PUBLICATIONS

A 1 1 1 4 DSniM

NBSIR 84-2992 00

Guidelines for NBS Standards

Committee Participants

U.S. DEPARTMENT OF COMMERCE

National Bureau of Standards

Office of Product Standards Policy

Gaithersburg, Maryland 20899

December 1984

U.S. DEPARTMENT OF COMMERCE

-nc

100

. U56

34-2992

1934

NATIONAL BUREAU OF STANDARDS

NATIONAL BUREAU

OF STANDARDS

LIBRARY

NBSIR 84-2992

GUIDELINES FOR NBS STANDARDS

COMMITTEE PARTICIPANTS

December 6, 1984

Prepared by the Office of

Product Standards Policy

Approved by the Standardization

Advisory and Coordination

Committee

U.S. DEPARTMENT OF COMMERCE

National Bureau of Standards

Office of Product Standards Policy

Gaithersburg, MD 20899

December 1984

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

NATIONAL BUREAU OF STANDARDS. Ernest Ambler. Director

PREFACE

This document provides guidance to NBS employees who participate in voluntary

standards Development activities of standards bodies. The information

provided reflects Federal policy as stated in Office of Management and Budget

circular A-119 as well as Bureau policy relating to voluntary standards

activities.

These guidelines represent a revision of a document issued in January 1972.

This revision was prepared by the Office of Product Standards Policy, the

organization within the Bureau responsible for the formulation and

implementation of Federal government standards policy. This document was reviewed and approved by the NBS Standardization Advisory and Coordination

Committee (SACC) under its responsibi lity to advise management on Bureau-wide

issues relating to standardization activities.

NBS employees are encouraged to become familiar with these guidelines as well

as with the several documents in the appendices. NBS managers should assure

that NBS staff participation in standards activities conforms to these

guidelines.

Suggestions for improvements and comments or questions relating to the

contents of this document should be forwarded to the Office of Product

Standards Policy.
TABLE OF CONTENTS

Guidelines for MBS Standards Committee Participants

Page

Preface iv

1. Introduction 1

2. Appointment to a Standards Committee 1

3. Funding 1

4. Responsibilities of NBS Representatives on a Standards Committee 2

5. National Center for Standards and Certification Information ... 3

6. References Included in Appendices 3

7. Other References ../ 4

Appendices

A. 0MB Circular A-119 5

B. Administrative Manual Subchapter 3.02 11

C. Administrative Manual Subchapter 3.03 17

D. Title IV of the Trade Agreements Act of 1979 21

E. Guidelines for Participation by U.S. Government Agencies,

Employees, or Representatives in International StandardsRelated Activities 27
1. Guidelines for NBS Standards Committee Participants

Introduction

These guidelines are designed to provide standards committee participants

with an understanding of their responsibilities.

NBS has participated in standards activities since the early 1900's. Through

standards participation, staff are able to contribute technical expertise and

gain valuable information relating to industry practices and needs, thus

helping to guide NBS research programs.

0MB Circular No. A-119, "Federal Participation in the Development and Use of

Voluntary Standards," states that "when properly conducted, standards

development can increase productivity and efficiency in industry, expand

opportunities for international trade, conserve resources, and improve health

and safety."^ it is also noted, that standards activities, "if improperly

conducted, can suppress free and fair competition, impede innovation and

technical progress, exclude safer and less expensive products, or otherwise

adversely affect trade, commerce, health or safety."!

Because standards have a significant effect in the marketplace, participants

have specific responsibilities in the standards development process, as well

as general obligations as Federal employees.

Participants are encouraged to contact the Office of Product Standards

Policy of NBS for any additional information or assistance they may need in

their standards activity.

2.

Appointment to a Standards Committee

Participation in a standards committee is a management decision.

Consideration is given to unit mission and goals, resource commitments,

and technical competence required. Standards committee participants are required to complete and have approved by their supervisor NBS Form 83,

"Record of Committee Assignment. "2

3.

Funding

When participating in a standards activity, the cost is normally paid by the

organizational unit at NBS or another Federal agency. Federal funds can not

be used to pay individual membership fees. NBS does pay certain

administrative and organizational fees.

3

1
4. Responsibilities of NBS Representatives on a Standards Committee

a) Keep Management Informed

Standards committee participants are to keep their supervisor informed

especially where other NBS representatives are involved and coordination of

viewpoints is necessary or desirable. Participants are to seek the help and

advice of the Office of Product Standards Policy at NBS on policy and

procedural matters.

b) Coordinate with Federal Participants

Participants should interact with other Federal agency committee members.

0MB Circular A-119 states that, "when two or more agencies participate in a given voluntary standards body or standards-developing group, their

representatives should coordinate views on matters of paramount importance so

as to present a single, unified position."

c) Report "High-Impact" Issues

NBS has adopted specific recommendations for identifying sensitive

standards-related issues to be brought to the attention of the Director of

the Office of Product Standards Policy and the MOU Director. A "high-impact"

issue is one that meets any one of the following criteria:

1) It may be brought to the attention of the Director of NBS or the

Secretary of Commerce by one or more outside groups, such as Congress,

another Federal agency, a trade association, an industrial firm, or an influential individual.

2) It contains the potential for outside criticism of NBS by reputable

persons or organizations.

3) It involves broad coordination across internal NBS operating units

or agency boundaries.

4) It generates a need for policy guidance regarding appropriate limits

of NBS responsibility, whether technical or financial.

5) It would have significant impact on the United States' industrial

position.

d) Encourage Innovation

The use of performance criteria in standards will generally encourage

innovation. Design specifications or the inclusion of a patented device,

material or process may unnecessarily limit technical progress.

e) Consider International Standardization

Participants should be aware of international standardization activities

related to their national standards committee work. The United States is

obligated under the Trade Agreements Act of 1979 to adopt international

standards, where appropriate.

4

2
f ) Know the Rules

Participants should familiarize themselves with the scope of the standards

committee and the standards body's policies and procedures. The use or abuse by participants in standards committee activities of standards

procedures to restrict competition is improper and violative of various

Federal and state antitrust statutes. Violators of those statutes are subject to civil and criminal prosecution.

g) Keep Records

Participants should maintain a file of committee-related information

including the committee by-laws, current membership list, minutes of

committee meetings, final ballots, and relevant correspondence. This file

should be retained by the participant or the unit for at least 5 years.

5. National Center for Standards and Certification Information

The Office of Product Standards Policy maintains the National Center for

Standards and Certification Information (NCSCI) with a reference collection

of over 240,000 standards, specifications and codes published by U.S.

professional and technical societies, state purchasing offices, U.S.

Government agencies, and major national and international bodies. The

collection also contains articles, pamphlets, reports, and handbooks on standardization and over 100 foreign and domestic periodicals and newsletters

published by standards organizations. 5 NCSCI has access to computerized data

bases and Key-Word-In-Context (KWIC) indexes.

6. References - (attached)

1) Office of Management and Budget Circular No. A-119, "Federal

Participation in the Development and Use of Voluntary Standards ,

Federal Register, Vol. 47, No. 211, p. 49496, dated November 1, 1982.

2) NBS Administrative Manual Subchapter 3.02, "Standards and Professional

Committees ,

11 dated November 13, 1984.

3) NBS Administrative Manual Subchapter 3.03, "Payment of Fees for Private

Voluntary Standards Activities ,

11 dated July 8, 1983.

4) a) Trade Agreements Act of 1979, Public Law 96-39, July 26, 1979,

Title IV , "Technical Barriers to Trade (Standards) "

b) "Guidelines for Participation by U.S. Government Agencies,

Employees, or Representatives in International Standards-Rela tod

Activities , " issued by the Secretary of Commerce, Federal Register,

Vol. 49, No. 32, p. 5792, dated February 15, 1984.

3
7. Other References - (available from OPSP)

1) "Standards Committee Activities of NBS 11 - an annual report describing

Bureau contributions in standards activities.

2)

" Directory of NBS Staff Memberships " - a semi-annual report listing

committee participation by staff.

3) "Standards Activities of Organizations in the United States " - NBS

Special Publication 681, (1984).

4) "Directory of International and Regional Organizations Conducting

Standards-Related Activities " - NBS Special Publication 649, (1983).

4
. APPENDIX A

OMB Circular A-119

"Federal Participation in the Development and Use of Voluntary Standards"

5
49496 Federal Register / Vol, 47, No. 211 / Monday, November 1, 1982 / Notices

OFFICE OF MANAGEMENT AND

BUDGET

Issuance of Circular No. A-119,

"Federal Participation in the Development and Use of Voluntary

Standards"

agency: Office of Management and

Budget.

action: Final Issuance of OMB Circular No. A-119, “Federal Participation in the Development and Use of Voluntary

Standards.”

Summary: This OMB Circular provides

policy and administrative guidance to Federal agencies on using voluntary standards for procurement and

regulatory purposes, on participating

with private sector organizations to develop such standards, and

coordinating Executive Branch

participation in the development of voluntary standards. Implementation of

this Circular is expected to result in reduced costs to the Government in developing and maintaining standards

for products, systems and services. effective date: This Circular, which

supersedes OMB Circular No. A-119. dated January 17, 1980. is effective upon

publication.

FOR FURTHER INFORMATION CONTACT:

David F. Baker, Office of Federal Procurement Policy, Office of Management and Budget, Washington,

DC 20503 (202) 395-7207. SUPPLEMENTARY INFORMATION: On April '

21, 1S82, the Office of Management and

Budget published a draft Circular,

subject as above, for a 60-day period of public and agency comment. Comments

were received from more than 120

individuals and organizations, including Federal agencies, business firms,

industry associations, professional groups and private citizens. There follows a summary of the major

comments grouped by subject and a response to each—including a brief description of changes made as a result of the comments. Many other changes of

a less significant character were made

to increase clarity, simplicity, precision

and readibility, and to reduce the burdens of compliance as much as

possible. A. Procedural Criteria Imposed on

Standards Developers

Comment: Several commenters

objected to OMB's deletion of specific

procedural criteria which the previous

version of the Circular imposed on

voluntary standards bodies as a precondition to Federal participation.

They argued that such criteria

intended to increase public participation

and openness—would help to minimize

the potential for anti-trust activities. Other commenters suggested that while

such procedures should not be

mandatorily imposed, OMB should

instruct agencies to encourage private

standards developers to follow such

procedures.

Response: With regard to the inclusion of procedural criteria and their mandatory imposition on standard

developers, we have concluded that imposition of the mandatory procedures

contained in the previous edition of the Circular is inappropriate, burdensome • and costly and that the question of imposing such criteria is peripheral to the fundamental aims of the Circular. We do agree that, as with any human

endeavor, the voluntary standards

development process is vulnerable to abuse. Consequently, we have cautioned

Federal agencies to beware of such

potential (Para. 7). We have also provided guidance to agencies in the form of a letter from the Department of

Justice, dated June 22, 1982, which

discusses suggested agency approaches

to the question of public participation in private sector standards development.

B. Regulatory Applications

Comment: Some commenters

suggested that the Circular should be

limited to procurement applications, and

that Federal agencies should not be

required to use voluntary standards for regulatory purposes. Some commenters

suggested, in addition, that the Circular should not apply to "independent

regulatory agencies".

