ANNUAL REPORT NISTIR-6494

TO THE

OFFICE OF MANAGEMENT AND BUDGET

ON THE

IMPLEMENTATION OF OMB CIRCULAR A-119

AND P.L. 104-113

COVERING THE PERIOD:

OCTOBER 1, 1998 THROUGH SEPTEMBER 30, 1999

 

United States Department of Commerce

National Institute of Standards and Technology

Technology Services

Office of Standards Services

Gaithersburg, Maryland 20899-2100
ii

ANNUAL REPORT TO THE OFFICE OF MANAGEMENT AND BUDGET (OMB)

ON THE

IMPLEMENTATION OF OMB CIRCULAR A-119 AND P.L. 104-113

Table of Contents

EXECUTIVE SUMMARY .............................................................. iv

1. SCOPE ......................................................................... 1

2. FEDERAL STATUTES .......................................................... 1

2.1 National Technology Transfer and Advancement Act (NTTAA) ........................ 1

2.2 OMB Circular A-119 and P.L. 104-113 ............................................ 1

2.2.1 Agencies  use of voluntary consensus standards versus government-unique standards ....... 1

2.2.2 Guidance to agencies .......................................................... 2

2.2.3 Other issues covered by the Circular .............................................. 2

2.2.4 Role of Secretary of Commerce and NIST .......................................... 2

2.2.5 Agency Standards Executives .................................................... 2

3. INTERAGENCY COMMITTEE ON STANDARDS POLICY (ICSP) ..................... 2

3.1 Purpose ..................................................................... 2

3.2 ICSP chair ................................................................... 2

3.3 ICSP membership ............................................................. 3

4. HIGHLIGHTS OF ICSP ACTIVITIES .............................................. 3

4.1 General ..................................................................... 3

4.2 Interaction with private sector standards organizations ................................ 3

4.3 ICSP working groups .......................................................... 3

5. HIGHLIGHTS OF FEDERAL AGENCY ACTIVITIES ................................ 7

5.1 Department of Commerce (DOC) ................................................. 7

5.2 Department of Defense (DOD) ................................................... 9

5.3 Department of Energy (DOE) .................................................... 9

5.4 Department of Health and Human Services (HHS),

Food and Drug Administration (FDA) .......................................... 9

5.5 Consumer Product Safety Commission (CPSC) ..................................... 10

5.6 Environmental Protection Agency (EPA) .......................................... 10

5.7 Federal Communications Commission (FCC) ...................................... 10

5.8 Federal Emergency Management Agency (FEMA) .................................. 11

5.9 General Services Administration (GSA) .......................................... 11

5.10 National Aeronautics and Space Administration (NASA) ............................. 11

5.11 Nuclear Regulatory Commission (NRC) .......................................... 11

6. AGENCY USE OF GOVERNMENT-UNIQUE STANDARDS IN LIEU OF

VOLUNTARY CONSENSUS STANDARDS ....................................... 12

6.1 Department of Defense (DOD) .................................................. 12

6.2 National Aeronautics and Space Administration (NASA) ............................. 12

6.3 Environmental Protection Agency (EPA) .......................................... 13

6.4 Federal Emergency Management Agency (FEMA) .................................. 13
iii

7. CONCLUSIONS .............................................................. 14

8. RECOMMENDATIONS ........................................................ 18

APPENDIX A: CABINET DEPARTMENT REPORTS ................................... .A-1

Department of Agriculture (USDA) ............................................... A-2

Department of Commerce (DOC) ................................................ A-7

Department of Defense (DOD) ................................................. A-14

National Communication System (NCS) ........................................ A-24

Department of Education (DOED) ............................................... A-26

Department of Energy (DOE) .................................................. A-28

Department of Health and Human Services (HHS)

Food and Drug Administration (FDA) .......................................... A-34

Department of Housing and Urban Development (HUD) ............................. A-41

Department of the Interior (DOI) ................................................ A-42

Department of Justice (DOJ) ................................................... A-43

Department of Labor (DOL) ................................................... A-44

Department of State (STATE) .................................................. A-46

Department of Transportation (DOT) ............................................ A-47

Department of the Treasury (TREASURY) ........................................ A-51

Department of Veterans Affairs (VA) ............................................ A-53

APPENDIX B: OTHER AGENCY AND COMMISSION REPORTS ........................ B-1

Agency for International Development (USAID) .................................... B-2

Consumer Product Safety Commission (CPSC) ..................................... B-3

Environmental Protection Agency (EPA) .......................................... B-5

Federal Communications Commission (FCC) ...................................... B-37

Federal Emergency Management Agency (FEMA) .................................. B-39

General Services Administration (GSA) .......................................... B-41

Government Printing Office (GPO) .............................................. B-43

National Aeronautics and Space Administration (NASA) ............................ B-44

National Archives and Records Administration (NARA) ............................. B-47

National Science Foundation (NSF) ............................................. B-49

Nuclear Regulatory Commission (NRC) .......................................... B-50

APPENDIX C: CHARTER OF THE INTERAGENCY COMMITTEE ON STANDARDS

 POLICY ........................................................... C-1

APPENDIX D: MEMBERSHIP OF THE INTERAGENCY COMMITTEE ON STANDARDS

 POLICY ........................................................... D-1

APPENDIX E: LIST OF NIST PUBLICATIONS RELATED TO P.L. 104-113 ................ E-1
1OMB issued a revised Circular A-119 on February 19, 1998.

iv

EXECUTIVE SUMMARY

Office of Management and Budget (OMB) Circular A-1191

, Federal Participation in the

Development and Use of Voluntary Consensus Standards and in Conformity Assessment

Activities, requires the National Institute of Standards and Technology (NIST) to report annually

to OMB on the progress that Federal agencies have made toward using voluntary standards rather

than agency-unique standards, as well as on NIST efforts in coordinating agencies  use of

voluntary standards and participation in standardization activities, and to provide summaries of

the status of individual agency use of standards and participation and interaction with private

sector voluntary standards bodies.

Public Law (P.L.) 104-113, the National Technology Transfer and Advancement Act (NTTAA),

and OMB Circular A-119 require Federal agencies to use voluntary standards to the extent

practicable, and to report when they have developed agency-specific standards in lieu of

voluntary consensus standards. The present report addresses the development of agency-unique

standards, the extent and nature of participation by Federal agencies in the development of

voluntary standards, their use of voluntary standards, and an evaluation of the effectiveness of the

policies promulgated in the Circular.

This report covers fiscal year (FY) 1999, from October 1, 1998, through September 30, 1999.

NIST relies on the Interagency Committee on Standards Policy (ICSP) as the primary means of

fulfilling NIST s responsibilities for coordinating Federal standards-related activities. This

report describes NIST s coordination activities with special emphasis on implementing the

NTTAA. It also includes information on the activities of the ICSP and its working groups, an

overview of standards policy coordination, individual agencies  reports on NTTAA

implementation efforts, and future courses of action.

On September 28 1999, NIST, who chairs the ICSP, requested that each agency provide

information on the status of its implementation of both the OMB Circular A-119 and the

NTTAA. The Circular and the NTTAA require that each agency collect specific information

regarding the status of its implementation activities: agency use of government-unique standards

in lieu of voluntary consensus standards, the use of voluntary consensus standards, the number of

voluntary standards substituted for government-unique standards, and the number of individual

agency participants in voluntary standards bodies. This information is summarized by agency in

Table 1 on page 15 of the report. Totals for all Federal agencies are shown in the following

table:
v

Fiscal Year (FY) 1999 Statistics on Federal Agencies  Participation in Development of

and Adoption of Voluntary Consensus Standards 1

Number of

Voluntary

Consensus

Standards Bodies in

which Agencies

Reported

Participation

Number of Agencies 

Employees

Participating in

Voluntary Consensus

Standards Bodies

Number of

additional

Voluntary

Consensus

Standards

used in

FY 1999

Number of

Voluntary

Consensus

Standards

substituted in

FY 1999 for

GovernmentUnique

Standards

Number of

GovernmentUnique

Standards

Used in Lieu

of Voluntary

Consensus

Standards in

FY 1999

FY

1999

Change

from

FY 1998

FY 1999 Change

from 

FY 1998

823 -41 2,832 -378 2,669 542 88

1 Not reflected in the chart are the total number of voluntary consensus standards adopted

by Federal agencies and those in the process of being adopted. For example, DOD

reported that their total number of adopted voluntary consensus standards was 8,618 for

FY 1999, DOE reported that their total was 1,306 for FY 1999.

In addition to adoption of voluntary consensus standards, Federal regulatory agencies, such as

EPA, have developed procedures for alerting the public about proposed regulations. The EPA

has developed wording for inclusion in its notices of proposed rulemaking to draw attention to

Federal opportunities for using voluntary consensus standards. Such notices allow standards

developing organizations (SDOs) the opportunity to alert Federal agencies of standards and

standards activities of potential interest. Federal procurement agencies, such as DOD and

NASA, have developed procedures for alerting proposers about opportunities for use of

voluntary standards on procurement actions.

Agencies have also instituted procedures for identifying existing standards when proposing new

regulations or in procurement activities. During FY 1999, DOD continued to move Mil-Specs

into the private sector. Some agencies, notably the HHS, have convened agency-wide workshops

with other agencies, and invited key stakeholders to educate their standards personnel. Finally,

private sector SDOs instituted briefing sessions with Federal agencies to address the issue of

references to out-of-date standards in regulations.

The decline in agency participation in standards committee activities first noted in the FYs 1997

and 1998 reports has continued. (See charts 2 and 3 on page 17 of the report). In the

recommendations section of this report, a number of possible reasons for this decline are listed.
vi

Included in Appendices A and B of this report are the reports sent to NIST from the 14 Cabinet

Departments and 12 other agencies and commissions. They are provided, with minimal or no

editing and reformatting. Copies of the ICSP Charter, the FY 1999 ICSP membership list, and a

list of NIST publications related to P.L. 104-113 are provided in Appendices C, D, and E,

respectively.
1

Annual Report to the Office of Management and Budget on

Implementation of OMB Circular A-119

1. SCOPE

This report describes the progress that Federal agencies have made in the use of voluntary

consensus standards and participation in standardization activities. It also highlights some

examples of agencies  interactions with private-sector voluntary consensus standards bodies,

agencies  use of government-unique standards, and the activities of the Interagency Committee

on Standards Policy (ICSP). It discusses National Institute of Standards and Technology s

(NIST s) efforts in coordinating Federal agencies  standards-related activities, including

interactions with key private sector organizations. This report covers fiscal year (FY) 1999 from

October 1, 1998, through September 30, 1999.

Appendices A and B provide copies of the reports that NIST received from Cabinet Departments,

other agencies, and commissions. Appendices C, D, and E, respectively, provide copies of the

ICSP Charter, ICSP membership, and a list of NIST publications related to Public Law

(P.L.) 104-113.

2. FEDERAL STATUTES

2.1 National Technology Transfer and Advancement Act (NTTAA) - P.L. 104-113, the

NTTAA of 1995, codified existing policies of the Office of Management and Budget (OMB)

Circular A-119, established reporting requirements, and authorized NIST to coordinate standards

conformity assessment activities of Federal agencies, and with the private sector.

2.2 OMB Circular A-119 and P.L. 104-113 - On February 19, 1998, OMB issued the newlyrevised Circular A-119, Federal Participation in the Development and Use of Voluntary

Consensus Standards and in Conformity Assessment Activities, to replace the Circular dated

October 20, 1993. The purpose was to make the terminology of the Circular consistent with

P.L. 104-113, to issue guidance to agencies on making their reports to OMB, to direct the

Secretary of Commerce to issue policy guidance for conformity assessment, and to make changes

for clarity. 

