy, N. Mohan and Cort, Stanton G. "Industrywide Technical Product Standards." in R & D

Management, 19, 1, 1989, pp. 13-25.

Rosenberg, Ernest S. "Standards and Industry Self-Regulation," in California Management

Review, Fall 1976, pp. 79-90.

Society of Automotive Engineers. Cooperative Engineering Program. Warrendale, PA, 1988.

Stremba, Henry J. "The Home That Standards Built," in ASTM Standardization News, June

1988, p. 56.

Sullivan, Charles D. Standards and Standardization: Basic Principles and Applications. New

York: Marcel Dekker, Inc., 1983.

Swankin, David A.: How Due Process in the Development of Voluntary Standards Can

Reduce the Risk of Anti-trust Liability. Washington, D.C.: National Institute of Standards and

Technology, 1990.

Truck Trailers Manufacturers Association. TTMA Publication Brochure. Alexandria, VA, 1992.

Underwriters Laboratories. Testing for Public Safety. Northbrook, IL, 1990.

U.S. Congress, Office of Technology Assessment: Global Standards: Building Blocks for the

Future. TCT-512. Washington, D.C.: U.S. Government Printing Office, March 1992.
BIBLIOGRAPHY OF WRITTEN SOURCES (Continued)

U.S. Department of Commerce, National Institute of Standards and Technology. Research.

Services. Facilities. Washington, D.C., date N/A.

U.S. Department of Defense. DoD Directive 4120.20, "Development and Use of NonGovernmental Specifications and Standards," March 28, 1988.

U.S. Office of Management and Budget, "Circular No. A-119 Revised," Transmittal

Memorandum No. 1, October 26, 1982.
APPENDIX

ANALYSIS OF SPECIFIC INDUSTRY STANDARDS PROGRAMS

This appendix provides a summary description of specific standard-setting and

standard-coordinating organizations in the aerospace, automotive, petrochemical, consumer

electronics, and maritime industries. It includes a discussion of the genesis of the standards

programs, and delineates key factors that have led to standardization in that particular

industry. This analysis also examines the procedural mechanisms that control standards

development, shows the relationship of standards organizations to government agencies,

discusses the legal aspects of standards formulation, and examines each standards program

in its international context. This review is based on discussions and data collected from the

organizations listed below:

• American National Standards Institute (ANSI)

• American Society for Testing and Materials (ASTM)

• Aerospace Industries Association (AIA)

• American Institute of Aeronautics and Astronautics (AIAA)

• Society of Automotive Engineers (SAE), Air and Space Division

• Society of Automotive Engineers (SAE), Land and Sea Division

• Truck Trailer Manufacturers Association (TTMA)

• American Petroleum Institute (API)

• American Society of Mechanical Engineers (ASME)

• Manufacturers Standardization Society of the Valves and Fittings Industry

(MSS)

• Electronics Industry Association (EIA)

• Institute of Electrical and Electronics Engineers (IEEE)

• Underwriters Laboratories (UL)

• American Bureau of Shipping (ABS)

The appendix begins with an examination of the American National Standards Institute (ANSI),

which serves as an umbrella group that oversees the standard-setting work of other technical

and trade organizations. ANSI differs from the other standards organizations reviewed here,

in that it does not concern itself with specific lines of research or the technical content of

standards it approves. Instead, it devotes its efforts to administration of the overall

development process.

AMERICAN NATIONAL STANDARDS INSTITUTE (ANSI)

ANSI is a privately operated nonprofit organization that coordinates standard-setting

work in the United States. ANSI provides the framework and process through which

standards developers may conduct research and validation, but does not itself engage in the

technical formulation of codes. ANSI accredits qualified organizations to develop standards

using methods that are intended to ensure due process and consensus among interested

parties. Once approved by ANSI, standards become part of the American National Standards,

the body of code promulgated through ANSI's voluntary-consensus system. In 1990, over

1,300 American National Standards were approved, with ANSI standards program
expenditures of $2 million for national activities and $5 million for international efforts. ANSI

presently consists of approximately 1400 institutional members representing industry,

government, labor, as well as technical and trade organizations. ANSI funds itself through

membership fees and the sale of standards documents.

Genesis of Program

ANSI was established in 1918, a time of expanding industrialization, by a group of

engineering societies (including ASME, ASCE, and IEEE) interested in establishing an

institutional apparatus for drafting standards. Originally organized as the American

Engineering Standards Committee, the group set out to promote and facilitate the use of

technical standards by industry. In 1928 the committee was reorganized as the American

Standards Society, and opened its membership to include corporations, trade associations,

and government agencies. Up until the 1960s ANSI actually devised standards itself, but by

1969 the emphasis had become the coordination of other organizations, standards

development process, and the organization was rechartered into its present form.

Evolution of Program

A number of elements have played significant roles in the evolution of ANSI as it

stands today. Early on, it was recognized by the technical professions that standardization

would be vital to commerce and manufacturing, as well as the safety and welfare of the

public. The primary concern was to promote standardization without stemming innovation. 

From the outset, the breadth of work conducted by ANSI members placed an emphasis on the

administrative responsibilities of the organization. Coordinating the standards research of

such diverse groups as the electrical engineering and marine engineering communities

underscored the importance of developing an approval system. In the late 1920s, when ANSI

membership was opened to include technology users and industry, it became an explicit

organizational goal to develop standards that would not be unduly burdensome to any one

business. Until the 1960s ANSI played the dual role of standards developer and

administrator, with ANSI staff conducting technical studies and performing management

duties. With its growing and increasingly sophisticated membership, ANSI realized that

technical expertise resided with its constituent organizations and withdrew from standards

creation. ANSI then devoted itself to developing techniques for promoting and administering a

consensual and voluntary standards regime.

Procedural Mechanisms

As a coordinating organization, ANSI provides a process through which standards are

developed. At the center of the ANSI process is the concept of consensus. Proposed

standards are comprehensively reviewed by parties that have expertise and interest in the

field. ANSI provides a forum through which differences among the membership are resolved

and comments are incorporated. ANSI initiates its process upon request from a member

organization conducting work in specific standardization issues. Standards developers

seeking ANSI approval must be accredited through ANSI as meeting the requirements of the

consensus process. A standards developer may be accredited to use one or more of the

following methods to establish consensus:

• The Accredited Standards Committee consists of individuals representing a

cross-section of industry concerned with similar standards. All committees
have a Secretariat or other overseeing body, which is responsible for

coordination within the committee. Members of the committee write and vote

on a standard, which is then sent to ANSI for approval.

• The Accredited Organization is a multi-member group with standards

procedures established and approved internally. These organizations have

their own committees, which are created to address specific proposals for new

standards and are open to affected members of the industry. The committee

devises a standard, and submits it for internal approval, after which it becomes

an organizational standard (such as an SAE standard). The organization then

sends the standard to ANSI for review, publication, and approval, at which point

it becomes an ANSI standard (such as an ANSI/SAE standard). Standards

which are approved in this manner are known as American National Standards.

• The Accredited Sponsor for Canvass method is used for smaller scale efforts. 

A person or group (producers, users, general public) concerned about an issue

can seek approval to develop a standard. The person or group becomes an

accredited ANSI sponsor and must then develop a canvass list of those parties

(organizations, committees, other standards developers, individuals, etc.)

affected by the standard and interested in participating in its development. In a

process with many iterations, the sponsor writes the standard and sends it to

members of the canvass list who review the standard and return it to the

sponsor, which incorporates the comments and sends it out again. When a

final draft has been approved by the participants, the sponsor sends it to ANSI

for approval and publication.

Once a standard has been approved by the developing organization, ANSI must give

its approval in order for the standard to become an "American National Standard." Upon

receipt of the standard, ANSI publishes an announcement about the standard in its magazine

Standard Action. ANSI ensures that all comments received from that announcement, as well

as comments received by the developing organization, have been properly addressed. In

granting approval for a standard, ANSI does not look at the standard itself, but rather

examines the process through which it was developed. Development of a standard may take

from two to four years.

As part of its coordinating responsibilities, ANSI helps standards developers avoid the

problem of drafting standards that conflict with others already approved. It also endeavors to

preclude duplication of effort by separate groups working in the same discipline. The

objective of this management activity is to increase efficiency in the overall standard-setting

process. Much of this coordination work is done by ANSI's Executive Standards Council.

Reporting directly to the Executive Standards Council are the Standards Boards, which

have primary responsibility for standards activities within ANSI for given industrial sectors. 

Among their functions, Standards Boards monitor the work of standards developers, review

and assess applications for new standards work, coordinate research to avoid duplication of

effort, accredit new standards developers, and provide supervisory support to ensure that all

standards work is consistent with ANSI practice. Members of Standards Boards include

standards users such as companies and regulatory agencies, academic organizations,

standard developers, and other groups that have demonstrated interests in a standards topic. 
Standards Boards, designed to represent a "balance of interests," are the mechanism through

which conflicts are resolved.

Relationship of Program to Government

Government involvement with ANSI has become extensive over the years as

standards have become increasingly important to public safety and commerce. Sixteen

Federal agencies or departments presently are members of ANSI, including the Departments

of Defense, Energy, and Housing and Urban Development; the National Aeronautics and

Space Administration; and the National Institute of Standards and Technology. Government

representatives serve on ANSI boards such as the Government Member Council and the

Board of Directors. In addition, Government/ANSI coordinating committees have been

established to provide a forum for discussing governmental standards activities and interests. 

The Occupational Safety and Health Administration and the Consumer Product Safety

Commission have been especially involved in this area.