Response: We believe the benefits to be derived from the procurement use of standards are equally valid for regulatory applications—particularly the benefits of assuring private sector input

into Federal regulatory activities while

reducing the potential for duplicating

existing, adequate voluntary standards

with Government standards. With

regard to the second concern, the Circular does not "require” Federal agencies to use voluntary standards for regulatory purposes. It establishes a policy preference in that regard but leaves to the agencies, themselves, the decision as to whether to adopt a given

voluntary standard for a specific Federal

regulatory purpose. (The legal

requirements associated with such

adoption, such as those of the Administrative Procedures Act. will, of course, continue to apply.) We believe such an approach is entirely appropriate

with respect to independent regulatory

agencies as with the rest of the Executive Branch.

C. Role of the Department of Commerce

Comment: Several commenters

objected to the requirements that the Department of Commerce maintain

listings of (1) voluntary and Government

standards, (2) voluntary standards

bodies, and (3) those standards

organizations with which Federal

agencies interact—on the grounds that

this would result in extensive and costly

reporting requirements. Other

commenters suggested that the agency

reporting requirements contained in the Circular were, themselves, overly

burdensome.

Response: We agree. The

requirements to maintain various

listings have been eliminated. The

provisions dealing with reports on agency implementation of the Circular have been revised to require that reports

be summary, as opposed to detailed, in nature. D. Voluntary Dispute Resolution Service Comment: Some commenters objected

to our deletion of the requirement that the Department of Commerce establish a program to make available a "voluntary

dispute resolution service" to handle

precedural complaints brought by

6
Federal Register / Vol. 47. No. 211 / Monday. November 1. 1982 / Notices

interested parties against voluntary

standards bodies. Those commenters

suggested that such a mechanism would

provide an impartial means of resolving standards disputes without costly and

lenethv litigation. Response: While we take no position on the substantive merits of such a mechanism, we are satisfied that the requirement to establish such a service

is not an appropriate element for inclusion in this Circular. Agencies with

mission concerns in this area (e.g. Commerce. |ustice. etc.) may. of course, consider establishing such a service as it

is within their province to do so. The

creation of the mechanism is clearly

peripheral to the policy issues dealt with

in the Circular, however, which are

limited to Federal participation in the development and use of voluntary

standards.

E. Single Federal Position Comment: Many commenters

suggested that the provisions of the Circular that required agencies to coordinate their views and express a

single Federal position in private sector standards development activities were

unnecessary and unworkable—and that establishment of a mechanism to achieve these purposes would be costly

and lead to lengthy delays in the standards development process. Response: We continue to believe that agencies should endeavor to coordinate

their views and present single Federal

positions in matters of paramount

importance. We agree, however, that the requirement to do so in all such

instances is unreasonable and could

lead to bureaucratic delays.

Consequently, we have eliminated the requirement that Federal positions must

be developed in all instances, as well as

those provisions which would have

required the Secretary of Commerce to appoint a “lead'' agency when

disagreements as to the nature of the Government's position occurred on a given issue. We continue to expect agency representatives to make a reasonable elfort to present a single Federal position reflective of the public

interest on matters on paramount

interest in those standards activities wherein two or more agencies

participate. Candice C. Bryant, Acting Deputy Assistant. Director for Administration. Execulive Office of the President

Office of Management and Budget

October 2G. 1982. Memorandum lo Heads of Executive Departments and Agencies

From- David A. Stockman

Subject: OMB Circular No. A-119. "Federal

Participation in the Development and

Use of Voluntary Standards"

Attached, for vour implementation, is a revision to OMB Circular No. A-119 which

provides guidance lo agencies in working

with, and using the products of. private sector standards organizations. The effect of this revision is to eliminate the costly, unnecessary, and burdensome aspects of the

Circular, while continuing to encourage

agency participation in the development of

private sector standards. Also attached for vour information and use

is a letter, dated June 22. 1982. from the Department of justice, which provides

guidance in the implementation of the Circular—particularly as it relates to working

with private sector groups to develop needed

standards. Executive Office of the President

Office of Management and Budget

October 26. 1982.

Circular No. A-119—Revised To the Heads of Executive Departments and

Establishments

Subject: Federal Participation in the Development and Use of Voluntary

Standards

1. Purpose. This Circular establishes policy

to be followed by executive agencies in working with voluntary standards bodies. It also establishes policy to be followed by

executive branch agencies in adopting and

using voluntary standards.

2. Rescissions. This Circular supersedes

OMB Circular No. A-119. dated January 17. I960, which is rescinded.

3. Background. Many Governmental

functions involve products or services that must meet reliable standards. Many such

standards, appropriate or adaptable for the Government's purposes, are available from

private voluntary standards bodies. Government participation in the standardsrelated activities of these voluntary bodies

provides incentives and opportunities to establish standards that serve national

needs, and the adoption of voluntary

standards, whenever practicable and

appropriate, eliminates the cost lo the Government of developing its own standards. Adoption of such standards also furthers the

policy of reliance upon the private sector to supply Government needs for goods and

services, as enunciated in OMB Circular No.

A-76.

4. Applicability. This Circular applies lo all executive agency participation in voluntary

stanaards activities, domestic ana

international, but not to activities carried out pursuant to treaties and international standardization agreements.

5. Definitions. As used in this Circular:

a. Executive agency (hereinafter referred to as "agency") means any executive department, independent commission, board,

bureau, office, agency. Government-owned

or—controlled corporation or other establishment ol ihe Federal Government,

including regulatory commission or board. It does noi inciude ine legislative or ludicial branches oi Ihe Federal Government

b. Standard means a prescribed sci r

'

rules, conditions, or requirements con >ec with the definu.on of terms: ciassificaion c

.’ components: delineation of procedures:

specification of dimensions, materials, performance, design, or operations: measurement of quality and quantity in describing materials, products, systems,

services, or practices: or descriptions of fit and measurement of size.

c. Voluntary standards are established generally by private sector bodies and arj available for use by any person or organization, private or governmental, the term includes what are commonly referred to as "industry standards" as well as "consensus standards”, but does not include

professional standards of personal conduct,

institutional codes of ethics, private standards of individual firms, or standards mandated by law. such as those contained in the United States Pharmacopeia and the National Formulary, as referenced in 21 U.S.C. 351.

d. Government standards include

individual agency standards and

specifications as well as Federal and Military standards and specifications.

e. Voluntary standards bodies are private sector domestic or multinational organizations—such as nonprofit

organizations, industry associations, professional and technical societies,

institutes, or groups, and recognized test laboratories—that plan, develop, esla'biish. or coordinate voluntary standards.

f. Stanaards-developing groups are committees, boards, or any other principal subdivisions of voluntary standards bodies, established by such bodies for the purpose of developing, revising, or reviewing standards, and which are bound by the procedures of those bodies.

g. Adoption means the use of the latest edition of a voluntary standard in whole, in part, or by reference for procurement

purposes and the inclusion of the latest edition of a voluntary standard in whole, in part, or by reference in regulation(s).

h. Secretary means the Secretary of Commerce or that Secretary 's designee

6. Policy. It is the policy of the Federal Government in its procurement and

regulatory activities to:

a. Reiy on voluntary standards, both domestic and international, whenever

. feasible and consistent with law and

regulation pursuant to law;

b. Participate in voluntary standards

bodies when such participation is in the public interest and is compatible with

agencies missions authorities, priorities and

buaget resources, and

c. Coordinate agenev participation in voluntary standards bodies so trial |1) the most effective use is maoe of avenev

resources and representatives .-id 12) the views expressed Dv suen repre* •mans r-. arr

in the public interest .inn as .i

• -t rr m do

noi conflict witn the interests ,i..a i sut .she : views of the agencies

7. Policy Guidelines In implementing the poiicy rstabhsncd bv this Ciri . ( r nemies

should rrcocni/e inc positive contribution of standards dev riopment and r. aird ariitii rl

7
49498 Federal Register / Vol. 47, No. 211 / Monday, November 1, 1982 / Notices

When properly conducted, standards development can Increase productivity and

efficiency in industry, expand opportunities

for international trade, conserve resources, and improve health and safety. It also must

be recognized, however, that these activities,

if improperiv conducted, can suppress free and fair competition, impede innovation and

technical progress, exclude safer and less expensive products, or otherwise adversely

affect trade, commerce, health, or safety. Full account shall be taken of the impact on the economy, applicable Federal laws, policies, and national objectives, including, for example, laws and regulations relating to antitrust, national security, small business, product safety, environment, technological

development, and conflicts of interest. It • should also be noied. however, that the provisions of this Circular are intended for internal management purposes only and are

f

-

.

not intended to (1) create delay in the administrative process. (2) provide new

grounds for judicial review, or (3) create legal

rights enforceable against agencies or their

officers. The following policy guidelines are provided to assist and govern implementation

of the policy enunciated in paragraph 6. a . Reliance on Voluntary Standards. (1) Voluntary standards that will serve agencies' purposes and are consistent with applicable laws and regulations should be adopted and

used by Federal agencies in the interests of

greater economy and efficiency, unless they

are specifically prohibited by law from doing

so.

(2) Voluntary standards should be given

preference over non-mandatory Government

standards unless use of such voluntary standards would adversely affect performance or cost, reduce competition, or have other significant disadvantages.

Agencies responsible for developing Government standards should review their existing standards at least every five years and cancel those for which an adequate and

appropriate voluntary standard can be

substituted.

(3) ln'sdopting and using voluntary

standards, preference should be given to those based on performance criteria when

such criteria may reasonably be used in lieu of design, material, or construction criteria.

(4) Voluntary standards adopted by

Federal agencies should be referenced, along

with their dates of issuance and sources of

availability, in appropriate publications,

regulatory orders, and related in-house documents. Such adoption should take into account the requirements of copyright and

other similar restrictions.

(5) Agencies should not be inhibited, if within their statutory authorities, from

developing and using Government standards

in the event that voluntary standards bodies

cannot or do not develop a needed,

acceptable standard in a timely fashion. Nor

should the policy contained in this Circular be construed to commit any agency to the use

ol a voluntary standard which, after due

consideration, is. in its opinion, inadequate, does not meet statutory criteria, or is otherwise inappropriate.

b. Partic.nalinn in Voluntary Standards

3naies. ( 1 ) h.irticination by knowledgeable

agency employees in the standards activities

of voluntary standards bodies and standards- developing groups should be actively encouraged and promoted by agency officials when consistent with the provisions of paragraph 6b.

(2) Agency employees who. at Government

expense, participate in standards activities of voluntary standards bodies and standards- developing groups should do so as

specifically authorized agency

representatives.

(3) Agency participation in voluntary standards bodies and standards-developing groups does not. of itself, connote agency

agreement with, or endorsement of. decisions reached by such bodies and groups or of standards approved and published by

voluntary standards bodies.

(4) Participation by agency representatives should be aimed at contributing to the development of voluntary standards that will eliminate the necessity for development or maintenance of separate Government

standards.

(5) Agency representatives serving as members of standards-developing groups

should participate actively and on a basis of equality with private sector representatives.

In doing so. agency representatives should

not seek to dominate such groups. Active

participation is intended to include full involvement in discussions and technical debates, registering of opinions and. if selected, serving as chairpersons or in other

official capacities. Agency representatives

may vote, in accordance with the procedures

of the voluntary standards body, at each

stage of standards development, unless

specifically prohibited from doing so by law

or their agencies.

(6) The number of individual agency

participants in a given voluntary standards

activity should be kept to the minimum

required for effective presentation of the various program, technical, or other concerns

of Federal agencies.