2.2.1 Agencies  use of voluntary consensus standards versus government-unique

standards - Consistent with section 12(d) of the NTTAA, the Circular directs agencies to use

voluntary consensus standards in lieu of government-unique standards except where inconsistent

with law or otherwise impractical. It also provides guidance for agencies participating in

voluntary consensus standards bodies and describes procedures for satisfying the reporting

requirements of the NTTAA. The policies in the Circular are intended to minimize reliance by

agencies on government-unique standards. These policies do not create the basis for
2

discrimination in agency procurement or regulatory activities among standards developed in the

private sector, whether or not they are developed by voluntary consensus standards bodies.

2.2.2 Guidance to agencies - Consistent with section 12(b) of the NTTAA, the Circular directs

the Secretary of Commerce to issue guidance to agencies on ways to coordinate their conformity

assessment activities. The goal of this guidance is to reduce unnecessary duplication and

complexity in Federal conformity assessment activities. Draft guidance was prepared and

circulated within the ICSP for comment, with particular attention paid to meeting regulatory

agency concerns. The draft guidance will be published in 2000 for additional public comment.

2.2.3 Other issues covered by the Circular - The Circular also describes policies regarding

Federal use of standards and Federal participation in voluntary consensus standards bodies. It

covers the use of standards in regulations and provides procedures for managing and reporting on

agency use of standards in procurement and regulations. It also covers reporting requirements

including how an agency is to report on its development and use of standards. The Circular also

specifies the responsibilities of the Secretary of Commerce and NIST, agency heads, and Agency

Standards Executives.

2.2.4 Role of Secretary of Commerce and NIST - The NTTAA and the Circular assign

several policy coordination and implementation tasks to the Secretary of Commerce and

specifically to NIST. NIST is responsible for chairing the ICSP and submitting an annual report

to OMB on agency implementation activities. Compiling this report requires the full cooperation

and assistance of all departments and agencies.

2.2.5 Agency Standards Executives - The revised Circular clarifies the role of Agency

Standards Executives, particularly regarding agency-wide compliance with the NTTAA s legal

requirements. The Standards Executive is responsible for coordinating agency-wide standardsrelated activities, coordinating the implementation of the Circular, and serving on the ICSP.

3. INTERAGENCY COMMITTEE ON STANDARDS POLICY (ICSP)

3.1 Purpose - The ICSP was established in 1968 to encourage coordination and liaison among

Federal agencies on matters related to standards. In 1992, the Secretary of Commerce

reconstituted the ICSP to provide the required "interagency consultative mechanism to advise the

Secretary and agency heads in implementing the policy." In October 1997, the Secretary of

Commerce approved a new Charter, which included requirements of the NTTAA. A copy of the

new Charter is provided as Appendix C.

3.2. ICSP chair - The Director of the NIST Office of Standards Services chairs the ICSP on

behalf of the NIST Director and the Secretary of Commerce. The ICSP is the primary vehicle for 
3

coordinating Federal activities under the NTTAA and the OMB Circular. NIST develops very

few agency-unique standards for either procurement or regulation purposes, but plays a major

role in standards-related technical and policy-related activities as directed by both the Circular

and the NTTAA.

3.3 ICSP membership - The ICSP is currently composed of representatives of the 14 Federal

Cabinet Departments, 12 other Federal agencies and commissions, and several offices in the

Executive Office of the President. The composition of the ICSP is shown in figure 1 on page 6. 

The ICSP membership is provided as Appendix D.

4. HIGHLIGHTS OF ICSP ACTIVITIES

4.1 General - The ICSP met five times in FY 1999. The meetings focused on such topics as the

NTTAA, agency implementation of the OMB Circular A-119, the proposed conformity

assessment guidance, and the annual report to OMB. There were presentations and discussions

on implementing the NTTAA, various agency standards-related policy issues, and the proposed

guidance on Federal conformity assessment activities. ICSP members heard presentations from

NIST regarding the National Cooperation for Laboratory Accreditation (NACLA) activities, the

National Voluntary Conformity Assessment Systems Evaluation (NVCASE) Program, Strategic

Management of Standards activities at NIST, and a new NIST Standards Policy document.

At the March 1999 meeting, the Committee invited Mr. James H. Turner, Senior Staff Member

for Technology and Counsel, House Committee on Science, U.S. House of Representatives, to

give his perspective on the NTTAA.

4.2 Interaction with private sector standards organizations - Representatives from several

private sector standards developing organizations (SDOs) gave presentations on topics of

interest. The speakers represented such organizations as Underwriters Laboratories and the

American Society of Mechanical Engineers.

4.3 ICSP working groups - During 1999, a variety of ICSP activities were carried out by the

ICSP s working groups shown in figure 1 on page 6.

Their activities are described as follows:

"Regulatory Agencies Working Group (RAWG) - The ICSP s RAWG, chaired by

CPSC, helps to develop and implement standards policies of interest to regulatory entities

of the Federal Government. Membership includes representatives from CPSC, DOE,

EPA, FCC, FDA, FERC, HUD, NIST, NRC, OSHA, and USDA. The RAWG reports to

the ICSP and serves as a forum for interagency information exchange and discussion of

issues of mutual interest to regulatory agencies. During 1999, the RAWG focused on

issues and activities related to: (1) implementation of OMB Circular A-119 entitled,

"Federal Participation in the Development and Use of Voluntary Standards;"
4

(2) conformity assessment; (3) a national standards strategy; (4) on-line standards

development; (5) accreditation of standards developers using "essential requirements;"

and (6) referencing voluntary standards in Federal Regulations.

"Working Group on Strategic Standards Management - During 1999, the ICSP s

Standards Management Working Group, chaired by DOE, examined options for a second

Federal Technical Standards Workshop during FY 2000. The effort to coordinate the

Workshop among Federal agencies will continue in FY 2000, and will focus on Federal

standards management processes and coordination with SDOs.

"Working Group on Directory Databases - The ICSP working group on Directory

Databases, chaired by NIST, met once in 1999 to review and discuss the final report and

guidelines for developing databases of standards committee participants, review current

activities of working group members, and to assess the need for technical assistance, and

future activities. Ten agencies were represented. The final report and guidelines were

adopted as presented. It was decided that web-based systems are the preferred method for

developing, maintaining, and disseminating information on committee participation. 

Four agencies--NIST, DOD, DOE, and NASA--have their information available on the

Web. The NIST Webmaster provided the group with information on how agencies may

be able to link individual databases without creating one main database, allowing

agencies to maintain their own information. The group agreed to invite technical

representatives to the next meeting to provide guidance on developing databases and on

creating web links.

"Working Group on Quality Management (International Organization for

Standardization (ISO) 9000) - NIST provided material on the proposed revisions to the

ISO 9000 standards to the ICSP. NIST also responded to requests for assistance/

information from individual agencies on this topic. However, there were no meetings of

this working group in FY 1999. To determine if there is a continuing need for this

working group, ICSP members were asked to nominate representatives within their

agencies who might be interested in serving on the committee. No names were received. 

This working group will remain inactive until the ICSP determines that there is a need for

its reactivation, but NIST will continue to share information related to the revisions of

ISO 9000 with ICSP members.

"Interagency Working Group on Environmental Management Systems (EMS)

(ISO 14000) - The Interagency Working Group on EMS/ISO 14000, co-chaired by EPA

and DOE, met several times in FY 1999 to discuss items of mutual interest related to

ISO 14000. Recently, the group began drafting a fact sheet on Environmental

Management Systems and ISO 14000 in the Government. This document is slated for

completion in FY 2000.
5

"Procurement Agencies Working Group - This working group, chaired by DOD, did not

meet in FY 1999 since no issues specifically related to procurement were identified. This

working group will be reactivated should issues arise in this area in the future.

"Working Group on Federal Agency Participation - This working group, chaired by

DOD, did not meet in FY 1999. Last year, the working group surveyed SDOs about the

reported decline in government participation, but the survey did not yield significant

results. The working group had hoped to determine whether participation had, in fact,

declined, and that the decreasing numbers were not just a result of inaccurate reporting. 

The working group would have liked to compare government decline in participation

with changes in other sectors. While the limited data collected confirmed substantial

decline in government participation, and showed that it exceeded the decline from other

sectors, the sample size was considered too small to be representative. Some SDOs,

while not having exact numbers to report, did say that they had actually seen some

increases in government participation.

Working group members and the ICSP remain concerned about declining participation--

even fewer participants this year than last--and will request a discussion topic at a future

ICSP meeting.

"Laboratory Accreditation Work Group - This working group, chaired by NIST, did not

meet in FY 1999. Its primary functions are now being addressed by the National

Cooperation for Laboratory Accreditation (NACLA). This group will be subsumed into

the Federal Coordination Group of NACLA during FY 2000.

"Standards Working Group of the CIO and of ICSP - This Working Group s goal is to

develop a unified government voice on standards and technology requirements. The

Standards Working Group of the Enterprise Interoperability and Emerging Information

Technology Committee of the Federal CIO Council provides a forum for Federal agencies

to identify and define their common requirements so that they may be transmitted to the

appropriate voluntary standards development committees or consortia for action. The

intent of the working group, chaired by NIST, is to improve the bargaining power of

Federal agencies within voluntary standards committees through coordinated requirement

statements. In FY 2000, NIST intends to create an e-mail reflector for supporting the

work of the Standards Working Group, and a web-based requirements tracking database,

which includes capability for web-based submission of proposed requirements. The

group first met in December 1998 at NIST, with participants from the DISA Center for

Standards, HHS, DOE, DOED, DOI, DTIC, VA, EPA, NARA, NIH, Treasury, NRC,

USDA, HUD, FAA, DOD-ASD, and Center for Disease Control. The group met a

second time to provide briefings on topics requested by working group members,

including an overview of the voluntary standards community and a short introduction to

software conformance testing.
6

(Figure 1 not available)
7

5. HIGHLIGHTS OF AGENCY ACTIVITIES

5.1 Department of Commerce (DOC) - Within DOC, NIST has responsibility for the primary

activities for implementation of P.L. 104-113 and OMB Circular A-119. During FY 1999, NIST

conducted a number of activities to strengthen coordination between agencies and the private

sector. Among these were:

"NIST published two editions of Special Publication (SP) 739, Directory of Federal

Government Certification and Related Programs. The document contains information on

Federal Government procurement and regulatory conformity assessment programs that

might affect products and services. Entries include the purpose of each requirement,

whether mandatory or voluntary, and methods used to ensure compliance. Sources of

documentation, reciprocity arrangements, enforcement approaches, and other items are

listed. SP 739 contains information on many new Federal programs and the document s

scope has been expanded to include other related types of Federal programs that have an

impact on the marketplace. The document is available on the Internet at

<http://ts.nist.gov/ts/htdocs/210/216/216.htm>.

"NIST cosponsored a major national workshop on conformity assessment issues with the

American National Standards Institute (ANSI) and the American Council of Independent

Laboratories on February 9, 1999. This meeting concluded that: (1) the U.S. conformity

assessment system is very complex and all parties need to work together to simplify it,

and (2) both the Federal Government and the private sector need to harmonize their

conformity assessment activities to reduce duplication and complexity. One outcome of

the meeting was the formation of a public/private sector organization known as the

Conformity Assessment Network.

"In March 1999, NIST s Office of Standards Services (OSS) and five private sector

organizations cosponsored a one-week workshop on Electrical Safety Systems for the

Americas. This successful partnership among NIST, the National Electrical

Manufacturers Association, the National Fire Protection Association, Underwriters

Laboratories, Intertek Testing Services, and the International Code Council, established

an international forum for identifying and discussing issues related to building codes,

product certification, installation, and enforcement practices in the Americas.