Government agencies will often request ANSI to work on specific standards issues. 

ANSI reviews such requests to determine if the request is cogent and if the topic already has

been addressed. If ANSI determines that work on the topic is needed, ANSI-accredited

technical committees commence with the research.

ANSI-approved standards have been adopted or referenced by government agencies

in the areas of safety, health, public welfare, transportation, communications, procurement,

and cost-reduction measures. An increasing number of ANSI-sanctioned standards are being

included in the Department of Defense Index of Standards and Specifications (DoDISS).

Legal Aspects

The ANSI system of standards development has been devised with the intent of

minimizing the possibility of antitrust litigation against ANSI, it's constituent members, and

standards developed through ANSI's approved process. Since ANSI accredits its standardsetting membership, it assumes legal responsibility for litigation concerning those standards

which have been approved as American National Standards. In turn, in order to receive and

retain ANSI accreditation, a member organization assumes certain responsibilities, including

accurate recordkeeping of its standards activities, conformance to ANSI-approved standards

review and response procedures, provision of active support and maintenance of standards

once developed, and review of standards for technical accuracy at least once every five years. 

ANSI provisions stipulate that failure to comply with any of these requirements is cause for

revocation of ANSI endorsement. The comprehensive nature of the ANSI consensus process

is illustrated by the fact that ANSI-sanctioned standards have rarely been challenged in court.
International Aspects

ANSI's involvement in the international standards community occurs primarily through

its membership in two non-treaty organizations, the International Standardization Organization

(ISO) and the International Electrotechnical Commission (IEC). Through its United States

National Committee (USNC), ANSI is the main U.S. representative to these organizations. 

ANSI delegates in the ISO and IEC include technical and administrative personnel, drawn

largely from ANSI-member organizations, who represent U.S. interests in dealing both with

content and procedural standards issues. ANSI's influence in U.S. standards community

derives largely from its central role in international standards activities.

ISO was founded in 1946 as a federation of standards organizations from 86 countries. 

ANSI was one of the founding members, and has been active in the ISO efforts to develop,

coordinate, and promote international standards. There have been 7,400 ISO standards

published to date in all fields excluding electrical and electronic engineering.

IEC was formed in 1906 and develops international standards relating to electrical and

electronics engineering. There are 44 national committees within IEC, and 32 technical

committees and subcommittees. ANSI participates in some manner in over 95 percent of the

technical committees of the ISO and IEC.

In addition to these two primary standards bodies, ANSI participates in several other

standards organizations:

• The European Committee for Standardization (CEN) and the European

Committee for Electrotechnical Standardization (CENELEC) are the European

private sector organizations that have been charged by the European

Commission with the task of standards development within the European

Community (EC).

• The European Organization for Testing and Certification (EOTC) is the private

sector organization responsible for issues relating to conformity assessment.

• The Pacific Area Standards Congress (PASC) offers non-European Community

nations a forum to enhance their ability to participate in ISO/IEC activities

relevant to Europe. ANSI is an active member in PASC.

• The Pan American Standards Commission (COPANT) coordinates and

promotes South American standards. ANSI has just renewed membership in

COPANT.

• ANSI also maintains a cooperative relationship with the European

Telecommunications Standards Institute (ETSI).

• ANSI has signed a cooperative agreement with the Chinese Association for

Standardization of the People's Republic of China, in the interest of exchanging

official publications and promoting frequent technical consultations.
• The ANSI federation has entered into agreement with the Japanese Industrial

Standards Committee (JISC) and the Japanese Standards Association (JSA), to

encourage access to standards, testing, and certification processes.

• ANSI currently has strong ties to the Canadian Standard Association (CSA) and

is exploring similar relationships with Mexican standards organizations.

In order to establish closer ties to the EC and to participate more fully in European

standardization activities, ANSI in 1989 launched its EC'92 program; a key element of which

was the establishment of an ANSI office in Brussels. This office publishes ANSI Global

Standardization Reports, which provide U.S.industry with the most up-to-date information on

European standards, testing, and certification. A major effort of ANSI has been to strongly

encourage U.S. industry to fully cooperate in the process of international standards

development.

U.S. companies conducting business in the international arena are facing issues of

standardization on various fronts. Procedural as well as technical problems will need to be

addressed. For example, sterilization of health care products has emerged as an area of

technology in need of international standards. An ISO Technical Committee (ISO/TC-198) has

been formed to deal with this issue, and representation of U.S. interests are being coordinated

through ANSI. In terms of procedural issues, ANSI continues to promote its standardsdevelopment methodology on the international stage through publications, seminars, and

conferences.

STANDARDS-SETTING ORGANIZATIONS

American Society for Testing and Materials (ASTM)

Genesis of Program

The American Society for Testing and Materials (ASTM) is a nonprofit organization with

the objective of serving as a management system for the development of standards in a wide

variety of industries and disciplines. ASTM members work voluntarily to conduct research and

prepare standards under the auspices of the organization. ASTM is a founding member of

ANSI and promotes the consensus method of setting standards. As a standards-setting

organization, ASTM directly guides research and takes responsibility for the technical aspects

of its standards, whereas ANSI provides only the standards approval process for independent

standard-writing organizations. ASTM has membership of 33,000 individuals and

organizations in academia, business, and government. Close to 85 percent of ASTM's

funding comes from the sale of publications, primarily including standards documents. The

balance comes from annual administrative fees levied against members. In 1990, ASTM had

an operating income of over $21 million and expenditures of over $19 million in areas that

include publication of standards and standards technology training.

Founded in 1898 as the U.S. section of an international organization, ASTM set out to

address problems with materials performance in industrial applications. Specifically, failures in

railroad components and equipment such as rails, wheels, and axles were evidence that steel

producing methods in the U.S. were not adequate. To ensure materials uniformity, a coherent
system of testing was needed. It was agreed that the best way to accomplish this objective

was through standard specifications. By 1913, ASTM committees were conducting work in

the areas of corrosion, protective coatings, lubricants, and petroleum products. ASTM

presently does standards research and development in virtually every technical field ranging

from health care services to electronics.

ASTM feels that its philosophy of retaining technical expertise within its organization

facilitates the standard-development process and is the primary distinguishing feature between

itself and ANSI. ASTM further believes that the most effective way of achieving true

standards consensus is through a system that actively guides, encourages, and performs the

technical research. As a result, ASTM formed a subsidiary organization in 1987. The Institute

for Standards Research was founded to identify, develop, and manage areas of research on

topics as diverse as medical and dental implants to classification schemes for advanced

ceramics.

Evolution of Program

ASTM evolved in direct response to the realization by technical professionals and

industry that standards were required to regulate commercial and industrial expansion. Up

until the late 1950s ASTM had concentrated its efforts in the traditional areas of engineering

and industrial applications. By this time, however, public interest in safety, health and

environmental issues provided the impetus for ASTM to establish technical committees

covering consumer products, energy resources, environmental testing, waste recovery, and

other non-traditional fields. These committees have produced a broad array of standards,

from ambulance crew training requirements to specifications for protective clothing.

Procedural Mechanisms

In response to the basic principle of voluntary consensus standards in the U.S., ASTM

has developed a standards process based on the following tenets:

• Participation of all parties interested in the use and/or development of a

standard;

• Balanced representation of interests during the standards-writing process;

• Extensive testing to validate technical results; and

• Due process procedures and balloting to allow for broad involvement and input

during standards review.

Applying these tenets, ASTM produces standards of six different types:

• Standard Test Method: A definitive procedure for operations that yield test

results.

• Standard Specification: A statement of requirements to be satisfied by a

material, product, system, or service.
• Standard Practice: A definitive procedure for operations that do not yield test

results.

• Standard Terminology: A document that defines nomenclature and symbols.

• Standard Guide: Options or instructions that do not specify a course of action.

• Standard Classification: A systematic arrangement of materials, products,

systems or services into groups.

A standards activity is initiated when a written request is submitted by a member to

ASTM headquarters. This request should describe the proposed action and list parties that

might have an interest it. ASTM then conducts a review to determine if the activity is within

ASTM's purview, if there is adequate interest in the action, and if parallel activities are being

conducted by other organizations. Once these basic requirements have been satisfied, the

process may continue as follows:

• A series of conferences is held to define the scope, title, and structure of the

new standards. All interested individuals and organizations that can reasonably

be identified are invited to participate in this step.

• A new committee may be formed to conduct the work or an existing ASTM

committee may be given the responsibility. A committee must receive ASTM

Board of Director approval for a standard's title and scope before work

continues. A committee must have a balanced membership (i.e., users,

producers, academia) to insure that all interests are served.

• The technical committee submits the work to one of its subcommittees. These

subcommittees, which are intended to represent the highest degree of technical

expertise, are further subdivided into task groups.

• A task group will prepare a draft standard, which is then reviewed by the

governing subcommittees through letter ballots. Subcommittee approval leads

to main committee review, also by letter ballot.

• Upon main committee approval, the draft standard is submitted to ASTM for

further balloting. Dissenting votes must include reasons for the voter's

objections, which must be directly addressed by the standards developer before

the draft can go on in the process.

• Once consensus has been reached, the ASTM Committee on Standards

verifies that proper procedures were followed and due process was achieved. 

Only with this final approval can an ASTM standard be published.

ASTM publishes its standards in the Annual Book of ASTM Standards. Standards

remain under the jurisdiction of the originating technical committee, which is responsible for

keeping it technically current. Generally, a standard will take two years to develop, but some

have been produced in eight months to a year.