(7) The providing of Agency support to a voluntary standards activity should be

limited to that which is clearly in furtherance

of an agency's mission and responsibility. Normally, the total amount of Federal support should be no greater than that of all private

sector participants in that activity except when it 13 in the direct and predominant

interest of the Government to develop a standard or revision thereto and its development appears unlikely in the absence

of such support. The form of agency support, subject to legal and budgetary authority, may

include:

(a) Direct financial support; e g., grants, sustaining memberships, and contracts:

(b) Administrative support; e g., travel costs, hosting of meetings, and secretarial functions:

(c) Technical support: e.g.. cooperative

testing for standards evaluation and

participation of agency personnel in the

activities of standards-developing groups; and

(d) Joint planning with voluntary standards

bodies to facilitate a coordinated effort in identifying and developing needed standards.

(8) Participation by agency representatives

in the policymaking process of voluntary standards bodies, in accordance with the

procedures of those bodies, is encouraged

particularly in matters such as establishing

priorities, developing procedures for preparing, reviewing, and approving

standards, and creating standards-developing'

groups. In order to maintain the private, nongovernmental nature of such bodies, however, agency representatives should

refrain from, decisionmaking involvement in the internal day-to-day management of such

bodies (e.g.. selection of salaried officers and

employees, establishment of staff salaries and administrative policies).

(9)

This Circular does not provide guidance

concerning the internal operating procedures

that may be applicable to voluntary standards bodies because of their relationships to agencies under this Circular. Agencies should, however, carefully consider what laws or rules may apply in particular instance because of these relationships. For example, these relationships may involve the Federal Advisory Committee Act. as amended (5 U.S.C. App. I), or a provision of an authorizing statute for a particular agency. Agencies are best able to determine what

laws and policies should govern particular

relationships and to assess the extent to which competition may be enhanced and

cost-effectiveness increased. Questions

relating to anti-trust implications of such

relationships should be addressed to the Attorney General.

8. Responsibilities, a. The Secretary will:

(1) Coordinate and foster executive branch

implementation of the policy in paragraph 6

of this Circular, and may provide

administrative guidance to assist agencies in implementing paragraph 8.b. (5) of this Circular.

(2) Establish an interagency consultative mechanism to advise the Secretary and

agency heads in implementing the policy contained herein. That mechanism shall provide for participation by all affected agencies and ensure that their views are considered: and

(3) Report to the Office of Management and

Budget concerning implementation of this Circular.

b. The heads of agencies concerned with

standards will:

(1) Implement the policy in paragraph 6 of

this Circular in accordance with the policy

guidelines in paragraph 7 within 120 days of issuance:

(2) Establish procedures to ensure that agency representatives participating in voluntary standaros bodies and standards- developing groups will, to the extent possible, ascertain tnc views of the agency on matters

of paramount interest and will, as a minimum, express views that are not inconsistent or in conflict with established

agenr.v views:

(3) Endeavor, when two or more agencies

participate in a given voluntary standards body or standards-developing group, to coordinate their views on matters of paramount importance so as to present, whenever ieasibie. a single unified position.

(41 Cooperate with the Secretary in carrying out his responsibilities under this Circular; and

8
Federal Resister / Vol. 47. No. 211 / Monday. November 1 . 1982 / Notices 49499

(5) Consult with the Secretary, as necessary, in the development and issuance

of. internal agency procedures and guidance

imolementina this Circular, and submit, in response to the request of the Secretary, summarv reports on the status oi agency

interaction with voluntary stancaras bodies.

9. Reoonmg Requirements. Three years from the date oi issuance oi this Circular, and

each third year thereafter, the Secretary will submit tc the Office of Management and

Budget a bnei summary report on tne status

of agency interaction with voluntary stancaros oodies. As a minimum, the report

will include the following information.

a. The nature and extent of aaency

particioation in the development and

utilization of voluntary standards: and

b. An evaluation of the effectiveness of the

policy promuiaated in this Circular and

recommendations of change.,

10. Policy Review. The pofkty contained in

this Circular shall be reviewea for effectiveness by the Office of Management

and Budget three years from the date of issuance.

11. Inquiries. For information concerning

this Circular, contact the Office of Management and Budget. Office of Federal Procurement Policy, telephone 202/395-7207. David A. Stockman.

Director. Department of Justice

Antitrust Division

Office of the Assistant Attorney General

June 22. 1982. Mr. Donald E. Sowle.

Administrator for Federal Procurement

Policy

Office of Management and Budget

Washington. D.C. 20503 Dear Mr. Sowie: I am writing to express the views oi the Deoartment of Justice on

comoetition policy issues raised bv the Revised OMB Circular No. A-119, "Federal

Participation in the Development and Use of Voluntary Standards" published for comment

in the Federal Register on April 29. 1982 (47 Fed. Reg. 16. 919). In our comments on previous drafts of the

Circular, dated December 26. 1976 and June

13. 1978. we have supported a policy of federal adoption of privately developed

standards when appropriate. Through

participation in. and support for. private standards making activities, agencies may

benefit greatly from private expertise and

will avoid the wasteful duplication of cost and effort involved in developing their own

in-house standards. The Department of

Justice is not opposed to the policy announced in Revised OMB Circular A-119,

which would eliminate the ri 2 id "due

process" preconaition to federal participation

in private standards activities. Sucn a precondition is overly restrictive, since as a practical matter federal agencies will often be required to adopt the standards developed

regardless of federal participation in their deveioDment. Thus, in our view, me better solution is lo participate in stancards setting bodies and work within them to assure that appropriate procedures are adopted.

The Department believes that federal

participants should encourage the adoption of procedures to foster access to standard

setting activities and transparency in such

activities. Such procedures facilitate the deveiopment of standards acceptable to the

entire affected industry as well as to consumers. In particular, notice and

opportunity for comment help assure that standards will be based on adequate

information as to their utility and

consequences. Moreover, it is especially

important that performance criteria be given

a prominent, perhaps predominant, place in any stancards activity. Federal agency

representatives, therefore, should advocate,

as stroneiv as possible, procedures designed

to assure that a broad range of information is solicited, and that performance criteria are

central elements of the resulting standards.

In addition to the practical advantages of open standards proceedings, such safeguards

would mitigate the substantial anticompetitive potential inherent in private standards groups. The importance of assuring

adequate consideration of competition in the work of private standards bodies was noted

recently by the Supreme Court in American

Society of Mechanical Engineers. Inc. v. Hydrolevel Gorp. The case involved a product standard which had been adopted in 46 states and ail but one of the Canadian

provinces. The Court observed that organizations creating such standards could be “rife with opportunities for anticompetitive activity.” Federal agencies

ought to strongly encourage these private groups to ensure consideration of all relevant viewpoints and interests including those of consumers, and potential or existing industry

participants. This country's international obligations and policy, as expressed in the Standards Code negotiated during the Tokyo Round of

the Multilateral Trade Negotiations, see the Agreement on Technical Barriers to Trade,

codified at 19 U.S.C.A. 2531 et seq. (1930), provide another important reason for federal agency participants to encourage the adoption of open procedures for private standards groups. This Code, approved by

Congress as well as by our leading trading

partners, seeks to prevent the creation of product standards which discriminate against

import competition. It requires central governmental bodies to provide notice and

opportunity to comment in their own

* standards making activities, and encourages governments to take reasonable measures to ensure that non-governmental bodies provide

similar protection. Where the federal government is in fact involved in the private group, the obligations of the Standards Code

wouid appear even stronger. Open

procedures, specificaiiv adequate notice and

opportunity to comment, would further the objectives of the Standards Code, and would

substantially reduce the possibility that discriminatory, anticompetitive standards

will be developed.

The Circular would encourage use of voluntary standards for reeulatorv and other purposes. Although we appiaud tms

expansion of the scope oi the Circular, we

believe that broadened federal use oi privately developed standards snould be

accompanied with broad fpderal awareness

of the practical and competitive advantages

of industry-wide access to private standards

bodies. Such access is an asset to federal

participation in private standards activities, but it is also of great importance when

federal agencies, without participation in the process, merely adopt standards for procurement or regulatory use. As we indicated in our previous comments,

private activity is not. by virtue of governmental participation or approval,

shielded from the antitrust laws. Federal agency participation in a standards body,

however, may imply federal approval of the process and of the resulting standard, and

pernaps lead private participants to become

lax in their own antitrust scrutiny. To dispel any false impressions, federal agency

representatives should inform private

participants that federal participation does - • not remove antitrust concerns, as well as advocate that appropriate procedures be employed in the standards proceeaings.

Sincerely yours. Ronald G. Carr, Acting Assistant A ttorney Ceneral. Antitrust

Division.

|FR Doc. 82-30017 Filed 10-29-82: 8:45 «m|

BILL! MG CODE 3110-01-*!

9

APPENDIX B

Administrative Manual Subchapter 3.02

"Standards and Professional Committees"

11
U. S. Department of commerce

NATIONAL BUREAU OF STANDARDS Chapter 3 Committees

ADMINISTRATIVE MANUAL Subchapter 3.02 Standards and Professional

Committees

STANDARDS AND PROFESSIONAL COMMITTEES

Sections

3.02.01

3.02.02

3.02.03

3.02.04

3.02.05

3.02.06

3.02.07

3.02.08

3.02.09

3.02.10

3.02.11

Purpose

Scope

Definitions

Policy

Recognized Types of Committee Participation

Appointment Procedures

Responsibilities

Approval Procedures for Acceptance of Standards

Committee Secretariat Functions

Approval Procedures for Accreditation as a Standards Developer

Funding

N8S Committee Assignment Recording Officers

3.02.01

PURPOSE

This subchapter establishes policies and

procedures for the acceptance and

maintenance of membership on government and

nongovernment standards and professional

committees working in areas related to the

activities of the National Bureau of

Standards. In the case of standards

committees, these policies are consistent

with Federal policy guidelines for

participation in the development and use of

voluntary standards as set out by the

Office of Management and Budget (0MB) in

0MB Circular A-119 and Department

Administrative Order (DAO) 216-14.

3.02.02

SCOPE

a. The policies and procedures in this

subchapter apply to employees at NBSGaithersburg and NBS-Boulder.

b. This subchapter covers standards and

professional committees which may be

national or international in scope.

3.02.03

DEFINITIONS

a. Committee - Any board, commission,

council, conference, panel, task force.

or other similar group or any subcommittee

or other subgroup thereof.

b. Standard - A prescribed set of rules,

conditions, or requirements concerned with

the definition of terms; classification of

components; delineation of procedures;

specification of dimensions, materials,

performance, design, or operations;

measurement of quality and quantity in

describing materials, products, systems,

services, or practices; or descriptions of

fit and measurement of size.

c. Standards Committee - Any governmental

or nongovernmental committee that exercises

policy control over standard activities or that is principally concerned with the

administration of standards programs or the

development, approval, or promulgation of

standards. This includes, for example, all

committees of the American Society for

Testing and Materials (ASTM), as well as standards coranittees of professional and

scientific organizations such as the

Institute for Electrical and Electronics

Engineers (IEEE) and the American Nuclear

Society (ANS).

d. Professional Committee - Any committee,

other than a standards committee, which is

concerned with the accomplishment of

professional, technical, or scientific

objectives.