"Representatives of the European Commission and Canada, in conjunction with the Food

and Drug Administration (FDA) and NIST s OSS, held a workshop on April 12-14, 1999,

for U.S. and Canadian entities desiring to be designated as Conformity Assessment

Bodies (CABs) for medical devices under the U.S.-European Union (EU) and Canada-EU

Mutual Recognition Agreements (MRAs). The workshop covered the overall

requirements of the European Directive for Medical Devices and the specific

requirements for entities to be designated as CABs.
8

"The European Commission, in conjunction with the Federal Communications

Commission (FCC) and OSS, held a workshop on April 26-27, 1999, for U.S. and

Canadian entities desiring to be CABs for telecommunications and electromagnetic

compatibility (EMC) under the U.S.-EU and Canada-EU MRAs. The seminar, conducted

by staffs of the European Commission, FCC, and NIST, covered the European Directives

for Telecommunications and EMC and the specific requirements for entities to be

designated as CABs.

"OSS hosted a seminar in May 1999 for representatives of the International Organization

for Standardization Committee on Consumer Policy (COPOLCO) from 23 countries to

introduce them to consumer-related U.S. Government regulatory and standards activities. 

NIST welcomed the group and gave them an overview of NIST s program activities. 

Speakers from the Environmental Protection Agency (EPA), Consumer Product Safety

Commission, Department of Agriculture, and FDA described their regulatory activities

and their work with consumers to ensure that regulations reflect consumer needs. The

seminar, coordinated with ANSI and FDA, was part of a week-long program for

COPOLCO members.

"NIST Internal Report (IR) 6363, TBT Agreement Activities of the National Institute of

Standards and Technology 1998, published in August 1999, describes the role of NIST s

National Center for Standards and Certification Information (NCSCI) in support of the

World Trade Organization (WTO) Agreement on Technical Barriers to Trade (TBT). 

Under the U.S. Trade Agreements Act of 1979 and its amendments, NCSCI is responsible

for operating the U.S. WTO TBT inquiry point for information on standards, technical

regulations, and conformity assessment procedures that might significantly affect trade.

"OSS s Standards Assistance and Management Information (SAMI) project published the

 Directory of DOC Staff Memberships on Outside Standards Committees in

January 1999. This annual directory contains two indexes: (1) DOC staff committee

participants and (2) committee sponsors. The directory can be viewed electronically on

the SAMI Web site (<http://www.nist.gov/sami>).

"NIST officials from OSS participated in the annual Standards Engineering Society

Conference, Standards Strategies in a Competitive World, on August 16-17, 1999, in

Toronto, Canada.

"Based on a request by the Conformity Assessment Network, NIST launched a new Web

site (<http://ts.nist.gov/ca>) in September 1999, featuring conformity assessment issues,

programs, and procedures. This site is a one-stop shopping Web site for conformity

assessment information. The site contains the 1999 edition of NIST s Directory of

Federal Government Certification and Related Programs.

"Dr. Belinda Collins, Director of NIST OSS, took office as the International Laboratory

Accreditation Cooperation (ILAC) Chair at the annual ILAC meeting in Sydney,
9

Australia, in October 1999. The ILAC members represent laboratory accreditation bodies

in some 50 countries, plus three major regional organizations. ILAC aims to achieve

globally-accepted criteria for the recognition of the competence of accreditation bodies,

and the development of regional and world-wide mutual recognition arrangements based

on the needs of laboratories and their clients, and the importance of comprehensive audits

and periodic proficiency testing.

5.2 Department of Defense (DOD) - One major thrust of the Department s Military

Specifications (MilSpecs) Reform initiative was the emphasis on replacing military-unique

documents with voluntary consensus standards wherever there was a dual-use application. As a

result of this initiative, DOD carefully reviewed all of its 40,000 MilSpecs and standards and

identified documents with potential for becoming voluntary standards.

Also, the Department has put into place a very stringent system to review every new requirement

for a military-unique document to determine if a voluntary consensus document would be more

appropriate. At a minimum, new documents and revisions to existing documents must be

approved by a DOD senior executive. In addition, DOD activities are directed to review all

available sources to locate an appropriate voluntary consensus standard rather than create a

military-unique document. Further, its five-year review process identifies documents that did not

have a voluntary consensus standard counterpart at one time, but for which an appropriate

document may now have been created.

5.3 Department of Energy (DOE) - DOE continues to take a pro-active approach to

standards and standards management even as its mission changes in response to the conclusion of

the Cold War and shrinking Congressional appropriations. Within DOE, a number of programs

and facilities have shifted their focus from production, research, and/or development to

environmental remediation and restoration. DOE will literally be breaking new ground in these

areas. In the face of a changing mission and a reduced work force, DOE continues to actively use

and support the development of voluntary consensus standards to meet its needs. DOE is also

continuing its initiative to better define candidate DOE technical standards for conversion to

voluntary consensus standards.

5.4 Department of Health and Human Services (HHS), Food and Drug Administration

(FDA) - In November 1999, FDA conducted HHS-wide training on the requirements of OMB

Circular A-119. The training was designed for regulation writers and employees involved in

standards development and management activities. HHS is increasingly becoming involved in

the development and use of voluntary consensus standards. Additional HHS-wide training and

coordination activities are planned.
10

5.5 Consumer Product Safety Commission (CPSC) - At CPSC, the Voluntary Standards

Coordinator establishes agency views and decisions on standards issues using Commission

responses to staff briefing packages and recommendations. These views are reflected in the

Commission's Operating Plan and Budget.

5.6 Environmental Protection Agency (EPA) - In FY 1999, EPA promulgated 617 final rules,

of which 207 (33.5 percent) referenced the NTTAA. In addition, the Agency published a variety

of proposed rules, many of which also addressed compliance with the NTTAA. The total

number of final and proposed rules that contained reference to the NTTAA was 326. This

number reflects an increase of more than 300 percent over the 1998 report. This increase reflects

both the Agency s successful implementation of the NTTAA and the OMB Circular and the

publication of the interim Rule Writer s Guide last year.

In FY 1999, 10 final rules and 6 proposed rules adopted (or proposed for adoption) more than

45 voluntary consensus standards. Within 10 final rules, EPA found 83 instances where 18

voluntary consensus standards were found to be impracticable for agency use. Not all adopted

standards were new standards or newly referenced by EPA. In several cases, the references

included standards that had been previously adopted by EPA in other rulemaking activities.

One of the most notable examples of Agency rulemaking is found in the regulatory activities of

the Office of Air and Radiation (OAR) in the area of National Emission Standards for

Hazardous Air Pollutants. The following notation occurred in several OAR Federal Register

notices this year:

 As part of a larger effort, we are undertaking a project to cross-reference existing voluntary

consensus standards in testing, sampling, and analysis, with current and future EPA test

methods. When completed, this project will assist us in identifying potentially applicable

voluntary consensus standards that can then be evaluated for equivalency and applicability in

determining compliance with future regulations. 

5.7 Federal Communications Commission (FCC) - FCC uses voluntary standards in several

different ways:

"to satisfy industry and user requirements where it appears that mandatory standards are

unnecessary.

"to correct problems that might otherwise require regulation.

"as the basis for mandatory requirements--either incorporating voluntary standards by

reference or including the normative portion of the standard in the FCC rules.
2SECY-99-029, 

NRC Participation in the Development and Use of Consensus

Standards, January 28, 1999.

11

The Commission increasingly uses voluntary standards. In many instances, they have chosen not

to implement regulations (or more detailed regulations) because adequate voluntary industry

standards already exist or are under development.

5.8 Federal Emergency Management Agency (FEMA) - Although FEMA is a small agency,

they prefer using voluntary standards because no formal review process for standards usage has

been imposed on the program directors. FEMA participates in the high frequency (HF) industry

association working group to resolve HF standards problems, as well as the HF e-mail working

group.

FEMA continues to use Military Standard (MIL-STD) 188.141B for HF radio, although the

agency is working on a voluntary standard for transmitting e-mail via HF radio if landlines are

not available. FEMA also continues to use several MilSpecs in conjunction with its National

Emergency Management Information System.

5.9 General Services Administration (GSA) - GSA has become more selective in its

participation in standards organizations. As a result, the number of organizations GSA

participates in has decreased. GSA continues to emphasize the procurement of commercial offthe-shelf products and services. In addition, as a result of GSA 

s review of existing standards,

13 voluntary standards have been substituted for government-unique standards.

5.10 National Aeronautics and Space Administration (NASA) - In 1999, NASA completed

its review of voluntary standards currently in use and adopted an additional 430 voluntary

consensus standards, raising the total to 1,032. Citations for the adopted standards, along with

internal and other standards used by NASA, are accessible in a NASA Preferred Technical

Standards list publicly available on the Worldwide Web at <www.standards.nasa.gov>. This

site also provides information on NASA participation in voluntary consensus standards

development and gateways to other sources of standards.

An internal awareness campaign at NASA field centers, to make employees aware of the system,

has resulted in continuously increasing usage of the system as a reference data base for programs. 

In 1999, two NASA-initiated voluntary consensus standards projects were completed with

publication of standards, and two new projects were initiated. Meetings have also been held with

several SDOs to establish a basis for future cooperation, including possible transition of NASA

internal standards to voluntary consensus standards.

5.11 Nuclear Regulatory Commission (NRC) - The NRC staff used information gained from

its stakeholder meeting in Chicago in September 1998 to prepare a Recommendation2

 to the 
3Staff Requirements, SECY-99-029, February 17, 1999.

4Management Directive 6.5, 

NRC Participation in the Development and Use of

Consensus Standards, issued November 1999.

12

Commission to develop guidance for NRC staff when participating in the development and

utilization of consensus standards. The Commission supported the staff Recommendation.3

Based on the success of this meeting, future meetings will be held periodically.

Also, NRC staff prepared a management directive4 to support the NRC standards strategy. The

management directive defines NRC organizational responsibilities for standards activities and

provides direction for staff participation in the development and use of consensus standards. 

Specifically, the management directive provides direction for identifying and prioritizing needed

new and revised technical standards, selecting and nominating staff as authorized agency

representatives on SDO committees, and coordinating standards activities with SDOs and other

stakeholders. The management directive also requires periodic training of staff involved with

standards activities to update them on Federal requirements for standards development and to

discuss related issues.

6. AGENCY USE OF GOVERNMENT-UNIQUE STANDARDS IN LIEU OF

 VOLUNTARY CONSENSUS STANDARDS

6.1 Department of Defense (DOD) - The Department relies on MilSpecs and standards in lieu

of voluntary consensus documents when the requirement can be justified as truly military-unique,

when a voluntary standard does not exist and development is not imminent, or when there is no

industry interest to develop an appropriate voluntary standard.

Since the Department has a massive number of procurements, we have chosen to use the

categorical basis as our means of conveying information on our voluntary consensus standards

use.

6.2 National Aeronautics and Space Administration (NASA) - Because NASA uses the

 categorical method of reporting, use of government-unique standards is reported in terms of

additions to the NASA Technical Standards Management System, as opposed to tracking

individual procurement transactions. During 1999, NASA developed 11 NASA-unique technical

standards in three categories, namely: information technology, engineering, and safety and

mission assurance. There are four engineering standards, two of which are internal procedures

for the application of voluntary consensus standards and two are unique applications based on

spacecraft experiences with no current external interest. There are three safety and mission

assurance standards, with two being internal procedures and one based on aerospace applications. 

The last four standards are from the information technology area and are all procedural

documents for the application of commercial software.
13

6.3 Environmental Protection Agency (EPA) - In FY 1999, EPA found impracticable the use

of 18 existing voluntary consensus standards in 10 final rules, citing issues such as lack of

validation data, or in the case of one ISO standard (8178), on the standard s inability to

accommodate broad application because the standard relies too heavily on reference test

conditions. This resulted in 83 instances where EPA used government-unique standards in lieu

of voluntary consensus standards. Because the regulatory test procedures need to be used not

only for certification, but also for production line testing, selective enforcement audits, and inuse testing, they must be broadly based. The Agency determined that the ISO procedures are not

sufficiently broad in their current form and thus could not be adopted by reference.