Relationship of Program to Government
ASTM has had working relationships with a number of Federal as well as state

government agencies. At the state level, ASTM has assisted various departments of

transportation in areas such as pavement management technology and bridge service life

improvement techniques. At the Federal level, ASTM has worked closely with the EPA,

OSHA, the Consumer Protection Safety Commission, DOE and DOT. ASTM has produced

standards for groundwater quality and radon levels that have been incorporated by EPA. DOT

often cites ASTM standards for roadway construction and materials, and DOE has worked

with ASTM in the development of standards for geothermal energy since 1979.

Legal Aspects

ASTM procedures have been devised to preclude violation of antitrust laws. However,

a complaint was filed in 1964 against ASTM in the Philadelphia U.S. District Court contending

that testing requirements for asbestos cement piping restricted entry into the United States

market. After a 78-day trial and review, the judge's opinion stated that ASTM's "procedure

[makes] it most unlikely that the views of one member or group of members could

predominate over the consensus of the opinion of the committee as a whole." This decision

established a precedent that has helped preserve the integrity of ASTM standard against

subsequent legal challenges, none of which have been successful, according to ASTM.32

International Aspects

Notwithstanding the organization's international origins, ASTM has been involved

primarily with standards activities in the U.S. As international standards have become

increasingly important, however, ASTM has taken the position that direct U.S. industry

involvement in ISO and IEC is essential for U.S. products to remain competitive in foreign

markets. ASTM further believes that the most effective way of promulgating international

standards is through a consensus methodology as practiced by itself and other U.S. standards

organizations. Despite philosophical differences between the organizations, ASTM maintains

membership in ANSI in an effort to promote its interests and standards on the international

stage. Having organizational standards incorporated as part of ANSI National Standards is

often a direct, although not the only route to international acceptance, and is a primary reason

that ASTM continues to submit some of its standards to ANSI for approval. ASTM members

serve on ISO and IEC technical committees and a number of ASTM standards have been

adopted by these organizations in electronics testing and materials evaluation.

AEROSPACE AND AVIATION INDUSTRY

Three associations that develop standards for the aerospace industry were reviewed. 

Each addresses different aspects of the industry. The Aerospace Industries Association (AIA)

concentrates its standards efforts in the field of aircraft fasteners. The American Institute of

Aeronautics and Astronautics (AIAA) primarily focuses on standards relating to equipment

interfaces, software requirements, and operational characteristics of primarily space systems. 

The Society of Automotive Engineers (SAE), Air and Space Division does work in a wide

 

 

32Unnamed case cited in Stremba, Henry J.: "The House That Standards Built." ASTM

Standardization News, June 1988.
variety of areas including: materials, equipment requirements, calibration, and fuels to name

but a few.

Aerospace Industries Association (AIA)

Genesis of Program

AIA was founded in 1919 by members of the nascent aircraft industry to promote

American aviation. Originally, AIA published standards in a wide variety of fields relating to

aircraft production and operations. Guidelines were set for manufacturing processes, aircraft

electrical systems, and components design. In 1940, AIA's focus shifted to aircraft fasteners

when companies within the industry identified the need for standards for aeronautical bolts,

screws, and rivets. This move was driven by the need to establish consistent methods of

defining aircraft airworthiness (to which fasteners are critical), and fostering economic

efficiency in aircraft manufacture.

Evolution of Program

Since aviation's earliest days, most aircraft manufacturers have been dependent on

outside vendors to provide fasteners for their aircraft. Historically, a major problem had been

that the quality and capabilities of these fasteners had varied significantly from vendor to

vendor, making it difficult for airplanes to meet design specifications consistently, or forcing

manufacturers to buy fasteners from only one predictable source. The industry wanted to

remedy this situation by applying standards to fastener design and manufacture. In 1940, AIA

began its standards work in fasteners. At first, the standards were mostly dimension

specifications and materials requirements, but as the technology evolved, standards topics

expanded to include composites, high temperature adhesives and other areas. Today, most

of AIA's work involves aircraft, but some of its areas of research are applicable to spacecraft

design. Specifically, a recent AIA standard on robotics manufacturing, "NAS 875, Industrial

CNC for Drilling, Reaming, and Counter-sinking" may be of direct use in future large scale

production of spacecraft components.

Procedural Mechanism

Members of AIA sit on the association's Standards Committee. The Committee

conducts ongoing studies to define new standards that may be needed. A request for a

standard from this Committee, users, or manufacturers is sent to the Steering Committee for

review. Once approved, a sponsor is assigned responsibility for writing and drawing up the

new or revised standard. The sponsor is a committee member who has volunteered or has

been appointed for this duty. Once finished, the standard is sent back to the Steering

Committee for comments and approval. After the standard is approved by the Committee, it is

sent to the checker, an individual responsible for ensuring that all AIA procedures are met,

that all comments have been addressed, and that calculations have been done properly. After

the final approval by the checker and the Steering Committee, the standard is issued for

publishing and distribution.

Although AIA is a member of ANSI, AIA standards are not submitted to the ANSI

approval process. AIA's position is that its internal standard-setting procedures are sufficient

to ensure consensus and technical validity. AIA maintains membership in ANSI to stay

abreast of international standards efforts in the field of aerospace fasteners.
Relationship of Program to Government

AIA's involvement with the Federal government has been primarily through DoD and

the FAA. Approximately 500 AIA standards are currently listed on DoDISS for procurement

purposes, including codes for fasteners, aircraft control knobs, and aircraft tubing and cables. 

FAA has referenced or incorporated AIA standards covering life vests, oxygen masks, and

other commercial aviation technologies. AIA standards are often developed in close

cooperation with Federal agencies. Special liaison groups within AIA have members from

both industry and government to coordinate lines of standards research of common interest. 

In this way, manufacturers are better able to respond to specific needs identified by Federal

agencies.

Legal Aspects

In the early stages of standards setting, AIA experienced legal problems with

trademarks. Products which met AIA standards were labelled as such with an AIA trademark. 

AIA was involved in several antitrust lawsuits because AIA was approving the quality of

certain producers, and thus recommending their products over those of others. As a result of

this experience, AIA currently does not maintain any list of qualified parts (those produced by

a specific group of manufacturers). AIA is very aware of the need to remain strictly a

standards-setting group, and not involve itself in certifying specific companies. Additionally,

AIA adheres closely to its consensus method of setting standards. It actively encourages

feedback during the standard development process to afford all concerned parties the chance

to influence the final product.

International Aspects

AIA is an active participant in international aircraft standards efforts. Presently, AIA

serves as ISO Secretariat for Aircraft Fastener Standards, which gives it great influence in this

area. AIA also has a close working relationship with the European Association of Aerospace

Manufacturers (AECMA), a French-based international organization involved in aircraft issues. 

AECMA members include major European aircraft manufacturers like Airbus, and it is in AIA's

interest to present its position on fasteners and other issues in this forum because these

foreign aircraft manufacturers often employ AIA standards.
American Institute of Aeronautics and Astronautics (AIAA)

Genesis of Program

AIAA was established over 60 years ago to promote engineering and scientific

research in aviation and space. Its origins as an engineering society closely associate it with

that academic discipline, but AIAA also has worked extensively with the aerospace industry to

enhance productivity in that field.

AIAA began its standards program in 1981 with the intent of assisting engineers,

scientists, and other aerospace professionals with accurately identifying and defining the

characteristics of space systems and components. Standards developed by AIAA establish

common nomenclature, performance parameters, equipment interface specifications, and

design practices in areas ranging from metrication (the adoption of the metric system) to

human factors. The AIAA presently spends approximately $300,000 per year on its standards

activities.

Evolution of Program

In the early 1980s, senior AIAA officials recognized the need for greater efficiency in

design and research efforts with regard to space applications of aerospace technologies. It

was felt that the best way of achieving "economy of effort" in this area was through a

comprehensive standards program. Such a program would help further AIAA's organizational

goals of anticipating space technology trends, creating and disseminating technical

information, and helping to formulate national aerospace policy. By 1981, using the ANSI

methodology, AIAA had produced its first standard on terminology for space structures. In

1987, AIAA's standards program was fully accredited by ANSI and the organization began its

standards work in earnest. To date, AIAA has produced 10 space standards documents in

software (2), hardware (3), and other areas (5), including coordinate systems, atmospheric

environments, and design approaches. Ten additional standards are presently in process with

7 due for publication in the spring/summer of 1992.

Since the beginning, AIAA has concentrated its standards-setting efforts on space

issues to avoid duplicating the work of other organizations with aircraft standards programs. 

This role has come as a result of negotiations between AIAA and other aerospace standards

organizations such as SAE and AIA. As these groups' standards developing efforts broaden,

however, areas of standards responsibilities will need to be re-examined and clearly defined to

avoid redundant work.

Part of AIAA's mission in formulating standards is to anticipate technical developments

and needs, a goal which is accomplished through the input of AIAA's membership. This kind

of professional advice often leads to development of special reports such as "The Future of

Aerospace Standards" and "Orbital Debris Mitigation: Technical, Legal and Economic

Aspects," which in turn may lead to important standards research. Anticipatory standards

research is, of course, influenced by industry and government interests, but is not wholly

dependent upon it. For example, cancellation of the Orbital Maneuvering Vehicle (OMV)

program was a blow to space robotics research, but standards work continues within AIAA in

this area of technology.
Presently, AIAA has 50 active standards projects, with 33 Committees on Standards

(COS) and study groups doing work in astrodynamics, reliability, serviceable spacecraft, and

other areas. It is expected that these numbers will increase as new areas of research are

identified.