November 13, 1984

(Trans. 527) ] 2 3.02.01 - 3.02.03
Standards and Professional

Committees

- 2 - 11-13-34

(Trans. 527)

e. National Committee - Any committee

functioning under the jurisdiction of a United States organization or a United

States Government agency. Included under

this definition are national committees

with major international responsibilities,

such as the U.S. National Committee for the

International Electrotechnical Commission

(IEC), American National Standards

Institute (ANSI) technical advisory groups

for committees of the International

Organization for Standardization (ISO), and

the U.S. Advisory Committee for

International Legal Metrology (ACILM).

f. International Committee - Any committee

functioning under the jurisdiction of an international organization (governmental or nongovermental) such as the International

Organization for Standardization (ISO), the

International Electrotechnical Commission

(IEC), the International Union of Pure and

Applied Chemistry ( IUPAC) , the International Organization of Legal Metrology

(OIML), and the International Committee of

Weights and Measures (CIPM).

3.02.04

POLICY

NBS policy encourages and supports

participation of the professional staff in

professional committee activities relating

to the scientific and technical mission of

the Bureau and in national and international standards committee activities when

such participation is in the public

interest and is compatible with the

Bureau's mission, authorities, priorities,

and budget resources. NBS employee

participating in standards and professional

committee activities relating to the

professional basis of their employment

carry an inseparable identification with

the Bureau. For this reason, they have a fundamental obligation to avoid actions

that are inconsistent with established

policies and programmatic objectives of

NBS, DoC, and the Administration. However,

participation in such committees by

employees does not, of itself, connote NBS

agreement with or endorsement of decisions

reached by such groups or of standards

approved and published by voluntary

standards bodies.

NBS Administrative Manual

3.02.05

RECOGNIZED TYPES OF COMMITTEE PARTICIPATION

a. Approval may be given to an employee to work on standards and professional

committee assignments:

(1) By reason of individual

professional and technical expertise, or

(2) By reason of management or program

responsbilities within the Bureau, which

may justify participation on boards of

directors or similar policy-making bodies

of standards or professional organizations.

b. Employees are authorized to serve as full voting members or officers of committees, boards of directors, or similar

policy-making bodies of standards and

professional organizations unless specifically prohibited from doing so. However,

in order to maintain the private nongovernmental nature of standards-developing

organizations, NBS participants on boards

of directors or policy-making bodies shall

refrain from decision-making involvement in

the internal day-to-day management of

standards-developing organizations (e.g.,

selection of salaried officers and

employees, establishment of staff salaries

and administrative policies).

3.02.06

APPOINTMENT PROCEDURES

The employee is responsible for taking the

following actions for each requested

committee assignment:

a. Complete Form NBS-83, Record of

Committee Assignment.

b. Submit Form NBS-83 (original and two copies) to the division chief (or higher

official as appropriate) for approval.

Note : Employees invited to participate in boards or other policy-making bodies of

professional or standards organizations

must additionally submit Form NBS-83 for

approval to the NBS Director through the

Office of Product Standards Policy (OPSP) . The request should include the employee's

recommendation as to voting or nonvoting

status of participation.

3.02.04 - 3.02.06

13
Standards and Professional

Committees

-3- 11-13-84

(Trans. 527)

c. Following approval, send Form NBS-83

(original and two copies) to Standards

Assistance and Management Information,

Standards Management Program (120).

d. Complete and return any forms that may

be required by the outside committee or parent organization.

3.02.07

RESPONSIBILITIES

a. Committee Participants

(1) Initiate appointment procedures

(see Section 3.02.06);

(2) Ensure that Form NBS-83 is up to date for each committee assignment;

(3) Submit committee documents to the

NBS Editorial Review Board (Gaithersburg or Boulder) for notation and review, if the

documents name an NBS employee as a principal author and the documents are intended for publication or distribution

outside the committee. This requirement

applies even when the documents will not be

issued as NBS publications. Likewise,

submit portions of committee documents that

refer to NBS data not previously published

to the NBS Editorial Review Board. If any

special or extensive testing or other

experimental work is undertaken for a committee in Bureau laboratories, such work

would be considered for summarization in an NBS report or other publication;

(4) Ensure that questionnaires receive

required clearance, if any. Questionnaires

sent outside the Government by NBS members

of committees must be cleared by the Office

of Management and Budget if there are to be

10 or more respondents other than members

of the committee or organization in whose

name the information is being gathered, and

if:

(a) The name of the National Bureau

of Standards appears on the form as a sponsor of the inquiry; or

(b) NBS is to be the publisher or user of the results of the survey; or

NBS Administrative Manual

(c) The committee is sponsored by

NBS or by another Government agency, even though NBS or the other Federal agency may

not be identified on the questionnaire

itself

.

The Management Systems Division (348)

offers assistance and arranges for required

clearances

.

(5) Ensure that no conflict of interest

is involved in their committee appointments; and

(6) Maintain complete records of

committee documents relating to NBS

involvement with that committee, including

records of all NBS participants' votes on committee ballots.

b. Division- Chief (or higher official)

(1) Ensures that the activity is

directly related to the authorized

functions of NBS and in line with program

objectives;

(2) Ensures that Che proposed appointee

is qualified and can devote enough time and

effort to serve creditably;

(3) Ensures that resources (including

funds for travel and per diem) are available or in prospect to support

necessary participation;

(4) Ensures that the number of

individual agency participants in a given

activity is kept to Che minimum required

for effective presentation of NBS concerns;

(5) Ensures that records of committee

documents and ballots as prescribed in

paragraph 3.02.07a. are maintained within

the organizational unit and are readily

available for inspection; and

(6) Reviews committee assignments

periodically to determine if participation

is still appropriate.

3.02.07

14
Standards and Professional

Committees

-4- 11-13-84

(Trans. 527)

c . NBS Office of Product Standards Policy

(1) Monitors committee assignments to ensure that participation of NBS employees

is properly authorized and consistent with

NBS policy as set forth in Section 3.02.04;

and

(2) Submits annually to NBS center

directors a report on staff participation

in standards activities.

d . NBS Standardization Advisory and

Coordination Committee (SACC)

(1) Advises the NBS Director and MOU

Directors on Bureauwide issues relating to NBS participation in standardization

activit ies

;

(2) Provides Bureauwide representation

in the development of recommendations for

NBS standards policies and procedures; and

(3) Assists the NBS Director and MOU

Directors to ensure that NBS standards

participation is effective and efficient.

(See Subchapter 3.01 Appendix A for

additional responsibilities and functions

of the SACC.)

3.02.08

APPROVAL PROCEDURES FOR ACCEPTANCE OF

STANDARDS COMMITTEE SECRETARIAT FUNCTIONS

a. NBS organizational units may assume secretariat responsibilities for national

and international standards committees and

their subgroups and may serve as Administrators of U.S. Technical Advisory Groups

providing input to international standards

committees. However, in accepting such

functions, NBS units should not automatically assume final responsibility for

ensuring that all appropriate procedures

are followed in the standards development

process, but should seek to persuade the

sponsoring parent organization to retain

this responsbility . The MOU Director or

a designee should effect an agreement

within the organization that assumes responsibility for ensuring that all

appropriate procedures are followed.

b. If acceptance of the secretariat is considered necessary to the accomplishment

NBS Administrative Manual

of NBS objectives and if no reasonable

sponsor or cosponsor will accept the

responsibility for assuring due process

procedures, the NBS unit may take the

responsibility upon approval by the NBS

Executive Board. Proposals for NBS acceptance of standards committee secretariat

functions are to be submitted through line

management to OPSP for policy review prior

to submission to the NBS Executive Board

for approval.

3.02.09

APPROVAL PROCEDURES FOR ACCREDITATION AS A STANDARDS DEVELOPER

NBS organizational units may seek

accreditation as an American National

Standards developer if such accreditation

is considered to be essential to accomplish

NBS objectives. Since ANSI procedures

require the standards developer to provide

evidence of conformance to due process

requirements, proposals for accreditation

of NBS units as American National Standards

developers are subject to approval by the

NBS Executive Board. Proposals for

accreditation are to be submitted through

line management to OPSP for policy review

prior to being submitted to the NBS

Executive Board for approval.

3.02.10

FUNDING

a. Overhead funds and appropriated funds

(STRS and OA) may not be used for the

payment of committee membership fees or dues of officers and employees of the

Government (5 U.S.C. 5946).

b. When an employee participates in standards and professional committees with

NBS approval, the cost of participation

is normally paid by NBS. Expenses involved

with attendance at meetings are paid by NBS

in accordance with DAO 204-1, Chapter 16 of

the NBS Administrative Manual , the DoC

Handbook of Travel Policies and Procedures , and the Federal Travel Regulations. If committee activities are performed for the

benefit of another agency, it is appropriate for committee-related travel

expenses to be charged to that agency.

3.02.08 - 3.02. 10

15
Standards and Professional

Committees

-5- 11-13-84

(Trans. 527)

c. Committee memberships and officerships

in professional organizations which involve

use of official time should pertain to research, development, testing, standardization, symposia, or administrative work

of direct interest to the Bureau. In order

to warrant the charging of time and

expenditures to technical cost centers,

committee activities must be closely

related to those cost centers.

d. Where the committee assignment involves

travel costs to be financed by an outside

group, the employee must obtain a Bureau

travel order that either (1) authorizes

acceptance of transportation and

accommodations in kind, or (2) is charged

to the appropriate cost center to which the

reimbursement check will be credited. In neither case may the employee accept

monetary reimbursement for travel expenses

while in duty status since the authority to receive gifts and other reimbursements is limited to the Bureau as an organization

and cannot be extended to an employee.

Advice can be obtained from the NBS

Comptroller on procedures for accepting

funds as payment to the Bureau.

e. It is usually inappropriate for the

Bureau to take an institutional membership

in a private organization. This policy is applicable at all organizational levels

within the Bureau. Requests for exceptions

to this policy should be sent to the NBS

Director through the Chairperson of the

Standardization Advisory and Coordination

Committee. Exceptions will be granted only

with the approval of the NBS Executive

Board. See Subchapter 3.03 for information

on approvals required for payment of

institutional membership fees to voluntary

standards bodies.

Currently approved exceptions are the

Bureau's institutional memberships in the

American Society for Testing and Materials

(ASTM); the American National Standards

Institute (ANSI); the National Committee

for Clinical Laboratory Standards (NCCLS);

the International Council for Building

Research, Studies, and Documentation (CIB);

and the International Union of Testing and

Research Laboratories for Materials and

Structures (RILEM).

3.02.11

NBS COMMITTEE ASSIGNMENT RECORDING OFFICERS

a. The Management Systems Division (348) serves as the NBS Liaison Office to the

Department of Commerce for all committee

matters.

b. Standards Assistance and Management

Information, Standards Management Program

(120) serves as the NBS Standards and

Professional Committee Monitoring Office.

NBS Administrative Manual 3.02.11

16
APPENDIX C

Administrative Manual Subchapter 3.03

"Payment of Fees for Private Voluntary Standards Activities"

17
U. S. Department of Commerce

NATIONAL BUREAU OF STANDARDS ADMINISTRATIVE MANUAL

Chapter 3 Committees

Subchapter 3.03 Payment of Fees for Private

Voluntary Standards Activitie

PAYMENT OF FEES FOR PRIVATE VOLUNTARY STANDARDS ACTIVITIES

Sections

3.03.01 Purpose

3.03.02 Scope

3.03.03 Definitions

3.03.04 Policy

3.03.05 Responsibilities

3.03.06 Collection of Fees

Appendix A - Standard Language for Adtainistrative

Service Fee Contracts

Appendix B - Collection of ASTM Fees

Appendix C - Collection of ANSI Fees

3.03.01

PURPOSE

This subchapter states NBS policies and

internal procedures for payment of fees in

support of NBS participation in private

voluntary standards activities.