In one National Emissions Standards for Hazardous Air Pollutants (NESHAP) rule, more than

12 standards were rejected in lieu of government-unique standards. EPA s reasoning and

justification are consistent with the NTTAA. The Federal Register notice states:

Candidate voluntary consensus standards for materials analysis were identified for freeformaldehyde content. Consensus comments provided by industry experts were that the

candidate standards did not meet industry materials analysis requirements. Therefore, EPA

has determined these voluntary consensus standards are impractical for the mineral wool

production NESHAP. The EPA, in consultation with the North American Insulation

Manufacturers Association (NAIMA), has formulated an industry-specific materials analysis

consensus standard for free-formaldehyde content, which is promulgated in this rule.

There has been an increase in EPA s instances reported of government-unique standards used in

lieu of voluntary consensus standards from the previous report. This is due, in part, to two

different phenomena. First, from 1997 to 1999, EPA put a series of tools in place that have

improved its rule writers  ability to find and evaluate standards. Second, EPA s use of voluntary

consensus standards cannot be analyzed by comparing absolute numbers from year-to-year, since

the Agency s regulatory agenda varies annually in the number and kinds of regulations

promulgated. Because of this fluctuation each year, the Agency s opportunity to use voluntary

consensus standards in regulation will vary. The EPA has included additional information at the

back of their portion of the report.

6.4 Federal Emergency Management Agency (FEMA) - As required by Public Law (P.L.)

104-113, identification of all instances when the agency used government-unique standards in

lieu of voluntary consensus standards:

FEMA continues to use Military Standard (MIL-STD) 188.141B for HF radio, although the

agency is working on a voluntary standard for transmitting e-mail via HF radio if landlines

are not available.

Developers of the National Emergency Management Information System used and continue

to use MIL-STD 498, Software Development and Documentation; MIL-STD 490A,

Specification Practices; MIL-STD 1521B, Technical Reviews and Audits for Systems,
14

Equipment and Computer Programs; and MIL-STD 2168, Defense System Software Quality

Program, et al. The Agency used these standards as part of a large project started in 1995. At

that time, the Agency wanted to use standards with which contractors were familiar. A solid,

proven standard that worked and would keep costs in line.

7. CONCLUSIONS

In FY 1999, Federal agencies have continued to implement P.L. 104-113 and OMB

Circular A-119.

Agencies continue to improve their procedures to track their uses of standards in both regulation

and procurement activities. The decline in agency participation in standards committees, as first

noted in the FY 1997 and 1998 reports, continues. This is most likely due to staff attrition,

budget cuts, and streamlining of agency standards programs. NIST is working with all agencies

on the timeliness of their annual reports to NIST and its report to OMB. NIST is also publishing

the annual report both in hard copy and on the Web at <http://ts.nist.gov/icsp>, so that agencies

and the public have ready access.

Agencies conduct standards related activities for a variety of reasons, such as to improve

procurement efforts, facilitate adoption of a standard in regulatory activities, better manage

agency programs through internal adoption of appropriate voluntary consensus standards,

represent the United States in standards activities with important potential trade implications,

advance U.S. technology both domestically and internationally, improve the U.S. standards and

conformity assessment systems, comply with treaty obligations, and share with industry

information and data from ongoing research efforts. These different reasons may create difficulty

in reporting due to confusion in determining which activities to report and how to report them. 

NIST is working with individual agencies on specific problems, and provides general

information to the ICSP.
15

Table 1. FEDERAL AGENCY INFORMATION ON PARTICIPATION/ADOPTION OF

VOLUNTARY STANDARDS ACTIVITIES REQUIRED BY OMB CIRCULAR A-119

(DATA AS OF 9/30/99)

AGENCY NO. OF

VOLUNTARY

CONSENSUS

STANDARDS

BODIES IN WHICH

AGENCY

PARTICIPATES

CHANGE

FROM FY 98

NO. OF AGENCY

EMPLOYEES

PARTICIPATING

CHANGE

FROM FY 98

NO. OF

VOLUNTARY

CONSENSUS

STANDARDS

USED SINCE

10/98

NO. OF

VOLUNTARY

CONSENSUS

STANDARDS

SUBSTITUTED

FOR GOVTUNIQUE

STANDARDS

NO. OF GOVTUNIQUE

STANDARDS

USED IN LIEU

OF

VOLUNTARY

CONSENSUS

STANDARDS

USDA 25 -21 39 -29 0 0 0

DOC 138 0 382 +3 0 0 0

DOD 48 -41 420 -263 627 (1) 491 -

NCS (DOD) 12 -5 15 +1 0 0 0

DOED 1 0 6 0 0 0 0

DOE 58 -7 668 (2) -13 916 0 0

HHS 43 (3) -3 255 -19 90 0 0

HUD 5 -5 6 -1 2 0 0

DOI 54 0 84 0 144 0 0

DOJ 3 0 8 0 59 0 0

DOL 22 0 65 +2 15 0 0 

STATE 1 0 6 0 0 0 0

DOT 120 +14 229 -63 238 28 0

TREASURY 9 +1 19 -2 6 0 0

VA 26 +23 12 +8 36 0 0

CPSC 65 +15 25 +4 4 0 0

EPA 15 +1 197 -3 34 0 83 (4)

FCC 24 (5) 0 50 +1 0 0 0

FEMA 1 +1 - - 1 - 5

GSA 79 -12 49 +4 0 13 0

NASA 45 +2 145 -3 430 (6) 8 0

NARA 8 -6 8 0 22 0 0

NSF 3 0 3 -1 0 0 0

NRC 18 (7) +2 141 -4 45 2 0

TOTALS 823 -41 2,832 -378 2,669 542 88
16

(1) Total number of DOD-adopted voluntary consensus standards is 8,618.

(2) DOE reports 1,306 total agency participations in standards development groups.

(3) HHS staff participates on a total of 544 voluntary consensus standards development

committees among these 43 bodies.

(4) EPA distinguishes between the total number of standards substituted and the number of

rulemaking decisions in which the standards were used. For more information with regard to

this, refer to the EPA s submission, which begins on page B-5. NOTE: EPA s submission

includes supplemental information that can be found in the table at the back of their portion of

the report. The 83 instances to use government unique standards refer, however, to only 18 individual

voluntary consensus standards. 

(5) FCC participations cover approximately 100 sub-groups with the 24 standards bodies.

(6) Total number of NASA-adopted voluntary consensus standards is 1,032.

(7) NRC staff participates on a total of 267 standards writing, consensus, and board-level

committees among the 18 standards developing organizations indicated.
17
18

8. RECOMMENDATIONS

Most Federal agencies have continued to progress in their use of voluntary consensus standards

for agency programs and missions for both procurement and regulatory activities. Where

appropriate, strategic alliances and teaming arrangements between Federal agencies and SDOs

may be beneficial in ensuring that this trend continues.

All Federal agencies should continue to strengthen their efforts to plan and allocate resources and

staff for participation in appropriate voluntary consensus standard activities.

Federal agencies should continue to develop policies and systems needed to implement the

NTTAA and OMB Circular A-119. Actions that should be considered include: (1) the

establishment of an agency standards policy, (2) monitoring standards activity participation and

resource allocation, and (3) taking steps to improve reporting and program effectiveness.

Decreasing Federal resources and staff can lower the priorities for standards and conformity

assessment activities within a department or agency. Some agencies are finding it difficult to

actively participate in the ICSP or its working groups. Resources for participation in standards

activities also appear to be diminishing making it difficult for agencies to ensure adequate

representation on appropriate committees. The ICSP Participation Work Group, led by DOD,

will strengthen its activities in FY 2000 to better understand the causes of these problems and to

assist the ICSP in taking appropriate action to improve the situation.

Federal agencies should make more effective use of today s technology in coordinating standards

participation across government, in positions on standards committee ballots, and in preparing

reports on status of standards activities including the annual report for OMB.

Since the 1996 revisions of the Circular, a number of reporting issues have arisen. In particular,

agencies are having some difficulties knowing when to report instances of government standards

being used in lieu of voluntary consensus standards. NIST plans to hold a workshop in FY 2000

to address this and other reporting issues to harmonize reporting from the agencies.

Some agencies report difficulty in updating out-of-date standards in their regulations. In a l997

survey of the U.S. Code of Federal Regulations, ASTM found that of the 1,000 references to

ASTM standards, more than 90 percent were at least 10 years out of date, some were more than

30 years. Current standards may reflect new technology; new products; more precise methods of

testing; and faster, cheaper, and better ways of doing things. It is vital that those who are

regulated have the ability to use current technology embedded in the standards and not be

weighed down or even endangered by out-of-date standards. It is also imperative that agencies

review newly revised voluntary standards to ensure that they adequately address all regulatory

concerns. The time and effort required to conduct such reviews, combined with the resources 
19

needed to go through rulemaking, can require the commitment of substantial agency resources--

resources which may not be available given other agency priorities. The ICSP RAWG is

focusing on procedures for improving the timeliness of updates of standards used in regulations.

These are just a few of the many problems that agencies have reported in their implementation

efforts. Yet most agencies are diligently trying to comply with both the Law and Circular. There

is increased use of voluntary standards by Federal agencies in both regulation and procurement,

and conformity assessment activities are now receiving greater attention than before passage of 

the Law.

A-1

APPENDIX A:

Cabinet Department Reports
A-2

DEPARTMENT OF AGRICULTURE (USDA)

The following information was prepared for the National Institute of Standards and Technology

(NIST) by USDA as required annually under Office of Management and Budget (OMB) Circular

A-119, Federal Participation in the Development and Use of Voluntary Standards. 

BACKGROUND

In the Department of Agriculture, the Chief Information Officer (CIO) also serves as the

Standards Executive. This has made the Office of the Chief Information Officer (OCIO) the

coordinating organization within USDA for reporting on OMB Circular A-119 activities.

METHOD

To prepare this report, OCIO sought information from USDA Agency Heads. Based on the

requirements sent out by NIST, the CIO requested the agencies to:

"identify the number of voluntary consensus standards used since October 1, 1998, based

on the procedures set forth in sections 11 and 12 of the Circular. For each instance,

include agency rationale for such use, as well as specific government-unique standard

used.

"identify voluntary consensus standards that have been substituted for government-unique

standards as a result of any agency review under section 15b(7) of the Circular.

"identify the number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participation.

"evaluate the effectiveness of Circular A-119 policy and recommendations for any

changes.

USDA PARTICIPATION IN THE DEVELOPMENT AND USE OF VOLUNTARY

STANDARDS IN FISCAL YEAR (FY) 1999

Two USDA agencies, the Rural Utilities Service and the Agricultural Marketing Service reported

participation in voluntary standards development and use during FY 1999.

Rural Utilities Service (RUS)

The RUS has engineering missions to provide quality engineering for RUS customers in the RUS

Electric, Telecommunications, and Water and Waste Programs. Many RUS employees

participated in organizations that are developing voluntary standards.
A-3

RUS policy is to use, to the fullest extent possible, standards, rules, and regulations of recognized

standards-writing organizations in lieu of producing separate RUS specifications. This policy,

which is included in §1728.20 of 7 CFR 1728, was in effect many years before the OMB Circular

A-119 was published.

RUS maintains membership on a number of committees. RUS's interest is to oversee all aspects

of the various committees' standards-writing efforts to ensure that rural electric,

telecommunications, and water and waste concerns are included. The ultimate goal is to either:

"adopt the various standards, as appropriate, rather than generate individual RUS

standards.

or

"ensure that those standards that are regulatory in nature and generally must be observed

by borrowers contain cost-effective, reasonable requirements for rural areas and thus,

ensure or protect the security of government loans.

Electric Program

Over the years, the Electric Program of RUS has adopted or referenced the following standard

specifications, etc., in its specifications and regulations which RUS electrification borrowers

must comply with when using loan funds:

"Seventeen (17) procurement-type standards of the American Society for Testing and

Materials (ASTM).