Procedural Mechanisms

AIAA conducts its standards-setting efforts in conformance with ANSI-approved

methods. First, a need is identified, then study groups meet to evaluate possible standards

and topic areas. The process of developing a standard begins with a call to members and an

announcement in AIAA's magazine, The Standard Bearer. A new committee is organized for

each new standards topic. Those interested parties who are able to commit themselves to

long-term participation become members of the committee. Standards-developing committees

are composed of members of industry, Federal agencies, and academia. While it is not

necessary for the members of the individual committees on standards to be AIAA members,

the committee chairperson must be.

A Committee on Standards' first task is to write the scope of the proposed standard. 

This scope must be submitted to and approved by the Standards Technical Council, a

standing group appointed based on their technical expertise. A major portion of the scope is

a justification outlining the need for the new standard, to whom it will apply, what exactly it will

entail, and how it will be implemented. The committee does not actually begin discussion of

the proposed standard until the scope has been approved.

Committees on Standards are required to meet at least twice a year, though some

committees meet more often. The committees must also provide that some of their meetings

be open to the public for input. When the committee has met several times, and feels it is

ready to distribute a draft of the standard, a written document is first circulated to the

committee itself, and then to the membership of AIAA. The draft is also announced in The

Standard Bearer. Comments from review materials are returned to the committee, and the

document must be edited to reflect all comments. This cycle may be repeated several times

before the committee is satisfied with its standard document.

Once the committee has finalized its document, it is sent back to the Standards

Technical Council, which is responsible for ensuring that all comments have been adequately

responded to, and that consensus was reached during the development of the document. If

the standard is to be produced solely as an AIAA standard (common for reference directories

or other non-technical documents), AIAA will publish it. If it is to be an ANSI standard (all

technical documents), it is sent to ANSI for a 90-day review, during which ANSI ensures that

all of its requirements have been met. The standard is then published as an ANSI/AIAA

standard.
Relationship of Program to Government

While AIAA has worked with several Federal agencies on specific technical topics,

cooperative standards work has not been extensive due to the relative youth of the group's

standards program. Two AIAA standards have been adopted by DoD for procurement

purposes ("Standard for Aerodynamic Decelerator and Parachute Drawing," and "Guide to

Standard and Reference Atmosphere Models") and a third is referenced in the licensing

examination for parachute packers. No AIAA standards have yet been incorporated into

Federal regulatory requirements.

At present, FAA and AIAA jointly are involved in standardization work in satellite

navigation for aircraft. This developmental research is collaborative in nature (not under

contract) and is proceeding through AIAA's Committee on Standards for Guidance, Navigation

and Control as part of its scheduled work program.

Legal Aspects

As part of its requirements for ANSI accreditation, AIAA must conform to the

consensus methodology. To date, there have been no challenges to AIAA standards. 

However, as standards begin to prescribe specific design approaches and operational

practices, the prospect of such challenges increases. Already, AIAA's standards committees

are expanding their work with special studies and project research in areas such as

"Standards Requirements for a Future Multi-Mission Infrastructure" and a "Guide for Unit

Interface Design for Serviceable Spacecraft." While advancing efficiency, interchangeability,

and commonality in future space-related operations, these standards and others like them

may be perceived by some as commercially constraining.

International Aspects

AIAA maintains active membership in the International Standardization Organization

(ISO). The focus of ISO's space standards work, and AIAA's primary involvement in that

organization, is through Technical Committee 20, Aircraft and Space Vehicles (ISO/TC-20). In

1989, TC-20 created a working group to specifically assess space standardization needs. 

AIAA representatives are members of this group, as are participants from France, Germany,

Italy, and the former Soviet Union. France has been particularly interested in promulgating

international space standards because of its lead role in the European Space Agency (ESA). 

French government and industry leaders feel that commercial opportunities can best be

promoted through the clear definitions and methodologies that standards provide. Present

international standards efforts include work in space data systems; other areas under

consideration for standardization research are manned space flight and space debris issues.

Society of Automotive Engineers (SAE), Air and Space Division

Genesis of Program

SAE has its origins in the early years of the automotive industry. In 1905, automotive

manufacturers, engineers, and others involved in this new industry established the Society of

Automotive Engineers to promote standardization and to generally nurture the field of

transportation technology. To the founders of SAE, "automotive" was defined as "anything

that moves on the earth, under the earth, in the water, on the water, and in the air." In 1916
SAE acted to fulfill this broad charter by expanding to include the Society of Aeronautic

Engineers, which became SAE's Aeronautic and Aircraft Engine Divisions. From the

beginning, their responsibilities were centered on developing standards for aircraft parts and

performance.

Evolution of Program

The Aeronautics Division became very active in developing standards upon the United

States entry into World War I. Specifications and standards were required for military aircraft

and SAE became involved in setting code for everything from aircraft bolts to instruments. By

1921 the division was producing aeronautical material specifications, propeller standards, and

aircraft accessory specifications. The organization went on to develop an Aeronautical

Drafting Manual to establish uniform methods of presenting visual data, the first such standard

in the industry.

SAE's standard-setting activities kept pace with advancing aircraft technology so that

the organization was soon developing standards for helicopters, jet engines, and avionics. 

The evolution of aeronautical technology to include space systems has led to SAE's efforts in

spacecraft and satellites, including standards for hardware and software. At present there are

over 1,600 aerospace standards listed by SAE with approximately 130 new and revised

documents issued in 1991. SAE has budgeted almost $2 million for fiscal year 1992 for its

aerospace standards program. Examples of standards presently listed by SAE Air and Space

are "Automatic Pilots for Subsonic Aircraft" and "Actuation System Data for Launch and

Missile Vehicles."

Procedural Mechanisms

SAE Air and Space Division is organized under the Aerospace Council which reports to

the Technical Board. Beneath these two governing bodies are some 160 committees and

subcommittees that have primary responsibility for writing standards. These groups and their

6,000 members operate under clearly defined guidelines requiring due process and consensus

during the standards development process.

When a request for a standard has been made by a concerned party (manufacturer,

user, or government agency) the issue is assigned by the governing councils to a standing

committee with responsibility for that area. Committee expertise ranges widely and includes

electromagnetic compatibility, aerospace metals, fiber optics, and rocket reliability and

certification to name but a few. The committee researches the subject and prepares a

standard through the consensus method. Parties that might be affected by the standard are

allowed to comment on the results before a proposal is finalized. When a final version of the

proposed standard is ready, it is sent to the parent committee for review and, ultimately, to the

Aerospace Council for approval. SAE Air and Space Division publishes different standards

types, including recommended practices and aerospace information reports all of which are

prepared following the requirements for due process and consensus that form part of the

conditions for membership in ANSI.

Relationship of Program to Government

SAE Air and Space maintains active relationships with a number of government

organizations to coordinate standardization and research efforts. DOT, FAA, NASA and DoD
have worked extensively with SAE in the past. For example, over 40 FAA Technical Standing

Orders (TSOs) were originally developed by SAE technical committees, and SAE has been

requested by FAA to produce or update technical documents on such topics as "Aircraft

Engine Containment." At present over 260 SAE standards are listed on DODISS as

procurement specifications. As a further sign of the close working link between government

and SAE, NASA and the Air and Space Division recently co-sponsored a space standards

needs assessment workshop at the Johnson Space Center.

Legal Aspects

SAE submits all of its aerospace standards for ANSI recognition, and over the last year

some 300 Air and Space-developed codes have completed the ANSI process and have been

listed as American National Standards. SAE governing councils review standards extensively

to resolve potential legal difficulties before final approval is granted. By adhering to strict due

process and consensus procedures, SAE seeks to avoid antitrust litigation, to this point

successfully.

International Aspects

SAE Air and Space Division is the administrator of the U.S. advisory group to ISO

Technical Committee 20 - Aircraft and Space Vehicles. It also serves as secretariat for two

ISO subcommittees on "Air Cargo and Ground Equipment" and "Aerospace Fluid Systems and

Components." A number of SAE aerospace standards are under consideration as de facto

standards by ISO. These activities along with the direct links that SAE has to international

aerospace standards organizations, such as the European Association of Aerospace

Manufacturers (AECMA) and the European Organization for Civil Aviation Electronics

(EUROCAE), ensure that U.S. standards interests are represented abroad.

AUTOMOTIVE INDUSTRY

This section focuses on two standard-developing organizations in the motor vehicle

industry. The primary standard-setting group for passenger automobiles is the Society of

Automotive Engineers (SAE), whose standards cover every aspect of this field, from design to

performance. The Truck and Trailer Manufacturers Association (TTMA), which has been

included to represent the trucking industry, develops standards related to the design and

construction of truck trailers.

Society of Automotive Engineers (SAE), Land and Sea Division

Genesis of Program

As stated in the previous section covering SAE's Air and Space Division, the

organization was originally founded in 1905 with a focus on automotive technology and issues. 

The society was established to meet the needs of engineers within the fledgling automotive

industry rather than within a specific engineering discipline. The intent was to bring together

mechanical, civil, and electrical engineers working in the automotive field, as well as

manufacturers and suppliers, to define, through standards, the design and performance of

their industry's products.
Evolution of Program

SAE's first official standards committee was appointed in 1910. The 13 divisions

comprising this committee immediately set out to produce standards that would optimize

automotive design and mass production. Parts interchangeability, simplified production

processes, and dimensional standards were some areas in which this SAE committee directed

its efforts. By 1913, SAE published its first handbook on standards which included subjects

ranging from "navigation motors" to "yoke and eye rod ends."31

Over the years SAE's standard-setting activities have broadened to accommodate the

ever-widening spectrum of technologies applied to ground transportation. Currently, SAE

Land and Sea Division's 600 technical subcommittees produce over 100 new ground vehicle

standards per year and list a total of 1100 standards dealing with components and systems

for passenger cars, truck tractors, buses, and motorcycles. Some examples of SAE Land and

Sea Division automotive standards are "Passenger Car Side Door Latch Systems" and "Motor

Vehicle Seat Belt Assembly Installations."