3.03.02

SCOPE

The policies and procedures in this

subchapter apply to NBS-Gaithersburg and

NBS-Boulder.

3.03,03

DEFINITIONS

a. Private Voluntary Standards Bodies - Private sector domestic or multinational

organizations (such as nonprofit organizations, industry associations, professional

and technical societies, institutes, or groups, and recognized test laboratories)

that plan, develop, establish, or coordinate voluntary standards.

b. Fees

(1) Institutional Membership Fees (also

referred to as ^organizational" or "sustaining 11 membership fees) - Fees paid

for the purpose of obtaining institutional

representation in a voluntary standards

body. Such fees are intended to be used in

support of the organization's general

standards-related objectives and programs

(i.e., education activities intended to publicize the societal benefits of standardization activities and professional

awards programs which provide recognition

of individual accomplishments in the field

of standardization). An institutional

membership usually provides for voting

privileges exercised by a representative

officially designated by the organization.

An NBS institutional membership in a standards body signifies only that NBS

endorses the stated purposes of the standards body and that membership is deemed

appropriate and necessary in carrying out

the mission of NBS. Such membership does

not signify that NBS endorses or supports

positions taken by the standards body on any subject or issue. An NBS institutional

membership in a standards body does not confer individual membership rights or privileges on any member of the NBS staff.

(2) Administrative Service Fees - Fees

paid to help cover costs associated with

standards committee operation and

communication, e.g., preparation and

distribution of minutes, circulation of

July 8, 1983

(Trans. 490)

18

3.03.01 - 3.03.03
Payment of Fees for Private

Voluntary Standards Activities

- 2 - 7-8-S3

(Trans

.

drafts for comment, meeting arrangements,

and maintenance of committee records.

Payment of such fees does not confer

individual membership rights or privileges

on any member of the NBS staff nor result

in NBS being recognized as an institutional

member of the standards body.

(3) Individual Membership Fees - Fees

paid to standards bodies for the purpose of

obtaining membership rights or privileges

for individuals.

3.03.04

POLICY

a. Federal agencies cannot use appropriated funds to pay individual

membership fees either directly or indirectly (e.g., where purchase of a society journal would confer membership

status on an individual) to voluntary

standards bodies (5 D.S.C. 5946).

b. Administrative service fees may be paid

by NBS organizational units if the payment

of such fees is required by a voluntary

standards body in order to serve on a committee(s) of that body and if the MOD

Director or designee determines that

service on that committee(s) is essential

to the achievement of NBS goals and

objectives. Contracts, agreements, and

letters of intent relating to the payment

of these fees must include the language

given in Appendix A.

c. Payment of institutional membership

fees must be approved by the NBS Director.

d. NBS employs a decentralized system for

managing the participation of NBS representatives in external standards committee

activities (see Subchapter 3.02). Participation is monitored by the Office of

Product Standards Policy (120). Policylevel questions relating to NBS standards

activities are reviewed by the Standardization Advisory and Coordination

Committee

.

3.03.05

RESPONSIBILITIES

a. NBS Director - Approves the NBS

institutional membership and initial

NBS Administrative Manual

payment of fees to private voluntary

standards bodies. Requests for apprrval :t NBS institutional memberships and

to pay institutional membership fees

be sent to the Director through the

Chairperson of the NBS Standardization

Advisory and Coordination Committee.

b. MOU Directors - Approve payment of

administrative service fees to private

voluntary standards bodies.

c. Center Directors - Annually review

lists of staff participation in standards

activities for appropriateness, indicating

changes planned for the next calendar yea:,

d . Director,' Office of Product Standards

Policy - Maintains information on NBS staff

participation in standards conmittees and

activities in conjunction with operation of

the NBS Standards Assistance and Management:

Information project; and provides currer:

lists of NBS participants on standards

committees to appropriate NBS organizational units for verification and review.

e. Standardization Advisory and

Coordination Committee - May select policvlevel issues relating to payment of fees to review or will consider such issues

referred by the NBS Director, MOU

Directors, or the Executive Board.

3.03.06

COLLECTION OF FEES

With the exceptions noted in the appendixes

to this subchapter, organizational units

are responsible for paying applicable fees

for standards committee activities direct!;/

to the organizations concerned after

obtaining all required approvals. Copies

of all contracts, purchase orders, or other

correspondence regarding payment of administrative service fees or institutional

membership fees to standards bodies should

be sent to the Director, Office of Product

Standards Policy, who maintains records on NBS expenditures related to standards

committee activities.

19 3 . 03.04 - 3 . 03.06
\
APPENDIX D

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APPENDIX E

Federal Register - February 15, 1984

"Guidelines for Participation by U.S. Government Agencies, Employees or Representatives in International Standards-Related Activities"

27
Wednesday

February 15, 1984

Notice

National Bureau of Standards

Guideline Documents Implementing

Federal Standarda Policy

AGENCY: National Bureau of Standards. Commerce.

action: Notice of Guideline Documents

Implementing Federal Standards Policy.

SUMMARY: The purpose of this notice is to announce the approval by the Secretary of Commerce of three guideline documents that have been

developed by the Interagency

Committee on Standards Policy. These

documents implement various aspects of

the Federal Standards Policy as set out

in Office of Management and Budget

(OMB) Circular A-119, dated October

26. 1982. The Interagency Committee on

Standards Policy (ICSP) was established by the Secretary of Commerce under

Section 8.a.(2) of OMB. Circular A-119. The three guidance documents

developed by the ICSP are set out in their entirety at the conclusion of this notice. The first document establishes "Guidelines for Participation by U.S. Government Agencies, Employees or
Federal Register / VoL 49, No. 32. / Wednesday* Fefeniary 15, 1984 / Notices 5793

Representatives in. International Standards-Related Activities." Section 1

of this document applies to participation

in international organizations in which

the U.S. Government is the official U.S. member body. Section 2 of this document applies to participation in international organizations in which the

U.S. Government is not the official U.S. member body.

The second document establishes

"Guidelines for Federal Agency Use of

Private Sector Third-Party Certification Programs.” The third document provides

"Guidelines for Federal Agency Use of

Self Certification by Producer or

Supplier." These latter two documents

are generally applicable to agency

procurement and regulatory programs

that require statements of conformance

to specific standards or specifications.

Comments and questions- concerning

these guidelines should be directed to

Dr. Stanley I. Warsftaw, Director, Office

of Product Standards Policy, National Bureau of Standards, Washington, D.C.

20234, (301-021-37511. Dr. Warshaw is the Chairman of the Interagency

Committee on Standards Policy. Dated: February 0, 1984. Ernest Ambler,

Director. National Bureau ofStandards. Guidelines for Participation by U.S. Government Agencies, Employees, os Representatives in International Standards-Related Activities Introduction

The important role that standards*

related activities have played

throughout the whole fabric of national

and international economic activities

lias received increased recognition in recent years. Standards have

consolidated and extended the application of technology, helped to conserve scarce resources, improved

industrial efficiency, enhanced the general welfare of the public, promoted

commerce, and generally improved

communication and understanding

among the drafters and users of standards. In particular, governments

have been giving more attention to the

part played by standards as technical

barriers to trade. If improperly

conducted, international standards

activities can suppress free and fair competition, impede innovation and

technical progress, exclude safer and

less expensive products, or otherwise

adversely affect domestic and

international commerce. The role and functions of U.S. Government agencies, employees, and

representatives in international

standarda-related-activities have not been clearly defined- Consequently, the

interpretation of that role has varied

among Federal agencies, the private

sector, and fhreiga countries. Other

factors have ako prompted the need to establish uniform Federal guidelines in the international standards area, notablyD

1. The increasing tendency of governments, to regulate er procure by

"reference to standards’’;,

2. The growing impact of national

standards span domestic and

international commerce;

3. Current international activity aimed

at preventing barriers to trade that arise; from differing nstkssal. mandatory and

voluntary standards, including

heightened interest in the development

of international standards and theis subsequent national adoption,' mid

4. Ae expressed desire by several U.S. Government agendas for such

guidelinesA recent US. development covering

the subject of standardization gives

further impetus, for the development of

guidelines covering Federal

participation in international standardization activities:

• Trade Agreements Act of 1979, Title IV—Technical Barriers to Trade

(Standards), effective January 1, 1980. Section 413 of that Act deals specifically

with representation of U.S. interests before international standards

organizations. Regarding private

international organizations, this section

recognizes the role of US. private sector members of such organizations and

gpants the Secretaries of Commerce and

Agriculture authority, under certain

circumstances, to provide for adequate

U.S. representation in those private international standards organizations

through the US. member bodies. Regarding representation of U.S.

interests by Federal agencies, Section

413(c) encourages cooperation among

Federal agencies regarding the development of uniform positions, and

encourages such Federal agencies to seek information from and to cooperate

with domestic US. interests. Paragraph

2.3 of the international Standards

Agreement itself calls upon parties (e.g., the US. Government) to "play a full part

within the limits of their resources in the preparation by appropriate international standardizing bodies of international standards for products for which they

have either adopted, or expect to adapt,

technical regulations or standards." The recent and rapid expansion of international cooperation in trade- and

defense emphasizes the need for

effective government involvement in the development of acceptable international standards (including test methods and

certification) and requires that the limited U.S. Government resources

contributing to such standards be

expended effectively through efficient Government representation in and

coordination with international standards organizations. These

guidelines provide direction for strengthening such efficiency and

effectiveness. Accordingly, the aim of

this document is to provide guidance to U.S. Government agencies, employees,

and representatives who participate in: (a) ^International organizations in which the U.S. Government is the

official U,S. member body (commonly

called intergovernmental organizations?,

e-g.. International Organization of Legal

Metrology (OIML).

(b) International organizations in

which the US. Government is not the

official US. member body and where

the United States is represented by a

domestic private sector organization

that is recognized by a private

international organization as the U.S. member body, e.g., International Organization for Standardization (ISO)

and International Electrotechnical

Commission (ZEC), where the U.S. member body is the American National

Standards Institute (ANSI).

Although the two types of organizations are treated separately in these guidelines, such guidelines are uniform by being applicable to both

types to the maximum extent possible.

These guidelines cover not only

Federal participation in international conferences and meetings, but also

participation in the development of US.

positions in preparation for these conferences and meetings.

The application of these guidelines

will vary from time to time and from

committee to committee according to the end-use of a standard. Much will depend on whether the international standard under development is to be

considered for reference in regulations

and, if so, whether compliance with its provisions is likely to be mandatory,

and whether there are relevant existing or proposed national or international requirements. These and similar considerations will influence the role of the U.S. Government representatives

participating in standards-developing

groups. This document is intended to help ouch representatives discharge

their responsibilities while promoting

the development of reasonable and

effective international standards.

29
5794 Federal Register / Vol. 49, No. 32 / Wednesday, February 15, 1984 / Notices

It should be noted that individual U.S. Government departments may, in order

to cover special interests, issue . supplementary instructions to their representatives. Where possible, these

instructions should be compatible with

the principles contained in these

guidelines. Attached to these guidelines

is a list of Federal agency contact points on international standardization. Glossary

Accredited—Official authorization to serve as a member of a delegation to an

international standards-related activity.

Delegation—Representatives of a nation or member-body empowered to act at an international standards-related

meeting.

Delegate—An accredited member of a

delegation.