"Twenty-one (21) procurement-type standards of the American Wood Preservers 

Association (AWPA).

"Four (4) national design standards of the American Society of Civil Engineers (ASCE),

the American Concrete Institute (ACI), the Prestressed Concrete Institute (PCI),and the

American Welding Society (AWS).

"Three (3) building codes of the International Conference of Building Officials (ICBO)

Uniform Building Code, the Building Officials and Code Administrators (BOCA)

National Building Code, and the Southern Building Code Congress (SBCC) Standard

Building Code.

"Two (2) national lumber grading rules of the Southern Pine Inspection Bureau (SPIB)

Grading Rules and the West Coast Lumber Inspection Bureau (WCLB) Grading Rules.

"Fourteen (14) procurement-type standards of the American National Standards Institute

(ANSI).

"One (1) national safety code of the ANSI.

"One (1) procurement-type standard of the Institute of Electrical and Electronics Engineers

(IEEE).

"Two (2) procurement-type standards of the Insulated Cable Engineers Association.
A-4

Telecommunications Program

Over the years, the Telecommunications Program of RUS has adopted or referenced the

following standard specifications, etc., in its specifications and regulations which RUS

telecommunications borrowers must comply with when using loan funds:

"Four (4) procurement-type standards of the American Society for Testing and Materials

(ASTM).

"Two (2) Underwriters Laboratories procurement-type standards.

"Two (2) regulation and 1 procurement-type standard of the American National Standards

Institute (ANSI).

"Three (3) procurement-type standards of the Electronic Industries Association (EIA).

"Two (2) procurement-type standards of the IEEE.

"One (1) procurement-type standard of the Alliance for Telecommunications Industry

Solutions (ATIS) Protection Engineers  Group.

"Three (3) procurement-type standards of the Aluminum Association.

"Two (2) procurement-type standards of the International Radio Consultive Committee

(CCIR).

"Three (3) procurement-type Military Standards.

Water and Waste Program

Over the years, the Water and Waste Programs of RUS have adopted or referenced the following

standard specifications, etc., in its specifications and regulations which RUS water and waste

borrowers must comply with when using loan funds:

"All appropriate piping standards of the ASTM.

"All appropriate piping standards of the American Water Works Association (AWWA).

"For water system testing, leakage must not exceed the limits set by ASTM or AWWA,

whichever is more stringent.

Inasmuch as RUS has had the policy of referencing available recognized national or industrytype standards whenever possible, long before publication of OMB Circular A-119, there is

almost no change in RUS  reporting for all programs since the last report. All new or revised

RUS standards produced during 1999 have included, whenever possible, appropriate standards of

those other organizations to simplify and streamline RUS documents/requirements.

Agricultural Marketing Service (AMS)

AMS reports that 21 employees participated in 8 national voluntary standards bodies, and

18 employees participated in 17 international voluntary consensus standards bodies in FY 1999.
A-5

Since October 1, 1997, the agency has used the following voluntary consensus standards: 

Agreement on the International Carriage of Perishable Foodstuffs and Special Equipment,

Certification Standards of the American Association of Seed Certifying Agencies, Codex

Alimentarius International Grade Standards, Universal Cotton Standards Agreement, Analytical

Standards of the ANSI, Test Standards of the ASTM, and International Meat Purchase

Specifications. With the participation of the industry, AMS has developed 602 grade and

classification standards that have been accepted by the industry for marketing of 230 agricultural

commodities. These standards were created in response to the needs expressed by the industry

for uniform standards that could be used and certified nationwide. The usage of these standards

is voluntary.

In addition, AMS guided the development of 25 International Organization for Standardization

standards for the accreditation of the laboratories performing microbiological and chemical

testing, and the (3-A) Sanitary Standards of the International Association of Food Protection to

provide specifications for the dairy processing equipment.

At the request from and with the participation of the industry, AMS has developed 602 grade and

classification standards that are generally recognized by the industry for use in marketing of 230

agricultural commodities. While developed and maintained by AMS, these standards were

created in response to the needs expressed by the industry for uniform standards that could be

used nationwide. The usage of these standards is voluntary.

The American Dairy Products Institute has published a series of milk and dry milk standards that

can be used when USDA certification is not requested by the buyer or seller. These standards are

based on the USDA standards and contain the same requirements as the U.S. Grade standards. 

However, the majority of the industry prefers USDA certification because of its official value in

certification.

AMS has developed numerous grading and classification standards in response to requests from

the industry. AMS does not view these standards and classifications as government-unique since

they were developed with full consultation and participation of the industry and their usage by

the industry is voluntary. AMS uses government-unique specifications for the grading and

certification of tobacco products. Authority for this program is contained in the Tobacco

Statistics Act of 1929 and the Tobacco Inspection Act of 1935, as amended. Provisions of these

acts require that all tobacco sold at auction must be inspected and graded by USDA according to

the U.S. standards. AMS also uses government-unique specifications for purchases of

commodities for the School Lunch Program and other domestic feeding programs when

voluntary consensus standards do not meet the nutritional or program requirements of these

programs.

The above statement means that USDA develops unique specifications to meet the need of the

food program, which may not be consistent with specifications of commercially similar products. 
A-6

These specifications are used for nutritional reasons; for example, a commercial standard might

allow for peaches to be packed in heavy syrup; whereas, AMS specifications ensure that peaches

are packed in light syrup. Frequently, these specifications allow for less salt, fat, and sugar than

commercial specifications.
A-7

DEPARTMENT OF COMMERCE (DOC)

The DOC encourages its staff to participate in standards committee activities relating to the

mission of the Department, subject to resource availability. Agency employees participate in the

standards development activities of : (1) U.S. private sector standardization bodies; (2) local,

state, and Federal governments; and (3) both private and governmental (treaty and nontreaty)

international standardization organizations. Standards of interest to the Department cover a

broad range of technical areas including: (1) energy conservation, (2) information and computer

technology, (3) telecommunications, (4) environmental safety and health, and (5) a variety of

other product sectors and fields of technology.

The Standards Assistance and Management Information (SAMI) project in the Office of

Standards Services (OSS), National Institute of Standards and Technology (NIST), collects and

disseminates information on DOC staff participation in standards development activities. The

SAMI project publishes an annual directory containing statistics on standards committee

participation, alphabetical listings of staff participants and standards organizations and

committees, and a list of acronyms and abbreviations.

The DOC standards participant information is divided into two parts: NIST and other DOC

agencies. During FY 1999, 393 DOC staff participated in the standards writing activities of 152

(110 national and 42 international) standards developing organizations. NIST had 326

participants in the activities of 110 standards organizations (76 national and 34 international). 

NIST participated on 368 committees and held 1,175 memberships on these committees. Ten of

the standards organizations in which NIST staff members participated had 15 or more NIST

memberships. Sixty-eight staff members of other DOC agencies participated in 66 committees

of 42 standards organizations (27 national and 15 international). They held 139 memberships on

those committees. Eight of those standards organizations had five or more DOC participants.

The following organizations/agencies accounted for 66 percent (92) of the 139 other DOC

committee memberships:

Organizations with Other DOC Members: No. of Committee Memberships

American National Standards Institute 19

Office of Management and Budget 26

Department of Defense/Federal Aviation

Administration/Department of Commerce 6

Federal Committee for Metrological Service and

Supporting Research 6

Department of State 15
A-8

International Organization for Standardization 8

International Telecommunication Union - Telegraph 7

International Telecommunication Union - Radio 5

 _____

Total 92

The following standards organizations accounted for 81 percent (949) of the 1,175 NIST

committee memberships:

Organizations with NIST Members: No. of Committee Memberships

American Society for Testing and Materials 572

American National Standards Institute 111

Institute of Electrical and Electronic Engineers 41

International Organization for Standardization 68

American Society of Mechanical Engineers 33

International Organization of Legal Metrology 26

International Electrotechnical Commission 33

American Concrete Institute 21

Telecommunications Industry Association 20

CIE 24

 _______

Total 949

OTHER DOC AGENCIES: SUMMARY OF STANDARDS-RELATED ACTIVITIES

National Oceanic and Atmospheric Administration (NOAA)

Standardization of data acquisition and data management practices is vital to the mission at

NOAA. NOAA seeks to establish voluntary standards with selected industrial associations,

academia, and national organizations of state and local governments (e.g., the American

Association of State Climatologists), as well as through participation in professional societies

(e.g., American Meteorological Society). All NOAA line organizations participate in standards

development activities. In general, standards used in many NOAA activities are established in

conjunction with other Federal agencies (e.g., Department of Defense, Federal Aviation

Administration, U.S. Department of Agriculture) either through joint participation in

international organizations such as the World Metrological Organization, or by means of bilateral

and multilateral agreements with other nations. These standardization activities apply to all

phases of environmental data acquisition, processing and distribution.
A-9

National Telecommunications and Information Administration (NTIA)

The NTIA contributes to the development and application of national and international

telecommunication standards by participating and holding leadership roles in various voluntary

standards committees at the national and international levels (e.g., Telecommunications Industry

Association, International Telecommunication Union). These standards enhance the quality and

reliability of the domestic telecommunications infrastructure, promote healthy competition in

telecommunications products and services, and expand international trade opportunities for U.S.

telecommunications firms.

Patent and Trademark Office (PTO)

The PTO participates and contributes to the resolution of identified requirements for international

standards, primarily through the Permanent Committee on Industrial Property Information of the

World Intellectual Property Organization. PTO staff also participates in standardization

activities of the International Patent Classification Union and the American National Standards

Institute (ANSI) committee on Patent Standards.

Bureau of the Census

DOC s Bureau of the Census is active in the development of standards and specifications for: 

(1) the definition of metropolitan statistical areas; (2) the digitizing of geographic information;

and (3) the definition of statistical, economic, and geographic terms.

NIST: Summary of Standards-Related Activities

In addition to the activities described above, NIST s OSS operates a number of standards-related

programs and services to assist business, industry, and government in using and understanding

standards, technical regulations, and conformity assessment procedures affecting trade in the

global marketplace.

"The National Center for Standards and Certification Information (NCSCI) is the U.S.

focal point for standards-related information at home and abroad; it provides information

on U.S., foreign, regional, and international voluntary standards bodies, mandatory

government regulations, and conformity assessment procedures for nonagricultural

products. NCSCI is the U.S. member of the International Organization for

Standardization (ISO) Information Network, and serves as the U.S. inquiry point under

the World Trade Organization Agreement on Technical Barriers to Trade, the North

American Free Trade Agreement (NAFTA), and the Asia Pacific Economic Cooperation

Subcommittee on Standards and Conformance. NCSCI maintains an extensive collection

of reference materials, including U.S. military and other Federal Government

specifications, U.S. industry and national standards, international standards, and selected

foreign national standards.
5Directory of DOC Staff Memberships on Outside Standards Committees.

A-10

"Staff members respond to requests for specialized standards information, arrange for

translations of foreign standards and regulations, and disseminate information to U.S.

industry concerning proposed foreign regulations and general standards issues.

"Two telephone hotlines provide weekly updates on draft European standards and on

proposed foreign technical regulations that might significantly affect trade.

NIST Standards Advisory Committee (SAC)

To coordinate internal standards activities, NIST established a SAC. The SAC created a NIST

Voluntary Standards Policy, which was approved by NIST management in 1999 and is now

being implemented. This policy directs NIST organizational units to review their standardsrelated activities to ensure that they are in line with the agency 

s mission and goals so that

resources and participation are targeted most effectively. NIST currently has about

330 employees participating in more than 1,200 standards committee activities. The policy is

expected to assist in aligning this participation as closely as possible with applicable NIST and

industry needs. Because NIST also coordinates standards activities within DOC, including

publishing the Annual Directory5 and providing DOC input for the Annual Report, NIST

chartered a Commerce Standards Committee in 1999 to improve communication and

coordination on standards-related activities among DOC agencies.