Procedural Mechanisms

As with Air and Space standards, SAE Land & Sea Division standards are also

devised under the auspices of the SAE Technical Board. The primary difference between the

two divisions is the make-up of their constituent technical committees. Land and Sea Division

is comprised of five separate groups, four of which are responsible for different areas of

ground transportation technology including: construction, agricultural and off-road machinery,

motor vehicles, trucks and buses, and miscellaneous technology development. These

councils are further broken down into some 600 committees and subcommittees which cover

such areas as human factors, powertrains, fuels and lubricants, and braking systems. The

fifth group in the Land and Sea Division is responsible for marine standards. The Marine

Technical Committee devotes itself to standards for pleasure craft only. This differs from the

American Bureau of Shipping, which covers commercial, military, and civil marine applications,

and which will be discussed in detail in a later section.

The process of formulating a standard within SAE Land and Sea Division begins when

users, manufacturers, or other relevant organizations and individuals identify the need to

standardize some aspect of automotive technology. When the request for a standard is

received, it is reviewed by the governing technical board and then sent down to the

appropriate parent committee. From here, it is directed to the subcommittee that oversees the

specific technology covered by the standard request. This subcommittee conducts the

research and writes the standard proposal. The proposal is then sent back to the parent

committee and the Land and Sea Council for review and approval. It is the responsibility of

these last two groups to ensure that due process and consensus procedures have been

followed. SAE produces standards of various types for ground vehicles. Recommended

practices, materials specifications, technical information reports, as well as design and

performance standards are generated to provide guidance in virtually every aspect of ground

vehicle fabrication and function. As with the Air and Space Division, Land and Sea Division

submits its standards to ANSI review.

 

 

31 Rumbaugh, Max E.: "SAE Takes Equal-Partner Approach to Standards Development." 

ASTM Standardization News, July 1991.
Relationship of Program to Government

SAE Land and Sea Division has a strong relationship with a number of Federal

agencies that include DOT, the Federal Highway Administration, the National Highway Traffic

Safety Administration, DOE, DOD, and NIST. Approximately 150 SAE vehicular standards are

cited by various U.S. government regulatory agencies, and 30 standards are listed on

DODISS for procurement purposes. Types of standards incorporated by the government

range from procedures for collision tests to requirements for sealed beam headlamps. Worthy

of particular note are the 80 some SAE technical reports that have been incorporated into

NHTSA Federal Motor Vehicle Safety Standards. These requirements, which cover such

topics as driver's visual range guidelines and vehicle seating definitions, and the fact that

government representatives are active members of SAE's Motor Vehicle Council, illustrate the

close working link between Federal agencies and the Land and Sea Division of SAE.

Legal Aspects

SAE Land and Sea Division makes every effort to ensure that consensus is achieved

when formulating its voluntary standards. Every major committee maintains at least one staff

member to monitor potential legal problems with proposed standards and to make certain that

all questions of a legal nature are adequately addressed. Also, SAE's membership in ANSI

places upon it the requirement to meet the stringent consensus procedures of that

organization. To date, over 500 SAE automotive standards have been approved by ANSI as

American National Standards.

International Aspects

SAE maintains connections to the international automotive community by various

means. Through its ANSI membership, SAE has representatives on four ground vehicle

councils in the ISO, including TC 22 (Road Vehicles), TC 70 (Internal Combustion Engines),

TC 96 (Cranes and Related Lifting Equipment), and TC 127 (Earthmoving Machinery).

SAE maintains direct links to such organizations as the International Symposium on

Automotive Technology and Automation (ISATA) and the International Automotive Society of

France (SIA). In this manner, SAE identifies international trends and innovations in the

automotive arena and ensures its participation in multi-national efforts to devise technical

standards.
Truck Trailer Manufacturers Association (TTMA)

Genesis of Program

TTMA, incorporated in 1941, is an industry-based professional association that

publishes recommended practices for the construction and design of truck trailers. Member

companies aid in development of these recommendations. TTMA uses the term

"recommendations" rather than standards because the recommendations rely on voluntary

compliance and often cover procedural issues (e.g., how to respond to a situation) rather than

equipment specifications. With the onset of World War II, manufacturers realized there would

be a large government allocation of materials and resources to the industry and formed TTMA

to generate an interest in the industry as well as to provide guidance to both the manufacturer

and the end-user of truck trailers.

Evolution of Program

Through the late 1940s and 1950s, the U.S. became increasingly dependant on

automotive travel. By 1956, with the enactment of the Interstate and Defense Highway Act, it

was clear that motor vehicles had become the preeminent mode of travel. As more freight

was moved by truck along the growing Interstate Highway System, the industry took steps to

provide manufacturers and users with recommended practices and guidelines relating to the

operation, manufacture, and performance of truck trailers. The TTMA published and

continues to promulgate its recommendations to reflect industry-wide technical advances

made by the manufacturers. TTMA is comprised of truck trailer, tank trailer, cargo container,

and container chassis fabricators. Examples of TTMA-recommended practices include, "A

Guide for Periodic Inspection of Trailers," "Air Brake Application and Release Test," and "Tank

Trailer Ladders and Walkways."

Procedural Mechanisms

Through its recommendations TTMA hopes to provide guidance for manufacturers and

users, rather than to direct or prescribe technology. A part of its primary functions is to

provide a forum and an information clearinghouse for the industry. TTMA guidelines and

practices are the result of extensive manufacturer involvement in the standards development

process.

Recommendations are established through two engineering committees composed of

TTMA members. One committee covers tank trailers and the second covers all other types of

trailers. These committees propose and draft recommendations. After final approval by the

committee, recommendations go through two or three rounds of review by member companies

before being reviewed by the TTMA Board of Directors. Once approved by the Board, a

proposal is published as a recommended practice of TTMA and distributed to its members. 

Since all TTMA recommendations are voluntary, manufacturers do not have to abide by them. 

TTMA is not a member of ANSI, but it maintains an SAE liaison committee to keep apprised

of that organization's truck and trailer-related standards.

Relationship of Program to Government
TTMA maintains links to various offices within the Department of Transportation

including the Office of Hazardous Materials Transportation (OHMT) and the National Highway

Traffic Safety Administration (NHTSA). TTMA recommendations can be found referenced in

Federal regulations. For example, TTMA's "Procedure for Testing In-Service Cargo Tank

Manhole Covers" is cited in 49 CFR 171.7.

Legal Aspects

The voluntary nature of TTMA's recommendations has shielded the group from

antitrust litigation to date. The guidelines themselves are broad enough to provide latitude in

the approach to design. TTMA's practices are meant to be only a basis for industry

cooperation.

International Aspects

TTMA maintains an informal relationship with ISO to keep abreast of international

trailer standards activities. TTMA also has as members trailer manufacturers and suppliers

from Canada, France, The Netherlands, and Germany, which provide it with greater

international perspective and visibility in this field.

PETROCHEMICAL INDUSTRY

The petrochemical industry, which manufactures products from oil distillates and

byproducts, produces fuel products, and refines petroleum for various uses, depends

extensively on special equipment to conduct its business. This section discusses three

standard-setting organizations that develop standards to regulate this equipment. It should be

noted that the standards of all three organizations are frequently applied to other industries

that use similar equipment. The American Petroleum Institute (API) develops work practices

and management guides in addition to hardware standards. In this manner, it tries to cover

industry procedures as well as equipment requirements. The American Society of Mechanical

Engineers (ASME) concentrates its standards efforts in equipment design and performance

test code. The Manufacturers Standardization Society (MSS) specifically develops standards

for valves and fittings.

American Petroleum Institute (API)

Genesis of Program

API was established in 1919 as a trade association to represent the interests and

address the concerns of the oil industry. At the turn of the century, widening use of oil and

oil-based products by the U.S. commercial, transportation, and industrial sectors caused oil

producers to realize that achieving uniformity in their production processes was in the interest

of business and the public. Safety and economic efficiency could be increased through oil

industry cooperation and, with these goals in mind, API was formed. API began setting

standards in 1923 to fill gaps in technical knowledge related to oil production. Accidents

during drilling, refining, and other operations had caused deaths and injuries that might have

been avoided if equipment had been of a guaranteed level of quality. To address this
problem, API began to write standards for pipes, materials, and fittings associated with oil

production.

Evolution of Program

As oil production equipment and procedures became more complex and sophisticated,

the scope of API standard-setting efforts broadened to include operational guidelines,

standard safety procedures, and performance requirements for these systems.

At present, there are over 400 API standards, ranging from alloy requirements for

pipes to performance standards for high pressure transmission lines. Not only do such

standards ensure safety during operations, but they lower industry costs. Without such

industry-wide standards, each producer would be forced to develop specifications for their own

equipment.

Procedural Mechanisms

As a member of ANSI, API follows procedures to ensure consensus when developing

its standards. API issues standards for all types of equipment used in the petrochemical

industry through committees composed of professionals in various fields related to the

industry. Ideas for standards may come from industry or government representatives. 