Head of Delegation—The person

responsible for guiding the delegation at the international meeting and presenting

the U.S. position.

Representative—An individual designated by a Federal agency as its official participant in international standards-related activities and/or

development of U.S. positions thereon. Principal Representative—The

Federal representative designated to act as the primary U.S. Government

spokesperson and coordinator when two

or more Federal agencies participate in an international standards-related

activity. The principal representative

may function also as head of the delegation. International Standards or StandardsRelated Activities or Organizations—

Includes standards, testing, and

certification. Lead Agency—A Federal agency

which assumes responsibility for effective U.S. Federal representation in the International standards-related matter concerned.

Technical Offices Department of Commerce

Technical Office for Implementation

of Title IV of Trade Agreements Act

/

1979: Office of Product Standards Policy,

National Bureau of Standards, U.S. Department of Commerce, Washington,

D.C. 20234. Department ofAgriculture

Technical Office, Trade Relations

Division, International Trade Policy,

Foreign Agricultural Service, U.S. Department of Agriculture, South

Agriculture Building, Washington. D.C.

20250.

Section I—Guidelines for Participation

by U.S. Government Agencies,

Employees, or Representatives in International Standard-Related

Organizations in Which the U.S. Government is the Official U.S. Member

Body

Subsection A. Delegation Accredited by

U.S. Department of State

1. Scope. Subsection A applies only to international conferences, which are defined as meetings of three or more

governments whose representatives are formally accredited by their governments to the sponsoring

international organizations or host government. When this is the case, the

U.S. delegation represents the U.S. Government as a whole. Such meetings

may result in a formal commitment(s) by

the U.S. Government of a policy nature. Subsection A does net apply to bilateral discussions or meetings of subsidiary

international bodies which are intended

to produce only recommendations to.ff higher authority of the organization

concerned, and whose subject-matter is predominantly technical (in contrast to policy). The final arbiter as to whether

or not a. particular meeting meets the

definition of an international conference

(i.e., whether it falls under Subsection A

or Subsection B) rests with the Office of International Conferences, U.S. Department of State.

2. Lead Agency. The U.S. Federal agency having primary responsibility or authority for the subject matter of the meeting normally is designated by the Department of State as lead agency. In cases where such primacy is not clear or

is in dispute, the Department of State determines the lead agency. The lead •agency should assume responsibility for U.S. preparations to the conference, assure that nominations for the delegation reach the Office of International Conferences in a timely

fashion, and take responsibility for die

effective representation of U.S. interests

in the matter concerned.

3. Nomination and Accreditation of

Delegation. The delegation should be

proposed to the Office of International Conferences (OIC), U.S. Department of

State by the lead agency or by an

Interagency committee headed by the lead agency. The Office (OIC)

recognizes that particularly in standards

matters and effective representation

therein, experience and continuity of participation are important

considerations in the composition of delegations. Each person proposed for delegation membership including the

U.S. representative (head of delegation),

alternate, government advisors, and

private sector advisor?, as appropriate,

will be justified on the basis of his or her

essentiality to the work of the

delegation. Because the delegation will represent the United States Government

as a whole and will be instructed on

U.S. positions on all major points, each

interested agency need not have a representative on the delegation. OIC

exercises delegated Presidential authority in accrediting U.S. delegations. Final decisions on the size and make-up

of delegations including the resolution of any interagency differences thereon will be made by OIC.

4. Development of U.S. Positions. It is the responsibility of the lead agency to insure that a position paper is drafted on

each relevant agenda item and that these papers are properly coordinated

and cleared. In the discretion of the lead

agency, U.S. positions may also be. drafted on points which do not appear on the official agenda.

5. Coordination Outside of Government. The lead agency should

seek the advice of person and

organizations outside the U.S. 'Government whose interests may be

materially affected by the subject-matter

of the conference, especially U.S. trade

interests. Such advice should be

solicited in writing or through meetings

prior to the development of the U.S.

position.

6. Intra-government Coordination. It is the responsibility of the lead agency to insure that all interested government

departments and agencies have the opportunity to review proposed U.S. positions and to resolve any differences which may occur prior to the

international conference. It is the responsibility of the head of the- delegation to insure that all members of

the delegation are fully acquainted with

the U.S. position and that they maintain necessary conformity therewith

regardless of differences which may

have existed previously.

7. Report of Delegation. The head of

the delegation is responsible for preparing and submitting to OIC a final report on the meeting in accordance

with instructions from OIC. That report

should be made available by the head of the delegation to all members of the delegation and, if unclassified, to any

interested party. Wherever possible,

reports should be unclassified. Where

security classification is necessary, only

that portion of the report which merits

classification should be so classified and indicated as such (see Executive

Order 12356). When international trade

is involved, the head of the delegation

should transmit a copy of the report

promptly to appropriate agencies < a

organizations, including fie Dope I nf:

30
Federal Register / VoL 49, No. 32 / Wednesday, February 15. 1984 / Notices 5795

of Commerce's Technical Office for implementation of Title IV of the Trade

Agreements Act of 1979 on matters

relating to non-agriculture products, and

to the Department of Agriculture’s

Technical Office for implementation of

Title IV on matters concerning

agricultural products. Recommended

contents of the report are:

a. Results of meeting in terms of U.S.

objectives, including issues which were

discussed but which did not appear on

the agenda, if any:

b. Matters for further U.S. action or consideration, especially significant

problem areas which may affect U.S.

trade:

c. Information on future meeting(s), if available; and

d. Implications, if any, for U.S. export

prospects and for competition in domestic markets. Subsection B. Delegations Not

Accredited by U.S. Department of State

1. Scope. These guidelines apply to all participation by U.S. delegations in standards-related meetings of international organizations in which the

U.S. Government is the official U.S. member body, except those in which the

U.S. Department of State accredits the U.S. delegation, in which case

Subsection A shall apply.

2. Lead Agency. The Federal agency

having primary responsibility for U.S. participation in the international organization under whose auspices the meeting is to be held is responsible for assuring adequate U.S. participation at the meeting. In the case of planned

meetings (e.g., topical conferences,

symposia) which are not under the auspices of a single international organization, the U.S. Government

agencies having interests in the subject matter should cooperate in deciding

which will act as lead agency. The lead

agency should inform the relevant “Technical Office” of the Department of Commerce or Agriculture, as

appropriate, of standards meetings

whose outcome may affect U.S. trade.

3. Meeting Preparations. The lead agency is responsible for coordinating me many details involved in preparing

for U.S. participation in international standards-related meetings. It is incumbent on the lead agency to take all reasonable steps to: assure adequate

funding of the U.S. delegation; obtain necessary clearances (travel or otherwise); and, instruct the delegation

in its responsibilities and duties.

3.1

Formation ofDelegation. The

lead agency is normally responsible for formation of the delegation and for the

specific assignments of work to the delegation. In carrying out these

responsibilities the following points

should be taken into consideration:

3.1.1 Size ofDelegation. The lead

agency should use sufficiently selective

criteria to ensure that the size of the delegation is justifiable in terms of the importance of the meeting to U.S. national interests.

3.1.2 Balanced Representation. The

composition of the delegation requires

careful consideration and planning. In selecting the delegation, the lead agency

should take into consideration: The

nature and purpose of the meeting: the possible impact of the meeting's results: the use of qualified women and

minorities; and, the interests of all parties that may be substantially affected within the United States. In those cases where the meeting may

result in technical requirements or standards which may measurably affect trade, or which may be adopted as law

or regulation within the United States, it is particularly important to seek

representation on the delegation from

the affected community (e.g., industry, other Federal agencies, State and local gqvemments, labor, universities,

consuming public). The lead agency may

find that while there is interest in participation in the delegation by such

groups, they may lack the necessary

funds to do so (particularly to pay for international travel). In such cases a balanced U.S. viewpoint can often still be achieved by having all interested

parties participate in preparatory

meetings held to review, comment on, and agree on positions to be taken by

the delegation during the international meeting.

3.1.3 Head of Delegation. In making

its selection the lead agency should

ar^oint as head of delegation an able negotiator who is: Experienced in the subject matter of the meeting; familiar with the policies and procedures of the international organization sponsoring

the meeting; and, capable of maintaining

harmony within the delegation.

3.1.4 Accreditation of Delegation.

Once the composition of the U.S. delegation has been decided, the lead agency is responsible for satisfying any

requirements imposed by the relevant

international organization as regards

accrediting or advanced notice of

delegations. Generally, sponsors of

international intergovernmental

meetings request advance notification of

participation. Every effort should be

made by the lead agency to respect such

requests in a timely fashion. Often, a simple letter of appointment to each

delegate serves many useful purposes even when not required. For example, a

letter of appointment is often useful in

justifying participation in a standards

meeting to higher management. 3.1.5 Continuity of Delegation. In recognizing that the effectiveness of a delegation i3 enhanced by the long-term

continuity of participation by particular

delegates, the lead agency should

endeavor to provide and maintain that

continuity.

3.2 Preparation ofPosition Papers.

While it is advantageous to prepare

position papers in advance of the meeting, there are many instances when

advanced preparation of position papers

is not practical because of the technical nature of the meeting, insufficient information as to the exact agenda to be

discussed, or insufficient time. Consideration should be given to the

nature, purpose, and status of the meeting in determining the need for position papers. For example, there are many meetings of a technical nature where delegates participate as experts

under the rules of the organization and

are free to take positions without

committing their governments to a

particular course of action. Delegates to such meetings should be prepared to take positions which have been

coordinated with appropriate U.S.

interests, although it may not have been

possible to prepare position papers

concerning the points involved. Further, technical discussions, particularly in the early stages of standards development,

are free-wheeling and delegations

should have the latitude to freely debate

technical issues. In the standardization

process, there are normally a number of

iterations of a draft standard as it moves

through the system. Fosition papers may, therefore, be more appropriate in guiding the delegation in later stages of standards development when

delegations are expected to vote on

adoption of the standard. It is sometimes also useful to prepare

position papers for items not on the

official meeting agenda but which are deemed likely to arise or otherwise be

relevant to U.S. interests. In any case, the lead agency and the head of delegation should determine .vhelher position papers are appropriate. When

they are, the following guidelines should

be followed.

3.2.1 Unresolved Issues. The head of

delegation, with assistance as appropriate from the lead agency, should be responsible for the preparation of position papers. If agreement on a U.S. position on all major issues cannot be reached, the head of delegation should elevate any

unresolved issue to the lead agency for resoluUon, in consultation with affected

31
5796 Federal Register / VoiL 49, No. 32 / Wednesday, February 15, 1984 / Notices

interests (other agencies, private sector,

etc.) where possible and practical

3.2.2 Clearance ofPosition Papeis.

The head of delegation in cooperation

with the lead agency should determine on a Case-by-case basis what clearances

of position papers, if any, are

appropriate. With lead agency

assistance, the head of delegation

should also be responsible for obtaining

such clearances.