Federal Information Processing Standards (FIPS)

Under the Information Technology Management Reform Act (Public Law (P.L.) 104-106), the

Secretary of Commerce approves standards and guidelines that are developed by NIST for

Federal computer systems. Under section 513 of the Information Technology Management

Reform Act of 1996 and the Computer Security Act of 1987, P.L. 104-106, NIST develops

standards, guidelines, and associated methods and techniques for Federal computer systems,

including those needed to assure the cost-effective security and privacy of sensitive information

in Federal computer systems, when there are compelling Federal requirements and there are no

existing voluntary industry standards. These standards and guidelines are issued by NIST as

FIPS for use government-wide. FIPS address Federal requirements for the interoperability of

different systems, for the portability of data and software, and for computer security. When FIPS

are considered necessary, NIST announces proposed FIPS in the Federal Register for public

review and comment. No new FIPS were published in FY 1999, which required justification.
A-11

Following is a quick summary of 1999 Federal Register notices regarding FIPS:

Federal Register: January 15, 1999 (Volume 64, Number 10)

This notice announced proposed FIPS 46-3, Data Encryption Standard (DES), to provide for

the use of ANSI X9.52, Triple DES.

Federal Register: November 5, 1999 (Volume 64, Number 214)

This notice announced the approval of FIPS 46-3, Data Encryption Standard, to provide for

the use of ANSI X9.52, Triple DES.

Federal Register: November 17, 1999 (Volume 64, Number 221)

This notice announced proposed draft FIPS 140-2, Security Requirements for Cryptographic

Modules, to supersede FIPS 140-1, which required review within 5 years of its issuance. The

proposed FIPS concerns the security requirements for the modules that implement FIPSapproved cryptographic algorithms.

Federal Register: September 15, 1999 (Volume 64, Number 178)

This notice announced the continuation of the process to develop a FIPS for an Advanced

Encryption Standard (AES) specifying an Advanced Encryption Algorithm. The notice

solicited comments on algorithms that had been submitted by interested individuals and the

private sector and that are being publicly reviewed as candidates for the AES.

Conformity Assessment Activities - National Cooperation for Laboratory Accreditation

(NACLA)

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

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

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

has been a driving force behind the creation of NACLA. NACLA is composed of organizations

in the United States, with observers from Mexico and Canada, that actively support development

of a system for recognizing the competence of testing and calibration laboratories leading to

worldwide acceptance of test and calibration reports from those laboratories. Concerned with

costly, multiple, duplicate assessments, and the lack of domestic or international recognition of

laboratory accreditations, the group has explored solutions that could lead the United States, and

perhaps eventually its NAFTA partners, toward the goal of having only one assessment of a

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

vision is for a U.S. and eventually a North American laboratory accreditation system that

achieves the following goals:

- for the testing laboratory, a single accreditation in a given field of testing, with worldwide

recognition of the laboratory's competence.

- for the manufacturer/supplier, a test performed once, with worldwide acceptance.
A-12

- for the acceptance body (that is a government agency or an industry specifier), an

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

qualified to provide data of consistent quality.

Mutual Recognition Agreements (MRAs)/Arrangements

NIST has also worked to reduce duplication and complexity in conformity assessment activities

by participating in, or providing technical support for, various MRAs and related agreements

such as the Asia Pacific Laboratory Accreditation Cooperation and the U.S./Standards Council of

Canada agreement on calibration laboratory accreditation. To implement the Agreement of

Mutual Recognition Between the United States of America and the European Community (U.S.-

EU MRA), NIST works through its National Voluntary Conformity Assessment Systems

Evaluation program to provide U.S. Government assurance of the competence of U.S. conformity

assessment bodies to meet European governmental requirements. The ultimate goal is to help

U.S. manufacturers satisfy applicable product requirements mandated by other countries through

conformity assessment procedures conducted in the United States prior to export, thereby

reducing or eliminating the need for retesting by the importing country.

National Workshop on Conformity Assessment and the Conformity Assessment Network (CAN)

On February 9, 1999, NIST co-sponsored a major national workshop on conformity assessment

issues with ANSI and ACIL, formerly the American Council of Independent Laboratories. This

meeting concluded that: (1) the U.S. conformity assessment system is very complex and all

parties need to work together to simplify it, and (2) both the Federal Government and the private

sector need to harmonize their conformity assessment activities to reduce duplication and

complexity. One outcome of the meeting was the formation of a public/private sector

organization known as the CAN. This organization identified the lack of basic information on

conformity assessment-related topics as a key concern for the community. To address this need,

NIST created a one-stop shopping Web site for conformity assessment-related information,

ranging from ISO 9000 issues to conformity assessment topics under the U.S.-EU MRA.

Conformity Assessment Guidance

OMB Circular A-119, revised February 19, 1998, recognized the conformity assessment

requirements and obligations defined in the Act and the role of DOC in this area. The Circular

directed the Secretary of Commerce to issue guidance to agencies to ensure effective

coordination of Federal conformity assessment activities. On November 3, 1999, NIST

published proposed guidance on Federal conformity assessment activities in the Federal Register. 

The proposed guidance focuses on ways for Federal agencies to eliminate unnecessary

duplication and complexity in their conformity assessment activities. The comment period on

the proposed guidance ended January 18, 2000, and comments including recommendations

appearing in a recent Government Accounting Office report, are currently being reviewed. Final

guidance will be published later this year.
A-13

Other Standards Management Guidance

NIST has further recognized that to address the tenets of the NTTAA, a new style of managing

standards activities is required. To this end, NIST created a model plan for strategic management

of standards activities. Because each agency s standards efforts tend to be unique, the generic

plan can be tailored to suit the needs of individual agencies. This guidance was published in

1999, both as a NIST publication and in ASTM Standardization News. NIST is also updating its

Guidelines to Standards Participants in coordination with Environmental Protection Agency s

revision of its Rule Writer s Guide for Standards Participants and has provided an outline of

these guidelines to the Interagency Committee on Standards Policy to serve as a model for other

agencies  efforts.
A-14

DEPARTMENT OF DEFENSE (DOD)

The DOD implements the provisions of Public Law (P.L.) 104-113 and Office of Management

and Budget (OMB) Circular A-119 through DOD 4120.3-M, Defense Standardization Program

Policies and Procedures. As set forth in our existing policies, our activities routinely consider

meeting the Department's requirements with items or materials that are normally procured using

voluntary consensus standards. Our guidance further tasks standards developers to actively look

for opportunities to replace government-unique documents with voluntary consensus standards.

One major thrust of the Department s Military Specifications (MilSpec) Reform initiative was

the emphasis on replacing military unique documents with voluntary consensus standards

wherever there was a dual-use application. As a result of this initiative, DOD carefully reviewed

all of its 40,000 MilSpecs and standards and identified documents with voluntary standards

potential. In instances where replacement voluntary consensus standards were available, the

Department acted quickly to cancel the military documents and begin using voluntary consensus

standards. In cases where voluntary consensus replacements were needed but not available, the

DOD began working with standards developers to create appropriate standards.

Also, the Department has put into place a very stringent system to review every new requirement

for a document to determine if a voluntary consensus document would be more appropriate. At a

minimum, new documents and revisions to existing documents must be approved by a DOD

senior executive. In addition, DOD activities are directed to review all available sources to

locate an appropriate voluntary consensus document rather than create a military-unique

document. Further, our 5-year review process identifies documents that did not have a voluntary

consensus counterpart at one time, but for which an appropriate document may now have been

created.

The Department's initial review and correction procedures, coupled with oversight in the creation

of new military documents, and periodic review of existing military documents, ensures very

little proliferation of government-unique documentation.

In summary, the Department relies on MilSpecs and standards in lieu of voluntary consensus

documents when the requirement can be justified as truly military-unique; when a voluntary

standard does not exist and development is not imminent; when there is no industry interest to

develop an appropriate voluntary standard.

Since the Department has a massive number of procurements, we have chosen to use the

categorical basis as our means of conveying information on our voluntary consensus standards

use.

DOD Employee Participation -- The Department has 420 employees participating in the

standards development activities of 48 voluntary standards bodies.
A-15

DOD Adopted Voluntary Standards -- Since our input for the fiscal year (FY) 1998 report, we

have adopted an additional 627 voluntary standards, bringing the total number of DOD-adopted

voluntary standards to 8,618.

Government Standards Replaced by Voluntary Standards -- The following 491 governmentunique specifications and standards were replaced by voluntary standards since our FY 1998

report:

Defense and Federal Specifications and Standards Superseded by Non-Government Standards

Between October 1, 1998 and September 30, 1999

NGS BODY MILITARY/FED DOCUMENT NGS REPLACEMENT DOC

American National Stand ards Institute (ANSI) MIL-B-55130/2 NOT 2 ANSI-C18.2

American Society for Testing and Materials (ASTM) MIL-T-6945A NOT 2 ASTM-B135-95

MS14302 NOT 1 ASTM-B42-98

MIL-T-16343C(1) NOT 3 ASTM-A500-99

MIL-P-22296B NOT 2 ASTM-D1710-96

MIL-D-24194(1) NOT 3 ASTM-F859-95

MIL-P-43988C NOT 2 ASTM-D3905-93

MIL-R-46089C NOT 1 ASTM-D1056-98

MS51561(1) NOT 1 ASTM-F1145-92R97

MS51562(1) NOT 1 ASTM-F1145-92R97

MS51563(1) NOT 1 ASTM-F1145-92R97

MS51564(1) NOT 1 ASTM-F1145-92R97

MS51565(1) NOT 1 ASTM-F1145-92R97

MS51566(1) NOT 1 ASTM-F1145-92R97

MS51567(1) NOT 1 ASTM-F1145-92R97

MS51568(1) NOT 1 ASTM-F1145-92R97

MS51569(1) NOT 1 ASTM-F1145-92R97

MS51570(1) NOT 1 ASTM-F1145-92R97

MS51571(1) NOT 1 ASTM-F1145-92R97

MS51572(1) NOT 1 ASTM-F1145-92R97

MS51573(1) NOT 1 ASTM-F1145-92R97

MS51574(1) NOT 1 ASTM-F1145-92R97

International Electrotechnical Commission (IEC) MIL-B-18/31D NOT 1 IEC60086-2

MIL-B-18/3D NOT 1 IEC60086-2

National Aerospace Standards Committee (NA/NAS) AN42THRUAN49 RE V 6 NOT 1 NASM42THRU49

AN229 REV 5 NOT 1 NASM229

AN256 REV 5 NOT 2 NASM256

AN302 NOT 3 NASM302

AN315 REV 10 NOT 1 NASM315

AN316 REV 11 NOT 1 NASM316

AN320 REV 14 NOT 1 NASM320

AN501 REV 6 NOT 1 NASM501

AN961 REV 2 NOT 1 NASM961

MS3212B NOT 2 NASM3212

MS3213A NOT 2 NASM3213

MS3369D NOT 1 NASM3369

MIL-P-5673D NOT 1 NASM5673

MIL-B-6812E NOT 1 NASM6812

MIL-B-7838C(1) NOT 1 NASM7838

MIL-DTL-7885/2D NOT 2 NAS9301-98

MIL-DTL-7885/6D NOT 2 NAS9304-98

National Aerospace Standards Committee (NA/NAS) MIL-R-7885/7C (1) NOT 2 NAS9305-98
A-16