Industry members may feel it is necessary to standardize certain equipment or practices and

suggest to the relevant API committee that a standard be developed. Various government

agencies have contacted API committees to develop standards for given situations. For

example, both DOT and OSHA have asked API to develop pipeline standards to be used in

safety regulations. These codes have been on such topics as welding procedures and valve

design.

A suggestion for standardization is presented to the appropriate committee within API. 

A working group of eight to ten members drafts a proposed standard, which is submitted to a

full subcommittee for balloting. Members of the subcommittee either approve, approve with

comments, or disapprove the proposal. The working group then revises the proposal, taking

all of the comments into account. If, because the comments are extensive, the proposal is

drastically changed, a resubmission to the committee might be required. Upon acceptance by

the subcommittee, the proposal is submitted to the main committee for final review. In

addition to legal reviews, health, safety, and environmental reviews may be required before

final approval. The standard is then submitted for formal publication but does not take effect

until it has been issued. API-recommended practices are reviewed every five years or sooner

if new technology requires their modification.

An example of a standard published by API is "Specifications for Subsurface Sucker

Rod Pumps and Fittings," providing dimensional requirements to assure interchangeability of

all component parts. API also develops guidance (e.g., for inspection of refinery equipment)

and recommended practices (e.g., for electrical installation at petroleum processing plants).

API standards are voluntary, and it is the responsibility of the purchasers of the

equipment to ensure that the manufacturer has complied with API recommendations. The

exception to this is the API Monogram Program. This quality assurance program ensures that

manufacturers worldwide can consistently manufacture production equipment and materials to

API specifications. When a company initially applies for API certification, third party auditors
conduct an on-site inspection of the facilities. API's professional staff reviews the audits and

decides whether to issue the license. Licensed manufacturers undergo an unscheduled onsite review after one year, and then every three years. Noncompliance may be dealt with in a

number of ways, ranging from recommendations for changes to immediate revocation of API

certification.

Relationship of Program to Government

API has worked with many Federal agencies on standards issues over the years. 

Government organizations such as EPA, DOT, OSHA, USCG, and the U.S. Geological Survey

have adopted some 70 standards into regulations. These include specifications for oil storage

tanks, pipe transmission systems, and construction requirements for off-shore drilling rigs. 

These standards have been used in procurement specifications and in regulations at the

Federal level. Some 30 states also have adopted API codes into law.

Legal Aspects

Legal reviews are conducted during the development of all API standards. As a

preventative method, draft proposals are screened to reduce the likelihood that antitrust or

other legal issues might be raised against API standards. For example, the use in a draft

standard of any trade names that have become used commonly throughout the industry would

be removed -- the word "teflon" would be removed and replaced with its scientific name. 

Additionally, API makes every effort to develop standards based on industry consensus. To

date, as an ANSI member, this approach has precluded antitrust action against API.

International Aspects

API is currently working to have many of their standards adopted by the ISO. API

committee members sit on ISO committees through ANSI's U.S. National Committee to

provide the standards API has already developed to that organization and aid in the

development of new international standards. If such efforts are successful, those firms doing

international business can operate without the higher costs associated with increased

inventories necessary when standards differ among countries.
American Society of Mechanical Engineers (ASME)

Genesis of Program

ASME is a nonprofit professional society with the goal of promoting mechanical

engineering and technological progress in terms of machine design and construction, power

generation, and production programs as they apply to industry. Areas in which ASME

conducts research include energy resources, the environment, transportation, materials and

structures, and manufacturing.

In 1884, four years after the Society was founded, ASME began its standards program. 

At the time, machine design, performance, and operation lacked uniformity, making it difficult

for industry to specify and purchase equipment to suit its needs. ASME organized committees

that included research engineers, product manufacturers, and product users in an attempt to

"balance" the standards development process. It was clear that coherent standards would be

the only way of regulating the operation and quality of the technology that was being

introduced into late-19th Century American society.

As part of its responsibilities, ASME has established a standards-development program

with the purpose of fostering economic growth and public safety. ASME is a founding

member of ANSI and endorses the use of voluntary standards. Currently ASME has over 600

codes and standards in print, all of which have been developed using the consensus process. 

Examples of ASME code that are part of ANSI National Standards include safety codes for

elevators and escalators, the boiler and pressure vessel code, and the B-31 piping code. 

These last two codes are used extensively in the petrochemical industry.

Evolution of Program

Concern for public safety was a driving force behind the evolution of ASME's standards

program. The proliferation of steam boilers in the late 1800s brought a wave of accidents that

forced industry and government to act. By the 1880s, 50,000 deaths and 2 million injuries

were being reported per year due to exploding boilers. In response to public calls for action,

states began to formulate boiler codes. At the same time, insurance companies eager to limit

accident settlements were also writing and implementing boiler codes. The resulting

confusion brought all the concerned parties to the conclusion that a single entity should

assume the role of standards developer. ASME assumed this role and published its first

formal pressure vessel code in 1915.

Since then, ASME has produced standards in a wide variety of mechanical engineering

fields. These areas include quality assurance methods for nuclear power plants,

specifications for machine designs such as compressors and pumps, and recommended

testing practices for various industrial systems.
Procedural Mechanisms

The ASME Board of Governors has delegated all activities concerning standards and

codes to its 20-member Council on Codes and Standards. The Council oversees the work of

10 boards which cover the areas of primary ASME standards activities. These boards work in

such areas as pressure technology, safety, performance test codes, metrication, and include a

group specifically dedicated to international standards issues.

Reporting to the boards are over 120 committees which are directly responsible for a

specific technology from piston rings to drawing requirements. These committees and their

subcommittees are where standards are actually devised. Once a final draft has been

completed the standard is sent up through the ASME echelons. Once consensus has been

achieved, and upon the recommendations of the ASME Supervisory Board and ANSI, the

standard is submitted to public comment. When all issues have been addressed satisfactorily

and in accordance with ANSI/ASME protocol, the draft is approved as a standard and

published.

Relationship of Program to Government

Because of ASME's broad expertise and experience in developing standards, many

Federal and state agencies have incorporated and referenced ASME code. DOT, EPA, DoD,

OSHA, NRC, and others presently use such ASME standards as: "Nondestructive Testing"

(CFR 29), "Cast Iron Flanges and Flanged Fittings" (CFR 49), and the "Pressure Vessel and

Boiler Code" (CFR 10) in procurement specifications as well as regulations.

States have also incorporated ASME code into their regulations. At present, every

state except Alabama, New Mexico, and South Carolina has adopted at least one section of

the ASME Pressure Vessel Code. In some cases, ASME representatives have been

authorized by the state to conduct inspections and surveys to confirm compliance with the

law.

Legal Aspects

As a member of ANSI, ASME strictly adheres to the tenets of consensual standards

development, and takes active steps to preclude litigation against itself and its standards. If

legal issues were to arise, however, ANSI would serve as a buffer between ASME and legal

actions. In recent history, no litigation has been initiated against ASME standards. However,

ASME was included in the Hydrolevel case (see footnote 29) in which ASME committee

member interpreted ASME standard to commercial detriment of a competitor.

International Aspects

ASME has established an Advisory Board dedicated to promoting international

cooperation in standards development. Working both independently and through ANSI, this

group is taking such steps as signing agreements of cooperation with engineering societies in

the United Kingdom, Japan, the People's Republic of China, and other nations. Another of

ASME's current major international initiatives is the establishment of ASME chapters outside

of North America.

Manufacturers Standardization Society of the Valves and Fittings Industry (MSS)
Genesis of Program

In 1910, the Committee of Manufacturers on Standardization of Valves and Fittings

formed to help foster development of codes for valves, value activators, flanges, and other

pipe-associated technology. As industry expanded its use of piping, it became evident that

pipe manufacturers were designing and building valves and fittings of widely varying quality

and dimensions. In order to promote business and efficiency, many of these manufacturers

joined together to write interface standards. In 1924, the committee was formally reorganized

as the MSS and began to broaden its standards-setting activities.

Evolution of Program

As a trade association, MSS has been interested in developing standards that would

promote use of their products. The best way of accomplishing their goal has been to

establish levels of quality and performance that would consistently satisfy customer needs. 

The MSS standards program reflects the need to include test procedures and materials

requirements in the manufacture of valves and fittings. This need arose from failures of

equipment which resulted in steam pipe and liquid transport pipe accidents at the turn of the

century. Presently, MSS works in 23 distinct areas of pipe, valve, and fitting technology, and

has produced 56 standards.

Procedural Mechanisms

MSS is comprised of 23 technical committees identified by the specific subject matter

of the committee responsibilities. The committees are made up of professionals in various

fields related to the industry. A proposal is submitted to the Coordinating Committee of the

Board of Directors describing the proposal, justification, and the scope or breadth of the

standard. At its next quarterly meeting, the Coordinating Committee determines the need for

the proposed standard. If there is a sufficient amount of interest or need for the type of

standard proposed, it is assigned to the appropriate technical committee for development.

The technical committee then develops the proposed standard. Committee members

send their ballots to the Executive Director, who tallies the votes. The committee chairman is

provided with all comments against the proposal. The committee must then work out a

compromise. Upon final approval by the committee, the MSS coordinating committee receives

the proposal and reviews the proposals for consistency with the standards of other agencies

and Federal regulations. Standards are then published and provided to member companies. 

Standards published by MSS include: "Pressure Testing of Steel Valves" and "Techniques

and Specifications for Piping Hangers and Supports."