3.3 Coordination With Affected

Interests. Ensuring that affected U.S.

interests have been taken into account

in the preparation for the international meeting is perhaps the most difficult and

yet most important responsibility of the lead agency and head of delegation. For obvious reasons of time and resources, there must be limits to the effort of coordinating positions. Accordingly, the lead agency and head of delegation

should decide what actions need to be

taken. If the meeting involves the development of technical standards

which may become that basis for the conduct of international trade or of law

or regulation in this country or in other

countries, U.S. interests which may be

materially affected by these standards

should be notified of the meeting and

provided with relevant information and

the opportunity to comment on proposed

positions. This may be accomplished in any feasible manner, including the

solicitation of written comments or a

meeting. The lead agency and head of

delegation should be particularly aware

of international standards activities which may overlap or duplicate ongoing

activities either in other international organizations (intergovernmental or voluntary) in which the U.S. is a member, or within U.S. standards

bodies, and should wherever possible take steps to reduce the possibility of duplication of effort. 3.4 Prevention of Trade Barriers. Government agencies and employees

should be mindful that a standard may,

if improperly written, create an

unnecessary barrier to trade. Likewise,

they should also be aware that some

standards may be written in such a way

as to impede innovation and

technological progress and should strive

to provide standards that promote

innovative processes and technological

advances when they are in the public

interest. In general standards based on

performance criteria are less likely to pose competitive concerns than design,

material or construction criteria. Accordingly, preference should be given

to performance criterion whenever they

reasonably may be used in lieu of

design, material or construction

criterion.

3.4.1 While a standard may include a product incorporating a device or process which is patented, it is undesirable for a standard to be written

in such a way as to require the use of

the patented device or process in order

to be in conformance with the standard. Normally this problem can be avoided

by writing standards based on

performance criteria rather than design,

materials, or construction criteria. There

may be occasions, however, where there

is a great need for a particular standard

to be written to specify a patented item. Most standards organizations have

patent policies which require that if an

item which is patented is included in a

standard, the owner of a patent must

declare that the patent is available for unrestricted licensing under reasonable

terms and conditions. Government

participants should familiarize themselves with the patent policies of

the organizations in which they are - participating, and discuss them withtheir agency counsel should there be

any questions.

3.5. Technical Quality ofStandards.

It is particularly important that a

standard under development is technically sound, within the operating scope of the organization and meets

defined needs of the member nations. This may require that the Government

representative consult with other Government experts or with persons in other organizations who are not directly

involved with the standard under

consideration. Where a standard does

not meet a particular set of needs or is not technically sound in the view of the Government participant, he/she should

work with the committee to make the necessary corrections. If unsuccessful

the participant should oppose the adoption of the standard and report

such action to agency management

4. Meeting Participation. To be

effective at international standardsrelated meetings, a U.S delegation has

to be prepared not only for the substance of the meeting, but also for possible side issues and actions that can have a significant impact on the success

of the delegation. Instructions to a

delegation include information on how

to cope with unforeseen matters or with

extraneous political issues that might

arise during the meeting, and should

stress the importance of team work

and the need for the delegation to be

constantly aware that their actions, in and outside of the meeting, should

reflect credit upon the United States.

4.1 Responsibilities ofthe Delegation.

Delegates shall at all times maintain the highest standards of personal and

professional conduct

4.1.1 Head ofDelegation. The head of delegation is responsible for guiding the delegation and for presenting the U.S.

position, taking into account the guidelines contained in 4,1.3. 4.1.2. Delegation Members. Members

should assist the head of delegation

wherever possible to ensure the success

of U.S. participation in the meeting and

should accept such responsibilities as

are assigned, taking into account the guidelines contained in 4.1.3.

4.1.3

Participation Guidelines. Delegates to standards meetings

represent the public interest of the United States. Serving the public

interest requires a consideration of the viewpoints and objectives of all affected

parties and the choice of alternatives which promise to yield the greatest

economic and societal benfefits to the United States. Participation should be

guided by the following points.

4.1 .3.1 Unforeseen Matters. At the

discretion of the head of delegation,

unforeseen matters which arise during

the meeting should be addressed by the

delegation. If the delegation cannot

agree on a position on-the-spot, the head

of delegation should either seek time to obtain instructions from the lead

agency, or abstain from expressing a

U.S. point of view.

4.1.3.2 Unauthorized Personnel. Only

persons named as members of the delegation should participate in the work of the delegation. There may be

instances when qualified American

citizens are at the site of the meeting,

and the head of delegation may wish to consult them on technical matters. Such

consultation is permissible, but the persons may not be accredited or speak

as members of the U.S. delegation

without expressed prior authority from

the lead agency.

4.1.3.3 Press/Media Relations. The

head of delegation is responsible for any

press, media, or public statements of the

delegation. Except as specifically instructed to the contrary, the head of

delegation is under no obligation to make any public statements regarding

the meeting or on actions or positions

taken by the delegation during the meeting. Public statements to the press/

media should be made only after careful

deliberation, keeping the general

interests of the United States in mind.

Where possible, the head of delegation

may wish to consult with Embassy,

Consulate, or appropriate Mission

officials before making public statements.

4. 1.3.4 Meetings in the United States. Arrangements for hosting an

international meeting in the United

States are likely to require a very long

32
federal Register / Vol. 49, No. 32 / Wednesday, February 15, 1984 / Notices 5797

lead time and may involve considerable expense. The head of delegation should

neither invite a meeting of any kind to the United States nor imply that the U

n

; ied States would be willing to host a

specific meeting without prior approval

as appropriate.

4. 1.3. 5 Extraneous Political Issues. It

is the policy of the United States Government that at standards-related meetings or at conferences of a

.technical, professional, scientific, or other specialized nature, it is inappropriate to inject extraneous

political subjects. Accordingly, the U.S. delegation may not initiate political

discussions and should oppose on a

point of order the injection of political matters into the meeting by other

delegations.

4. 1.3. 6 Commitments of U.S. Participation in International Activities. At the meeting, careful consideration

should be given to any possible

commitments that may entail significant

expenditures of U.S. resources. This

applies in particular to: participation of

U.S. persons on committees, working

groups, etc., other than for the duration

of the meeting; undertaking Secretariat duties or committee chairmanships; and,

hosting of meetings in the United States. The U.S. delegation should make

tentative commitments only when

necessary. In such cases, care should be

taken to ensure that the commitments

being made are clearly understood as

tentative pending official confirmation.

4.1 .3.7 Expression of Personal

Opinion. Delegates should refrain from

publicly or privately expressing opinions on U.S. policies or programs not germane to the meeting. When personal

opinions, germane to the meeting are expressed, they should be clearly

identified as personal and unofficial.

4. 1.3. 8 Presentation of U.S. Positions. As stated in 4.1.1, the head of delegation

is responsible for presenting the U.S. position during the meeting. During the meeting, members of the U.S. delegation

should not speak on behalf of the delegation without the approval of the head of delegation.

4.2

Voting Guidelines. During certain international standards meetings, entire standards are approved by ballot and

the U.S. delegation will be expected to vote on adoption of a standard(s). The

procedures of international standards

bodies generally require approval of

draft international standards at a number of successive levels (e.g., at the subcommittee, committee, and final or plenary level] before final adoption. The

following guidelines for establishing U.S. positions on approval of draft standards

are intended as a step towards a unified Federal Government approach to the

development and use of international standards.

4.2.1 Voting "Yes " to Approve Draft Standards. Subject to the guidelines

concerning trade barriers in section 3.4, consider voting “Yes” to approve an

entire draft standard under any one of

the following circumstances:

(a] If there is a U.S. national standard

(a standard generally accepted within

the U.S.), or a relevant regulation, or Federal agency policy which can be

considered to be equivalent to the

international document under

consideration.

(b) If any conflict between the

international document and U.S.

practice (standard, regulation or policy)

is such that the U.S. practice could be

modified to conform without losing

equivalence. In such cases the

affirmative vote should be accompanied

by a statement that, “the U.S.

affirmative vote recognized the following minor technical additions, or

changes, which may be included in the national standard, regulation or policy."

(c) If no relevant U.S. standard,

regulation or policy exists and the

international document is technically

acceptable and could be used to develop

national standards.

4.2.2 Voting "No " to Disapprove

Draft Standards. Consider voting "No"

to not approve an entire draft standard

under any one of the following

circumstances:

(a) If the international document is considered to be not equivalent to or in clear conflict with a U.S. national

standard, regulation of Federal agency

policy.

(b) The international document is not

technically acceptable.

tej If a U.S. standard, regulation or

policy exists which differs from the international document only because the national practice (standard, regulation

or policy] includes additional or more

stringent requirements. In such a case,

the U.S. Vote should be accompanied by

comments pointing out that additional requirements must be met to satisfy the national practice.

(d] The international document

unnecessarily creates a barrier to domestic or international trade, or impedes innovation or technological

progress. Reasons must be given for a negative

vote. The U.S. vote must, therefore, be

accompanied by reasons for the negative vote, such as exceptions and

/

or additions that will be required to conform with our safety practices or

regulations.

4.2.3

Voting to "Abstain" on Draft

Standards. Consider "Abstanining" on

an entire draft standard under any one

of the following circumstances:

(a) If the international document is considered to be of little interest to the

U.S.

(b) If no U.S. standard, regulation or Federal agency policy exists and there is no intent to develop such.

(c) If no consensus position can be

established on the international document.

4.2.4

Exceptions. Exceptions to the above stated voting guidelines should be

carefully considered and based on a consensus.

5. Post Meeting Responsibilities. The

delegation should prepare a written

report to provide basic information with

which to evaluate the results of the meeting and to plan for future meetings.

5.1 Report of the Delegation. The

head of delegation should be

responsible for preparing a report on the meeting within thirty (30) days of the close of meeting. As a minimum, the report should provide the following

information:

(a) Title of the meeting, site, and

inclusive dates.

(b) Meeting agenda as finally adopted.

(c) List of participants.

(d) Summary of the work of the meeting including titles of draft standards discussed, major issues presented (technical, procedural, or

administrative), actions approved, and

major positions taken by the delegation.

(3) Conclusions of the delegation as regards the work and accomplishments

of the meeting from the point of view of

U.S. interests (e.g., U.S. positions versus

decisions of the meeting as a whole).

(f) Recommendations of the delegation

as regards the nature and scope of U.S. participation in future meetings and

follow-up actions needed to ameliorate

significant problems, particularly those concerning the possible negative impact

of any standards requirements on

existing or future U.S. trade.

5.2 Distribution of Report. Asa

minimum the the report should be

distributed to the lead agency and to each delegate. When problems of a trade nature have been identified or when the delegation has voted not to approve an entire draft standard based

on the voting guidelines in section 4.2. the report should be sent to the appropriate Technical Office within the Department of Commerce or Department

of Agriculture. Circulation of the report

should also be made to any U.S.

interests that were consulted in the development of positions and.

particularly, to U.S. voluntary standards

bodies involved in activities related to the subjects covered in the meeting

33
5798 Federal Register / VoL 49, No. 32 / Wednesday, February 15, 1984 / Notices

Section II—GuidelLnsa for Participation

by U.S. Government Agencies,

Employees, or Representatives in International Standards-Reiated

Organizations in which the U.S. Government is not the Official U.S. Member-Body

1. Scope. These guidelines apply to • participation by U.S. Government

agencies, employees, or representatives

in international standards activities in which the U.S. Government is not the

official U.S. member-body, such as in the International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC). The guidelines

supplement OMB Circular No. A-119,

“Federal Participation in the Development and Use of Voluntary

Standards," which establishes policy to be followed by executive branch

agencies in working with voluntary

standards organizations.

2. Authorization. In accordance with

OMB Circular A-119, agencies and their employees are encouraged to participate

in the activities of international standards bodies and standards- developing groups when such

participation is in the public interest and

is compatible with agencies' missions,

authorities, priorities, and budget

limitations.