MIL-R-7885/3C (1) NOT 2 NAS9302-98

MIL-B-8906C(2) NOT 1 NASM8906

MIL-F-8975/1A NOT 2 NASM8975/1

MIL-F-8975/7 NOT 1 NASM8975/7

MIL-F-8975/6 NOT 1 NASM8975/6

MIL-F-8975/3A NOT 1 NASM8975/3

MIL-F-8975/4A(1) NOT 1 NASM8975/4

MIL-F-8975/5A NOT 1 NASM8975/5

MS14144C (1) NOT 1 NASM14144

MS14145C NOT 1 NASM14145

MS14151(1) NOT 2 NASM14151

MS14155 NOT 2 NASM14155

MS14157B NOT 2 NASM14157

MS14219A NOT 1 NASM14219

DS14289 NOT 1 NASM14289

DS14290 NOT 3 NAM14290

MS16187B NOT 1 NASM16187

MS16205A NOT 3 NASM16205

MS16206A NOT 3 NASM16206

MS16228A(1 ) NOT 1 NASM16228

MIL-G-16491/1 NOT 1 NASM16491/1

MIL-G-16491/2 NOT 1 NASM16491/2

MIL-G-16491/3 NOT 1 NASM16491/3

MS16536A NOT 1 NASM16536

MS16556B (1) NOT 2 NASM16556

MS16562C NOT 2 NASM16562

MS17855A NOT 2 NASM17855

MS17984F NOT 1 NASM17984

MS17985G NOT 1 NASM17985

MS17986G NOT 1 NASM17986

MS17987G NOT 1 NASM17987

MS17989E NOT 1 NASM17989

MS17990E NOT 1 NASM17990

MS18067A NOT 2 NASM18067

MS20004THRUMS20024E NOT 1 NASM20004THRU20024

MS20033THRUMS20046C NOT 1 NASM20033THRU20046

MS20066A NOT 2 NASM20066

MS20067A NOT 2 NASM20067

MS20068A NOT 2 NASM20068

MS20392F NOT 1 NASM20392

MS20427H NOT 1 NASM20427

MS20604K NOT 1 NASM20604

MS20615G NOT 1 NASM20615

MS21042M NOT 1 NASM21042

MS21044H NOT 1 NASM21044

MS21047F NOT 1 NASM21047

MS21048F NOT 1 NASM21048

MS21050D NOT 1 NASM21050

MS21052F NOT 2 NASM21052

MS21053D NOT 1 NASM21053

MS21054E NOT 2 NASM21054

MS21057G NOT 1 NASM21057

MS21059J NOT 1 NASM21059

MS21061G NOT 1 NASM21061

MS21069G NOT 1 NASM21069

MS21072G(1 ) NOT 1 NASM21072

MS21073G NOT 1 NASM21073

MS21075H NOT 1 NASM21075

MS21078G(2 ) NOT 1 NASM21078

MS21079F NOT 1 NASM21079

MS21080D NOT 1 NASM21080

MS21082F NOT 1 NASM21082

MS21084B NOT 1 NASM21084

National Aerospace Standards Committee (NA/NAS) MS21086D NOT 1 NASM21086

MS21087B NOT 1 NASM21087
A-17

MS21094(1) NOT 1 NASM21094

MS21095A NOT 2 NASM21095

MS21125F NOT 1 NASM21125

MS21130E NOT 1 NASM21130

MS21134 NOT 2 NASM21134

MS21140J NOT 1 NASM21140

MS21250L NOT 2 NASM21250

MS21258A NOT 1 NASM21258

MS21262D NOT 2 NASM21262

MS21266E (1) NOT 3 NASM21266

MS21287B NOT 2 NASM21287

MS21299A NOT 1 NASM21299

MS21314B NOT 1 NASM21314

MS21315A NOT 1 NASM21315

MS21318A NOT 2 NASM21318

MS21322D NOT 1 NASM21322

MS21333F NOT 1 NASM21333

MS21334B NOT 1 NASM21334

MIL-S-21472C NOT 1 NASM21472

MIL-DTL-22529/1C NOT 1 NASM22529/1

MIL-C-24066/4 D NOT 1 NASM24066/4

MS24661C NOT 1 NASM24661

MS24662B NOT 1 NASM24662

MS24665F NOT 2 NASM24665

MS24673D(1) NOT 1 NASM24673

MS24677D NOT 1 NASM24677

MS24678E NOT 1 NASM24678

MS24692D NOT 2 NASM24692

MIL-R-27384B NOT 1 NASM27384

MIL-K-27545B NOT 1 NASM27545

MS27576E NOT 1 NASM27576

MS27975D NOT 1 NASM27975

MS27984B NOT 3 NASM27984

MS33522C NOT 2 NASM33522

MS35140D NOT 1 NASM35140

MS35273C (1) NOT 2 NASM35273

MS35274C (1) NOT 1 NASM35274

MS35672B NOT 2 NASM35672

MS35674A NOT 2 NASM35674

MS35675B NOT 2 NASM35675

MS35677A NOT 2 NASM35677

MS35678B NOT 3 NASM35678

MS35751E NOT 1 NASM35751

MS35756E NOT 1 NASM35756

MS35792B NOT 1 NASM35792

MS35812E NOT 1 NASM35812

MS39086B NOT 2 NASM39086

MS39087F(1 ) NOT 1 NASM39087

MIL-S-43770(3) SUP 1 NOT 1 NASM43770

MIL-S-43770/1A NOT 3 NASM43770/1

MIL-S-43770/2A NOT 2 NASM43770/2

MIL-S-43770/3 NOT 3 NASM43770/3

MIL-S-43770/4 NOT 3 NASM43770/4

MIL-S-43770/5 NOT 3 NASM43770/5

MIL-S-43770/6 NOT 3 NASM43770/6

MIL-S-43770/7 NOT 3 NASM43770/7

MIL-S-43770/8 NOT 3 NASM43770/8

MIL-S-43770/9 NOT 3 NASM43770/9

MIL-S-43770/10 NOT 3 NASM43770/10

MIL-S-43770/11 NOT 3 NASM43770/11

MIL-S-43770/12A NOT 3 NASM43770/12

MIL-S-43770/13 NOT 3 NASM43770/13

National Aerospace Standards Committee (NA/NAS) MIL-S-43770/14 NOT 3 NASM43770/14

MIL-R-47195A NOT 2 NASM47195

MIL-R-47196A(1) NOT 3 NASM47196
A-18

MS51021C NOT 1 NASM51021

MS51023C NOT 1 NASM51023

MS51029B NOT 1 NASM51029

MS51031B NOT 1 NASM51031

MS51038B NOT 1 NASM51038

MS51109B NOT 2 NASM51109

MS51110B NOT 3 NASM51110

DS51417 NOT 1 NASM51417

MS51575A NOT 1 NASM51575

MS51833E (1) NOT 1 NASM51833

MS51834E (1) NOT 1 NASM51834

MS51896A(1 ) NOT 1 NASM51896

MS51923C NOT 1 NASM51923

MS51956A NOT 1 NASM51956

MS51958C (1) NOT 1 NASM51958

MS51963C NOT 1 NASM51963

MS51964E NOT 2 NASM51964

MS51975E NOT 1 NASM51975

MS51976A NOT 2 NASM51976

MS51977C NOT 1 NASM51977

MS51981C NOT 1 NASM51981

MS51982A NOT 1 NASM51982

MS51987A NOT 1 NASM51987

MIL-F-81177/1 NOT 2 NASM81177/1

MIL-F-81177/2 NOT 2 NASM81177/2

MIL-F-81177/3 NOT 2 NASM81177/3

MIL-R-83459/1 B NOT 1 NASM83459/1

MIL-R-83459/3 B NOT 2 NASM83459/3

MIL-N-85353/1(1) NOT 2 NASM85353/1

MS122196 THRUMS1222 35D NOT 2 NASM122196THRU122235

MS122236 THRUMS1222 75D NOT 1 NASM122236THRU122275

MS124731 THRUMS1247 70D NOT 3 NASM124731THRU124770

Nationa l Electric al Manufacturers Association (NEMA) MIL-W-16878/4C(1) NOT 1 NEMA-HP3-97

MIL-W-16878/24A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/23A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/13B(1) NOT 1 NEMA-HP4-97

MIL-W-16878/12D(1) NOT 1 NEMA-HP4-97

MIL-W-16878/11B(1) NOT 1 NEMA-HP4-97

MIL-W-16878/35A NOT 1 NEMA-HP3-97

MIL-W-16878/34A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/28A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/27A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/26A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/25A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/5C(1) NOT 1 NEMA-HP3-97

MIL-W-16878/20A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/21A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/22A(1) NOT 1 NEMA-HP3-97