MSS standards are voluntary and it is up to the purchasers of the equipment to ensure

that the manufacturer has complied with MSS recommendations. Although MSS is an ANSI

member, only one of its standards has been submitted for ANSI approval.
Relationship of Program to Government

MSS standards have used by various Federal agencies through citation or

incorporation in regulations and procurement specifications. Of the 56 MSS standards,

19 have been adopted by DoD for procurement purposes. Other U.S. government agencies

that have referenced MSS codes include DOT and OSHA. Examples include "MSS SP-44,

"Steel Pipe Line Flanges" and MSS SP-75, "Specification for High-Test Wrought Welding."

Legal Aspects

MSS consults extensively with user organizations in developing its standards. By

making recommendations to potential purchasers, and taking their comments and concerns

into consideration, MSS feels that it can adequately meet user needs while maintaining

economic manufacturing practices. MSS has not yet faced antitrust litigation resulting from its

standardization activities.

International Aspects

MSS takes an active role in promoting U.S. industrial interests in international forums. 

The U.S. serves as secretariat of ISO's Committee on General Purpose Values (TC 153) and

an MSS representative serves as committee chairman. Society members have also served

on many ISO working groups and subcommittees addressing valve, pipe, and fittings issues.

ELECTRONICS INDUSTRY

In this section, three standard-setting organizations are examined with respect to their

role within the electronics industry. The Electronics Industry Association (EIA) produces

standards for electronic components such as tubes and transistors. The Institute of Electric

and Electronics Engineers is a professional association that develops standards that cover

electronics performance, reliability, safety, and design. The last electronics organization

surveyed, Underwriters Laboratories (UL), primarily concerns itself primarily with standards for

electronic product performance, testing, and safety.

Electronics Industry Association (EIA)

Genesis of Program

EIA was founded in 1924 by users and manufacturers of commercial electronics parts. 

This group was established to promote electronic parts interchangeability, and write

component specifications within the growing radio and commercial electronics business. 

Although not initially a professional society per se, early involvement with the electrical and

electronic engineering discipline ensured the technical rigor of all EIA standards and

specifications.
Evolution of Program

EIA's standards activities have expanded markedly over the years as the scope of

electronics technology has broadened. The evolution of EIA closely mirrors the evolution of

technology: from tube, resistor, and capacitor specifications, to transistor requirements and,

most recently, to work in fiber optics. In response to specific changes in hardware, EIA has

formed groups to address standards issues in those areas. Additionally, the ever-increasing

complexity of electrical and electronics systems has led EIA to conduct standards work in

areas like configuration control, interface requirements, and digital systems synchronization.

EIA has established nine broad categories in which it presently produces standards

and other technical publications. These are:

• General

• Consumer Electronics

• Telecommunications

• Component Parts (Passive)

• Solid State Products

• Electronic Displays and Tubes

• Industrial Automation

• Design Automation

• Government Electronics

Procedural Mechanisms

Standards are promulgated through 275 EIA technical committees that have jurisdiction

over different sectors of the electronics industry. The committees are composed of members

of EIA, user groups, manufacturers, and, in some cases, government representatives. 

Committee members or the chairperson of a committee may initiate the setting of a new

standard. Once there is a consensus on the nature of the standard, the committee prepares a

written proposal to be submitted to the EIA engineering department.

The committee submits a statement of the scope of the standards project, a title for the

project, and a request for assignment of a project number. After reviewing the proposal, the

EIA engineering department assigns a number to the project and contacts organizations or

members who will be affected by the development of the standard to allow them the

opportunity to participate in the process.

After the proposed standard is assigned a project number, the committee works with

EIA staff engineers to develop and write the standard. Once written, the proposed standard is

available for review and comment by interested parties for a period of 30 days. If it is deemed

appropriate, the document is submitted simultaneously to ANSI for review. It then returns to

the committee, which responds to the comments and modifies the proposed standard, if

necessary. At this point, it is resubmitted to ANSI and to an EIA executive committee

composed of the chairpersons of each technical committee.

If approved by both organizations, the standard becomes an ANSI and an EIA

standard. It may then be listed and published by both groups. EIA publishes nearly 1,000

standards and engineering publications, with over 5,000 members participating on EIA
technical committees. EIA submits a standard to ANSI review when it wishes it to be listed as

an American National Standards.

Relationship of Program to Government

EIA has had a long working relationship with a number of Federal organizations,

including the DOT, DoD, and the FCC. Many of its standards are part of Federal regulations

either by reference or direct incorporation. These include various TV channel interference

standards for the FCC, mobile communications standards for DOT, and telephone link

standards for DoD. Often, EIA-devised standards are adopted or referenced in their ANSI

forms. As part of its standards-development process, EIA encourages government

participation, but limits government membership on any one technical committee to no more

than 10 percent. This measure is taken to ensure the balance that is central to EIA's

standard-setting regime.

Legal Aspects

EIA standards are subjected to the system of development prescribed by ANSI. 

Through its process of balloting and appeals, EIA attempts to address concerns and issues

that emerge in developing standards. The overall standards process may take two years and

its comprehensive nature allows for dissenting input throughout. Interested parties are

therefore offered ample opportunity to comment, with the result being that no antitrust litigation

has been initiated against EIA standards in recent times.

International Aspects

EIA is active in standards activities with the IEC. As a member of ANSI, EIA

represents U.S. interests in the international commercial electronics arena. EIA encourages

its industry members to participate in international standards issues such as interface

specifications and parts commonality. To date, over 50 EIA-developed standards have been

adopted as international standards.

Institute of Electrical and Electronics Engineers (IEEE)

Genesis of Program

IEEE can trace its roots to 1884 when a number of electrical engineers formed a

professional society devoted to the science and technology of electricity, electronics, and

allied disciplines. Among the organization's self-defined responsibilities was the setting of

standards. In 1890, the group published its first industry standard, proposing the name

"henry" for the unit of self-induction. Since that time the organization has committed a

significant part of its efforts to standards development. At present, IEEE publishes over 20

percent of the world's standards and literature on electrotechnology.
Evolution of Program

IEEE in its present form was chartered in 1963, when it merged with the Institute of

Radio Engineers. This move broadened the scope of IEEE's work to include communications

technology. From that point on, IEEE conducted standards research in areas such as

broadcast technology, frequency control, and antennas. IEEE now does standards in over 30

fields of the electronics discipline and has expanded its efforts to include new technologies as

they emerge. Computers, microwave theory, and superconductivity are areas to which IEEE

has dedicated some of its resources. Today, IEEE has over 600 active standards and

publishes approximately 60 new ones each year. The group is constantly exploring new

areas of electrotechnology to include in its standards efforts. IEEE has over 300,000

members representing industry, government, and individuals interested in advancing all

aspects of electrotechnology.

Procedural Mechanisms

IEEE is a founding member of ANSI and actively supports the consensus method of

developing standards. The IEEE standards development process is composed of six steps

that are meant to ensure involvement of all parties that might be affected by a standard. The

need for a standard may be identified by a member of IEEE or by someone outside of the

organization.

The proposal for a standard is submitted to the Standards Activity Board, which

assesses the merit and need for this standard. If the Board decides that further action is

needed, it assigns the proposed standard to a Standards Coordinating Committee. At this

level, the scope of the standard is defined, and a Technical Committee assumes

responsibility. The Technical Committee establishes a subcommittee to do the technical work. 

Once a draft is written, it is submitted to a ballot process which entitles dissenting parties to

comment. It becomes the Technical Committee's responsibility to either incorporate or

otherwise address points brought out during balloting. Once a final version of the standard is

prepared, it is submitted to the IEEE Standards Board for review. This group is the approval

authority for all IEEE standards and is made up of consumers, government representatives,

manufacturers, and other relevant organizations and individuals. Upon approval, the IEEE

Publication Board will print and distribute the document.

If a standard is intended to become an American National Standard, submittal to ANSI

is required. This may happen in parallel to the IEEE process, or after a standard has been

approved by IEEE, depending on which specific ANSI method of approval is chosen.

Relationship of Program to Government

IEEE has been extensively involved with many Federal agencies, including DoD, DOT,

NASA, and DOC. Their standards are often cited by or incorporated into regulations and have

been used in procurement specifications. Approximately 35 IEEE standards have been

adopted by DoD, including "Specifications for Electrical Interfaces," "Standards for Surge

Arresters," and "Standards for Electrical Relays."

Legal Aspects
Use of IEEE standards is wholly voluntary. Perhaps reflecting IEEE's effort to ensure

that its standards represent a consensus of all concerned interests, legal challenges have not

occurred to date. IEEE maintains that it rigorously follows a clearly documented standardsdevelopment process and routinely disapproves codes which have not been developed

accordingly.

International Aspects

Via its membership in ANSI, IEEE is an active participant in ISO and IEC efforts to

formulate international standards. It is often the goal of IEEE technical groups to set

standards that will be accepted readily in the international arena. Seven IEEE standards have

been adopted by ISO in the field of information processing.

Underwriters Laboratories (UL)

Genesis of Program

UL was established in 1894 by members of the insurance industry to help reduce or

prevent bodily injury, loss of life, and property damages resulting from poor design or

manufacture of consumer products. UL's primary area of research was in electrical system

safety, which applied to the growing number of electrical appliances which were finding their

way into consumer homes at the turn of the century. UL pursued its goal of promoting

consumer safety in two ways: through testing of products submitted directly by

manufacturers, and through preparing "Standards for Safety" that described generic UL

requirements for product families.

Evolution of Program

UL has expanded its areas over the years to accommodate the broadening consumer

market and the changing public perception of safety needs. In addition to electrical and

electronic equipment, UL now investigates mechanical products, building materials,

construction systems, fire protection equipment, burglary prevention systems, and marine

products.