3. Role. U.S. Government agencies

and their employees should assist the U.S. member-body in ensuring effective participation and representation of U.S.

interests in international standards

bodies and standards-developing

groups. Such assistance generally falls into one or more of the following types

of international standards-related

activities.

3.1. Secretariat ofan International Standards Activity. A U.S. Government

' agency may be designated by tb.e U.S. member-body to function as secretariat of an international standards committee,

subcommittee, working group or task

force.

3.2. Administrator/Participant in an

Advisory Group. A U.S. Government

agency may be requested by the U.S. member-body to function as

administrator of an advisory group

responsible for coordinating U.S. participation in an international standards activity. Such an advisory group is normally constituted to bring

together all interested parties (public

and private) in an international standards activity for the purpose of

guiding U.S. participation in that

activity. Similarly, agencies or their employees may be asked by the U.S. member-body, or designated advisory

group administrator, to participate as a member or officer of the advisory group.

3.3.

Delegate to an International

Standards Meeting. U.S. Government

employees may be invited by the U.S. member-body, or designated advisory group administrator, to participate as a member or head of delegation

assembled to represent the memberbody during an international standards

committee meeting.

4.

Participation Principles.

Participation in international standards

activities shall be at all times consistent with the highest standards of personal

and professional ethics.

4.1. Decision to Participate. Effective participation in international standards

activities outlined in sections 3.1 to 3.3 requires much more effort than merely

attending meetings. Before accepting

responsibility as secretariat or advisory group administrator of an international standards activity, agencies should

thoroughly explore the resource

implications and match to mission of

such activity and make sure that the work can be undertaken and completed

in an effective and timely manner.

Likewise, agency employees serving as

participants in international standards

activities should devote adequate time

and effort in preparing for meetings and

other related activities to assure die development of meaningful and

technically sound standards. The

participant should inform his/her

supervisor of the estimated time to be

devoted to these activities and reach an

understanding as to the extent and cost

of participation, governed by individual workload and other official commitments.

4.2. Adherence to Policies and

Procedures of Member Body. In all of

the activities listed in 3.1 to 3.3, agencies

and their employees are responsible for adhering to the guidelines and working

procedures of both the parent

international standards body and the respective U.S. member-body through

which their participation is channeled.

4.3. Representing the Public Interest. Agencies and employees involved in international standards activities should

represent the public interest of the United States in the broadest sense. The

public interest inolves the interest of those parties who are substantially

affected by the standards under

consideration and includes

manufacturers and producers, industrial

users, distributors and retailers, government agencies, individual consumers, and the public at large, in serving the public interest, one promotes

the general or national welfare rather than the self-interest of private individuals or organizations.

4.4. Consideration ofBalanced

Representation. Agencies responsible

for administering international standards committee secretariats or advisory groups which develop U.S. input to international standards

committees should seek a balance of viewpoints. In those cases where an

international standard may measurably

affect trade, or which may be proposed

for adoption as law or regulation within

the United States, it is particularly

important to seek representation from

the affected community (e.g., industry, other agencies, State and local governments, labor, universities,

consuming public). Similarly, agency

employees who participate on U.S. advisory groups, or as members of U.S. delegations preparing positions on

proposed international standards,

should offer to assist the responsible

parties in assuring that balanced

representation has been considered and

sought

' 4.S. Coordination of Government

Viewpoint There are occasions when

Government participants from different agencies are members of the same

standards advisory group or serve

together as member of a U.S. delegation

to an international standards meeting.

Generally, their presence is recognition

of professional expertise and

competence in a particular subject area and/or recognition of differing roles played by their agencies in the subject

area. Such participants may even

represent different disciplines (chemist versus economist). In such instances it i9 entirely possible for views to be

expressed which are different and

which reflect the differing roles of the agencies involved. When this occurs, the participants should try to resolve

substantive differences, particularly if they have a bearing on existing law or

regulation. If the differences are serious and cannot be resolved by the involved

participants, they should be brought to the attention of higher management

within the involved agencies.

4.6. Prevention of Trade Barriers. The

Government participant should be

mindful that a standard may. if improperly written, create an

unnecessary barrier to trade. Likewise,

the participant should also be aware

that some standards may be written in such a way as to impede innovation and

technological progress and should strive

to provide standards that do not

unnecessarily hinder innovative processes and technological advances

when they are in the public interest. In

general, standards based on

performance criteria are less likely to pose competitive concerns than design.

34
Federal Register / Yoi. 49, No. 32 / Wednesday, February 15, 1984 / Notices 5799

material, or construction criteria. Accordingly, preference should be given

to performace criterion whenever they

reasonably may be used in lieu of

design, material, or construction

criterion.

1.7. Technical Quality of Standards. It is particularly important that a standard

under development is technically sound,

within the operating scope of the organization and meets defined needs of

the member nations. This may require

that the Government representatives consult with other Government experts or with persons in other organizations

who are not directly involved with the standard under consideration. Where a standard does not meet a particular set of needs or is not technically sound in the view of the Government

participants, he/she should work with

the committee to make the necessary

corrections. If unsuccessful, the participant should oppose the adoption

of the standard and report such action to agency management.

4.8. Voting, When Authorized. In accordance with OMB Circular A-119,,

Government participants may vote at each stage of standards development

unless specifically prohibited from doing

so by the head of the agency or that

official’s designee. The procedures of international standards bodies generally

require approval of draft international standards at a number of successive

levels (e.g., at the subcommittee,

committee, and final or plenary level) before final adoption. The following

voting guidelines relate to agency

participation in technical advisory groups to international standards

committees or in U.S. delegations to international standards committee

meetings. The guidelines recognize the policy that U.S. positions relative to international standards activities are developed through a consensus of the

participants.

4.8.1 Voting ‘Yes " to Approve Draft Standards. Subject to the guidelines

concerning trade barrier in section 4.6, consider voting “Yes’’ to approve an

entire draft standard under any one of

the following circumstances:

(a) If there is a U.S. national standard

(a standard generally accepted within

the U.S.), or a relevant regulation, or Federal agency policy which can be

considered to be equivalent to the international document under

consideration.

(b) If any conflict between the international document and U.S. practice (standard, regulation or policy)

is such that the U.S. practice could be

modified to conform without losing

equivalence. In such cases the affirmative vote should be accompanied

by a statement that, “the U.S. affirmative vote recognizes the following

minor technical additions, or changes,

which may be included in the national

standard, regulation or policy.

(c) If no relevant standard, regulation

or policy exists and the international document is technically acceptable and

could be used to develop national standards. 4.&2 Voting “No" to Disapprove Draft

Standards. Consider voting “NoM to not approve an entire draft standard under

any one of the following circumstances:

(a) If the international document is considered to be not equivalent to or in clear conflict with a U.A. national

standard, regulation or Federal agency

policy.

(b) The international document is not

technically acceptable.

(c) If a UJ3. standard, regulation or

policy exists which differs from the

international document only because the national practice (standard, regulation

or policy) includes additional or more

stringent requirements. In such a case, the U.S. vote should be accompanied by

comments pointing out that additional

requirements must be met to satisfy the national practice.

(d) The international document

unnecessarily creates a barrier to domestic or international trade, or impedes innovation or technological

progress. Reasons must be given for a negative

vote. The U.S. vote must, therefore, be

accompanied by reasons for the negative vote, such as exceptions and

/

or additions that will be required to conform with our safety practices or

regulations.

4.8.3 Voting to “Abstain " on Draft

Standards. Consider “Abstaining” on an

“ntire draft standard under any one of

the following circumstances:

(a) If the international document is considered to be of little interest to the U.S.

(b) If no U.S. standard, regulation or Federal agency policy exists and there is no intent to develop such.

(c) If no consensus position can be

established on the international document.

4.8.4 Exceptions. Exceptions to the above stated voting guidelines should be

carefully considered and based on a consensus.

4.8J> Registering a Dissenting

Viewpoint Government participants

may be confronted with the situation where they consider a proposed U.S. vote as being in conflict with the public

interest, the interests of the Federal Government, and/or their own

professional judgment. Should such a

conflifct exist, participants should

attempt to resolve them within the framework of the advisory group or

delegation on which they serve. If unsuccessful, participants should make

their position clear in writing to the U.S. member-body for the particular

standards organization in question and

inform their agency of the perceived

conflict.

4.9.

Patents. While a standard may

include a product incorporating a device

or process which is patented, it is undesirable for a standard to be written

in such a way as to require the use of the patented device or process in order

to be in conformance with the standard

Normally this problem can be avoided

“by writing standards based on

performance criteria rather than design

material, or construction criteria. There

may be occasions, however, vyhere there

is a great need for a particular standard

to be written to specify a patented item. Most standards organizations have

patent policies which require that if an

item which is patented is included in a standard, the owner of a patent must

declare that the patent is available for unrestricted licensing under reasonable

terms and conditions. Government

participants should familiarize themselves with the patent policies of

the organizations in which they are

participating, and discuss them with

their agency counsel should there be

any questions.

5. Reports. Government participants

who serve as members of U.S. delegations to international standards

meetings should prepare a written report on their participation within thirty (30) days after the close of the meeting.

Distribution of the report depends upon

agency procedures covering such

matters. As a minimum, the report

should cover important actions and

decisions taken during the meeting.

Where problems are encountered,

particularly as regards a U-S. vote on a standard, participants should consider

sending a copy of their report to the appropriate Technical Office identified on page 3. Guidelines for Federal Agency Use of Private Sector Third-Party Certification Programs

O. Introduction

When purchasers receive a product or

service, they may seek assurance that it conforms to a specified standard ur

specification. The process by which

such assurance is provided is referred to as certification. These procedures are intended to provide guidekora tor Federal agency acceptance and me of private sector thrrd-party certification

35
NBS-114A (rev. 2 - 80 ) U.S. DEPT. OF COMM. 1. BIBLIOGRAPHIC DATA

SHEET (See instructions)

|

PUBLICATION OR 2 REPORT NO.

. Performing Organ. Report No. 3.

NBSIR 84-2992

Publication Date

4. TITLE AND SUBTITLE

Guidelines for NBS Standards Committee Participants

5. AUTHOR(S)

Donald R. Mackay, Coordinator

6. PERFORMING ORGANIZATION (If Joint or other than NBS, see instructions)

NATIONAL BUREAU OF STANDARDS

DEPARTMENT OF COMMERCE

WASHINGTON, D.C. 29234

7. Contract/Grant No.

S. Typa of Report & Period Covered

9. SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street, City, State, ZIP)

10. SUPPLEMENTARY NOTES

| | Document describes a computer program; SF-185, FIPS Software Summary, is attached.

11. ABSTRACT (A 200-word or less factual summary of most significant information. If document Includes a significant

bibliography or literature survey, mention it here)

This document provides guidance to NBS employees who participate in standards

development activities of private sector organizations like ASTM, ASME and IEEE.

It provides basic information concerning appointments to committees, funding of

participation and the need for coordination with other NBS participants and other

Federal participants. It also emphasizes the need to keep management informed

regarding sensitive issues.

12. KEY WORDS (Six to twelve entries; alphabetical order; capitalize only proper names; and separate key words by semicolons)

Committee participation; Federal standards policy; standards; standards committees;

standards participation

13. AVAILABILITY

| | Uni imited

)tX| For Official Distribution. Do Not Release to NTIS

| | Order From Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402.

14. NO. OF

PRINTED PAGES

36

15. Price

[^] Order From National Technical Information Service (NTIS), Springfield, VA. 22161 $8. 50

USCOMM-DC S043-P80