As government interest in consumer producer issues has grown, many manufacturers

have become increasingly eager to submit their products to some kind of neutral validation

procedure. As a result, UL has produced safety standards for goods as diverse as drip-type

coffee makers and asphalt shingles. UL presently lists over 2,000 standards.

Procedural Mechanisms

UL standards are prepared in accordance with the procedures promoted by ANSI, of

which UL is a member. Proposed standards are presented to concerned manufacturers, trade

organizations, and UL Engineering Councils for extensive review. To be accepted as an

American National Standard, a UL standard must undergo the ANSI approval process. Not all

UL standards are submitted to ANSI for approval.

A standard proposal may be initiated by any party interested in the relevant area of

research. The proposal is reviewed by the governing UL Engineering Council to determine if
its topic merits further study. If this step is successfully completed, the proposal is sent down

to the appropriate Engineering Group where the technical content and format are set.

The UL Engineering Councils are comprised of six major Engineering Departments

responsible for broad areas of technology. Those departments are further divided into

Engineering Groups which do the actual technical work. When a group completes the

development of a standard, it sends it up for review through the Engineering Department and

finally to the governing Engineering Council where it is reviewed for adherence to format and

process. Representatives of industry, government, and academia sit on the Councils to

ensure a broad consensus. Once the review process is completed to the satisfaction of UL,

and all dissenting comments have been addressed, the standard will be listed and published. 

The entire standard-setting process may take as long as two years.

Relationship of Program to Government

UL has had working agreements with various U.S. government agencies for a number

of years. DoD, the USCG, OSHA, DOC, and the Consumer Product Safety Commission

(CPSC) have all had representatives on various UL committees and have used UL-developed

standards in regulations and procurement specifications either by reference or adoption. 

Examples include fuel line standards for the Coast Guard, hazardous environmental electrical

equipment standards for DoD, and the many consumer product standards for the CPSC.

Legal Aspects

UL standards are developed through a consensual procedure that provides for

comment by the public, industry and government. An extensive review process ensures that 

all interested parties are given a forum to voice their concern. It is also important to note that

manufactures voluntarily submit their products to UL for testing and if disagreement arises

over test results, the issue can be referred to the National Institute of Standards and

Technology (NIST) for appeal. NIST will then act as arbiter and have both parties agree in

writing to accept and abide by its findings.

International Aspects

In addition to its involvement with ISO and IEC through membership in ANSI, UL has

established reciprocal agreements with many foreign standards organizations, including the

Standards Association of Australian, the Japan Standards Association, and the Canadian

Standards Association. These relationships have been formed to foster harmonized

international standards in UL's areas of interest.
SHIPPING

This last section is devoted to examining the standard-developing duties of the

American Bureau of Shipping (ABS). This organization is significant because it not only

promulgates standards in the shipping industry but also has authorization from the U.S. and

some foreign governments to carry out enforcement of those standards. Additionally, ABS

has been sanctioned to monitor international and national maritime conventions, and perform

other statutory services for various governmental organizations.

American Bureau of Shipping (ABS)

Genesis of Program

The ABS began as the American Shipmaster's Association in 1862, during the clipper

ship era. The original intent of the Association was to achieve a high degree of efficiency and

character among the free masters and officers of maritime vessels. The Association

developed tests to determine their knowledge of nautical science and seamanship. Each

applicant found qualified was issued a "Commission of Competency" by the Association.

The Association early on adopted a system for surveying, rating, and registering

vessels. By 1891, the Association had published rules for several types of vessels and

formed several technical committees that published and edited rules for various types of ship

structures. In 1898, the Association changed its name to the American Bureau of Shipping

(ABS). Today, the ABS is comprised of ten regional business centers and has 159 offices in

major ports and industrial centers in 86 countries.

The goal of the ABS is to promote the safety of life and property at sea by

promulgating rules and standards. ABS establishes and administers these rules for the

design, construction, and periodic survey of ships and other marine structures. Classification

certifies adherence to these rules, thus ensuring that a vessel possesses the structural and

mechanical integrity required for its intended service.

Evolution of Program

In the mid-1800s, after a series of marine disasters, the underwriting industry

recognized a need for the establishment and administration of safety standards for the design,

construction, and maintenance of ships and other marine structures. The response to this

need was a nonprofit organization charged with improving the structural and mechanical

safety of ships.

The first standards prepared by what would become the ABS were Rules for Building

and Classing Wooden Vessels. As technology and industry sophistication progressed,

standards were produced in response. The evolution of standards reflects the historical

changes in shipping: "Rules for Building and Classing Iron Vessels" (1877), "Rules for

Construction and Classification of Boilers for Steam Vessels" (1891), and the recent "Rules for

Building and Classing High Speed Craft (1988), which includes provisions for air-cushion

vehicles and surface effects ships. Today, ABS publishes 16 different rules and 30 guides,
and works to keep rules and standards current with advancing technology and, where

appropriate, develop new ones for emerging technology.

Procedural Mechanisms

ABS develops and upgrades its rules through a structure of 18 technical committees,

two panels, and 15 overseas technical committees. Each committee and panel is composed

of government representatives, individuals in the underwriting, ship-owning, ship-building,

naval architecture, naval engineering, and other related fields.

As a full ANSI member, ABS has representatives on various ANSI-sanctioned

standards committees. ABS subscribes to ANSI-approved standards by reference, but as

ANSI does not administrate maritime-specific standards, the reverse is not true. Therefore,

ABS-developed and published standards remain solely the responsibility of ABS.

In addition to its standards-writing work, ABS has the function of serving as a

classification agency for marine structures and equipment. The process of classification

certifies that the rules for design, construction, and maintenance have been met and that the

ship or structure in question is fit for its intended service. ABS classification involves four

steps:

• Technical plan review;

• Construction surveys;

• Acceptance by ABS Classification Committee; and

• Subsequent periodic surveys for maintenance of class.

Upon an initial request that a vessel be classified, the shipyard or design agent

presents design drawings and calculations to ABS engineers. A detailed review of the

structural and mechanical details is completed to verify compliance with the rules and

determine whether the design is suitable for production.

ABS field surveyors then monitor the construction process to verify that the approved

plans are being followed, good workmanship practices are used, and rules are adhered to in

all respects. ABS representatives witness materials and structures tests as well as the

installation of principal mechanical and electrical systems.

When completed, a vessel undergoes sea trials attended by ABS field surveyors and, if

the vessel passes this test, its credentials are presented to the ABS Classification Committee. 

If all of the rules have been satisfied, the vessel is accepted into class and a formal

certification is issued.

Once the vessel is in operation, ABS performs periodic surveys to verify that the class

standards are upheld throughout its service life. Classification renewal dates are explicit, but

a ship operation has three months before and after that date in which to comply with class

requirements. If the ship fails to meet ABS specifications, there are two levels of enforcement

that may be imposed. The first, suspension of class, means that a ship may operate, but that

certain maintenance procedures are required within a specified time period. The second level,

cancellation of class, indicates that a ship is no longer fit for service, and may not operate

wherever ABS classification is required.
Relationship of Program to Government

ABS and the U.S. Coast Guard (USCG) have had a close working relationship for a

number of years. In 1981, by a formal Memorandum of Understanding, ABS was authorized

by the USCG to perform plan review and inspection on their behalf for new U.S. flag vessels. 

USCG regulations (Title 33 and 46 of the CFR) reference ABS codes in 150 different sections. 

In many cases, the USCG has formally adopted ABS rules as their standard (e.g., 45 CFR

Sec. 31.10-1, "Inspection of Hulls, Boilers, and Machinery").

ABS is actively involved with a number of other U.S. government agencies and their

programs. These range from the Department of Agriculture (ABS certifies shipboard

refrigeration equipment for imported fruit) to the Department of the Interior (ABS classification

documents are part of the approval process for offshore drilling from mobile drilling units). 

DoD requires that commercial-type ships built for its Military Sealift Command be constructed

and classified according to ABS rules. The Code of Federal Regulations contains 24 direct

references to ABS with respect to agencies other than the U.S. Coast Guard.

The extent of the relationship between the U.S. government and the ABS is further

illustrated by the fact that both the Coast Guard Commandant and the Maritime Administration

Administrator sit on the ABS Board of Managers. Other government officials are members of

ABS rulemaking and management committees.

Legal Aspects

ABS has been given authority by the U.S. government to perform certain functions

pertaining to rulemaking, issuance of certificates, inspection and surveys, and other statutory

services. For example, under Title 46 of the U.S. Code (Section 3316), ABS is recognized as

an agency of the United States to perform classification of U.S. vessels. Further, some

sections of the code stipulate that an ABS action constitutes Federal agency action (e.g., 46

CFR Section 91.37-20, concerning cargo gear plans; which indicates that ABS approval

constitutes USCG approval). This level of government authorization coupled with the fact that

many ABS standards are part of Federal code have precluded antitrust litigation against ABS.

International Aspects

ABS is authorized by more than 90 governments to administer provisions of

international safety conventions on their behalf. These agreements, which were established

under the auspices of the International Maritime Organization (IMO), include the Tonnage

Convention, Load Line Convention, Marine Pollution Prevention Convention, and the Safety of

Life at Sea Convention. In this role, ABS conducts surveys, issues certificates, and performs

administrative duties for countries that might otherwise not have the expertise or resources to

do so for themselves.

The nature of the shipping industry dictates an international perspective. ABS

rulemaking technical committees include members from 15 nations that possess extensive

technical experience and know-how in the marine sciences. In this way, ABS ensures ship

operators and builders that standards and rules are international in scope from their inception.