MIL-W-16878/6C(1) NOT 1 NEMA-HP3-97

MIL-W-80043C NOT 1 NEMA-EW1-88

Parachute Industry Association MS70085D NOT 2 PIA-PS70085

MS70092B NOT 2 PIA-PS70092

Society of Automotive Engineers (SAE) AN490 REV 8 NOT 1 SAE-AS4901

MIL-C-601G(1) NOT 1 SAE-AS6011

AN774 REV 7 NOT 1 SAE-AS5160

Society of Automotive Engineers (SAE) AN775 REV 13 NOT 1 SAE-AS5161

AN783 REV J NOT 1 SAE-AS1036D

AN784 REV L NOT 1 SAE-AS1032C
A-19

AN804 REV G NOT 1 SAE-AS1033C

AN806 REV 7 NOT 1 SAE-AS5168

AN807 REV 6 NOT 1 SAE-AS5180

AN814 REV 14 NOT 1 SAE-AS5169

AN815 REV 9 NOT 1 SAE-AS5174

AN821 REV 8 NOT 1 SAE-AS1034C

AN824 REV 7 NOT 1 SAE-AS1035C

AN827 REV 7 NOT 1 SAE-AS1036D

AN833 REV 8 NOT 1 SAE-AS1038C

AN834 REV 9 NOT 1 SAE-AS1039C

AN837 REV 8 NOT 1 SAE-AS1040C

AN841 REV 5 NOT 1 SAE-AS5184

AN849 REV 11 NOT 1 SAE-AS5189

AN910 REV J NOT 1 SAE-AS4859

AN911 REV 9 NOT 1 SAE-AS4860

AN912 REV 9 NOT 1 SAE-AS4861

AN914 REV 9 NOT 1 SAE-AS4854

AN915 REV K NOT 1 SAE-AS4855

AN916 REV 10 NOT 1 SAE-AS4856

AN917 REV 8 NOT 1 SAE-AS4857

 AN918 REV 8 NOT 1 SAE-AS4858

AN919 REV 9 NOT 1 SAE-AS5174

AN933 REV 6 NOT 1 SAE-AS4862

MS3320N NOT 2 SAE-AS33201

MIL-U-3963A NOT 1 SAE-AS39631

MIL-B-3990D(3) NOT 1 SAE-AS39901

MIL-G-4343C NOT 1 SAE-AMS-G-4343

MIL-S-4383C NOT 2 SAE-AMS-S-4383

MIL-R-5001B NOT 1 SAE-AMS-R-5001

MIL-L-5057F(2) NOT 1 SAE-AS50571

MIL-F-5373D NOT 1 SAE-AS53731

MIL-H-5440H SUP 1 NOT 1 SAE-AS5440

MIL-C-5604B(3) NOT 1 SAE-AS5604

MIL-C-5809/1 NOT 2 SAE-AS58091/1

MIL-S-5944C NOT 1 SAE-AS5944

MIL-G-6032D(1) NOT 1 SAE-AMS-G-6032

MIL-B-6038A NOT 1 SAE-AS6038

MIL-R-6130C NOT 1 SAE-AMS-R-6130

MIL-C-6183B NOT 1 SAE-AMS-C-6183

AN6289 REV 7 NOT 2 SAE-AS5179

MIL-T-6302B(2) NOT 1 SAE-AS6302

MIL-H-6399B NOT 2 SAE-AS6399

MIL-S-6451E NOT 1 SAE-AS6451

MIL-S-6758B NOT 1 SAE-AMS-S-6758

MIL-T-6841D NOT 1 SAE-AMS-T-6841

MIL-R-6855E SUP 1 NOT 1 SAE-AMS-R-6855

MIL-W-6858D(1) NOT 2 SAE-AMS-W-6858

MIL-H-6875H(2) NOT 1 SAE-AMS-H-6875A

MIL-W-6882F(2) NOT 1 SAE-AS6882

MIL-I-7068A NOT 1 SAE-AMS-I-7068

MIL-F-7092(2) NOT 4 SAE-AS7092

MIL-T-7099E(1) SUP 1 NOT 1 SAE-AS70991

MIL-P-7105B(1) NOT 1 SAE-AS71051

MIL-S-7124B NOT 2 SAE-AMS-S-7124

MIL-I-7171D NOT 1 SAE-AMS-I-7171

MIL-F-7190B(1) NOT 1 SAE-AMS-F-7190

MIL-H-7199A(2) NOT 2 SAE-AMS-H-7199

MIL-L-7768B(1) NOT 1 SAE-AS7768

MIL-L-7768/1 NOT 1 SAE-AS7768/1

MIL-P-7788F(1) NOT 1 SAE-AS7788

MIL-T-7928G(1) SUP 1 NOT 1 SAE-AS7928

Society of Automotive Engineers (SAE) MIL-T-7928/7 NOT 1 SAE-AS7928/7

MIL-T-7928/6A(1) NOT 1 SAE-AS7928/6

MIL-T-7928/2C NOT 1 SAE-AS7928/2A

MIL-T-7928/1D NOT 1 SAE-AS7928/1A
A-20

MIL-T-7928/5B(1 ) NOT 1 SAE-AS7928/5

MIL-T-7928/4A(1) NOT 1 SAE-AS7928/4

MIL-C-8073D(1) NOT 2 SAE-AMS-C-8073

MIL-S-8559A(1) NOT 1 SAE-AMS-S-8559

MIL-B-8568B NOT 1 SAE-AS8568

MIL-S-8660C(2) NOT 1 SAE-AS8660

MIL-K-8662E(1) NOT 2 SAE-AS8662

MIL-I-8700A(1) NOT 1 SAE-AS8700

MIL-H-8796C(1) NOT 1 SAE-AS8796

MIL-S-8802F(4) NOT 2 SAE-AMS-S-8802

MIL-C-8837B(1) NOT 1 SAE-AMS-C-8837

MIL-S-8840B(1) NOT 1 SAE-AMS-S-8840 

MIL-F-8905B(1) NOT 1 SAE-AS8905 

MIL-B-8914B(3) NOT 1 SAE-AS8914

MIL-B-8952B NOT 1 SAE-AS8952

MIL-B-8964 NOT 1 SAE-AMS-B-8964

MIL-B-8976(4) NOT 1 SAE-AS8976

MS9021D NOT 2 SAE-AS3578

MIL-T-9046J(2) NOT 2 SAE-AMS-T-9046

MS9058D NOT 1 SAE-AS9058

MIL-C-9084C(1) NOT 1 SAE-AMS-C-9084

MS9112 NOT 2 SAE-AS9112

MS9142A(1) NOT 2 SAE-AS9142

MS9144A NOT 2 SAE-AS9144

MS9201B NOT 2 SAE-AS9201

MS9202A(1) NOT 3 SAE-AS9202

MS9203A(2) NOT 3 SAE-AS9203

MS9204A(1) NOT 1 SAE-AS9204

MS9205A(1) NOT 1 SAE-AS9205

MS9217 NOT 2 SAE-AS9217

MS9284 NOT 2 SAE-AS9284

MS9364A NOT 2 SAE-AS9364

MS9373A(1) NOT 1 SAE-AS9373

MS9451A(1) NOT 1 SAE-AS9451

MS9455A(1) NOT 1 SAE-AS9455

MS9456A(1) NOT 1 SAE-AS9456

MS9549 NOT 2 SAE-AS9549

MS9582B NOT 2 SAE-AS9582

MS9588D(1 ) NOT 1 SAE-AS9588

MS9686 NOT 2 SAE-AS9686

MS9697A NOT 2 SAE-AS9697

MS9734 NOT 2 SAE-AS9734

MS9741 NOT 2 SAE-AS9741

MS9771 NOT 3 SAE-AS9771

MS9772 NOT 2 SAE-AS9772

MS9805 NOT 2 SAE-AS9805

MS9808 NOT 2 SAE-AS9808

MS9842 NOT 2 SAE-AS9842

MS9843 NOT 2 SAE-AS9843

MS9845 NOT 2 SAE-AS9845

MS9846 NOT 2 SAE-AS9846

MS9847 NOT 2 SAE-AS9847

MS9848 NOT 1 SAE-AS9848

MS9882 NOT 2 SAE-AS9882

MS9885 NOT 2 SAE-AS9885

MS9955 NOT 2 SAE-AS9955

MS9956 NOT 1 SAE-AS9956

MS9966 NOT 2 SAE-AS9966

MS9967 NOT 2 SAE-AS9967

AND10081 REV 4 NOT 1 SAE-AS10081

Society of Automotive Engineers (SAE) MS14101J NOT 1 SAE-AS14101

MS14114 NOT 2 SAE-AS14114

DS14243 NOT 2 SAE-AS14243

DS14244 NOT 2 SAE-AS14244

DS14488 NOT 1 SAE-AS14244
A-21

MIL-R-17852C(1 ) NOT 1 SAE-AS17852

MS17983 NOT 2 SAE-AS17983

MS18013A NOT 1 SAE-AS18013

MS18121G NOT 1 SAE-AS18121

MIL-L-18276C(1) NOT 1 SAE-AS18276

MIL-F-18280F SUP 1 NOT 1 SAE-AS18280

MIL-L-18331B NOT 1 SAE-AMS-L-18331

MIL-P-19692E SUP 1 NOT 1 SAE-AS19692A

MIL-S-20708E(2) SUP 1B NOT 1 SAE-AS20708

MS20819G NOT 1 SAE-AS5176

MS20913G NOT 1 SAE-AS4863

MIL-T-21014D(1) NOT 1 SAE-AMS-T-21014

MS21155B NOT 2 SAE-AS21155

MIL-A-21180D(1) NOT 1 SAE-AMS-A-21180

MS21230B NOT 2 SAE-AS21230

MS21231B NOT 2 SAE-AS21231

MS21232A NOT 2 SAE-AS21232

MS21233B NOT 2 SAE-AS21233

MS21234 NOT 2 SAE-AS21234

MS21235 NOT 2 SAE-AS21235

MS21236 NOT 2 SAE-AS21236

MS21237 NOT 2 SAE-AS21237

MS21431A NOT 1 SAE-AS21431

MS21438C NOT 1 SAE-AS21438

MS21439B NOT 1 SAE-AS21439

MS21447A NOT 1 SAE-AS214 

MIL-F-21608E(1) NOT 1 SAE-AS21608

MS21935C NOT 1 SAE-AS21935

MS21938D NOT 1 SAE-AS21938

MS21945C NOT 1 SAE-AS21945

MIL-W-21985(2) NOT 1 SAE-AS21985

MIL-T-22085E NOT 1 SAE-AMS-T-22085

MIL-A-22145C NOT 1 SAE-AS22145

MIL-DTL-22499D NOT 1 SAE-AMS-DTL-22499

MIL-DTL-22499/4A NOT 1 SAE-AMS-DTL-22499/4

MIL-DTL-22499/1B NOT 1 SAE-AMS-DTL-22499/1

MIL-DTL-22499/2A NOT 1 SAE-AMS-DTL-22499/2

MIL-DTL-22499/3B NOT 1 SAE-AMS-DTL-22499/3

MIL-C-22587B NOT 1 SAE-AMS-C-22587

MIL-A-22771D NOT 1 SAE-AMS-A-22771

MIL-S-22805B(1 ) NOT 1 SAE-AS22805

MIL-P-22968B NOT 1 SAE-AMS-P-22968

MIL-I-23011C NOT 1 SAE-AMS-I-23011

MIL-DTL-23053E SUP 1A NOT 1 SAE-AMS-DTL-23053

MIL-DTL-23053/8C NOT 1 SAE-AMS-DTL-23053/8

MIL-DTL-23053/7C NOT 1 SAE-AMS-DTL-23053/7

MIL-DTL-23053/17B NOT 1 SAE-AMS-DTL-23053/17

MIL-DTL-23053/16B NOT 1 SAE-AMS-DTL-23053/16

MIL-DTL-23053/15B NOT 1 SAE-AMS-DTL-23053/15

MIL-DTL-23053/14B NOT 1 SAE-AMS-DTL-23053/14

MIL-DTL-23053/13B NOT 1 SAE-AMS-DTL-23053/13

MIL-DTL-23053/12C NOT 1 SAE-AMS-DTL-23053/12

MIL-DTL-23053/11C NOT 1 SAE-AMS-DTL-23053/11

MIL-DTL-23053/10D NOT 1 SAE-AMS-DTL-23053/10

MIL-DTL-23053/1C NOT 1 SAE-AMS-DTL-23053/1

MIL-DTL-23053/4D NOT 1 SAE-AMS-DTL-23053/4

MIL-DTL-23053/5C NOT 1 SAE-AMS-DTL-23053/5

MIL-DTL-23053/6D NOT 1 SAE-AMS-DTL-23053/6

MIL-S-23190/1A NOT 1 SAE-AS23190/1

Society of Automotive Engineers (SAE) MIL-S-23190/3 NOT 1 SAE-AS23190/3

MIL-I-23479B(1) NOT 3 SAE-AS23479

MIL-A-23899B NOT 1 SAE-AS23899

MS24000F NOT 1 SAE-AS24000

MS24001F NOT 1 SAE-AS24001

MS24388H NOT 1 SAE-AS1031C
A-22

MS24389F NOT 1 SAE-AS1032C

MS24390F NOT 1 SAE-AS1033C

MS24391H NOT 1 SAE-AS5169

MS24392F NOT 1 SAE-AS5174

MS24394G NOT 1 SAE-AS1038C

MS24395G NOT 1 SAE-AS1039C

MS24396E NOT 1 SAE-AS1040C

MS24401D NOT 1 SAE-AS1034C

MS24402D NOT 1 SAE-AS1035C

MS24403E NOT 1 SAE-AS1036D

MS24404E NOT 1 SAE-AS5168

MS24405D NOT 1 SAE-AS24405

MS24509K NOT 1 SAE-AS24509

MS24510K NOT 1 SAE-AS24510

MS24518B NOT 1 SAE-J1231-97

MS24519C NOT 1 SAE-J1231-97

MS24522B NOT 1 SAE-J1231-97

MS24563F NOT 1 SAE-AS24563

DOD-F-24610 NOT 1 SAE-AMS-F-24610

MS24651C NOT 1 SAE-AS24651

MS24652B NOT 1 SAE-AS24652

MS24654C NOT 1 SAE-AS24654

MS25019G NOT 2 SAE-AS25019

MS25027F NOT 1 SAE-AS25027

MIL-C-25050A(2) NOT 2 SAE-AS25050

MIL-E-25109 NOT 3 SAE-AS25109

MIL-G-25667B(1) NOT 3 SAE-AMS-G-25667

MIL-G-25871B(1) NOT 2 SAE-AMS-G-25871

MIL-DTL-27536C NOT 1 SAE-AS5355

MS33620B NOT 1 SAE-AIR797E

MS33658A NOT 3 SAE-AS5132

MS35867C NOT 2 SAE-J513-94

MS35868B NOT 2 SAE-J513-94

MS35869C NOT 2 SAE-J513-94

MS35870C NOT 2 SAE-J513-94

MS35871C NOT 1 SAE-J513-94

MS35872C NOT 2 SAE-J513-94

MS35873C NOT 2 SAE-J513-94

MS35926C NOT 2 SAE-J513-94

MIL-C-38334A(2) NOT 2 SAE-AMS1640

MS39155 NOT 1 SAE-J516-94

MS49008B NOT 1 SAE-J513-94

MIL-A-81596A NOT 1 SAE-AMS-A-81596

MIL-R-81835(1) NOT 1 SAE-AMS-R-81835

MIL-T-81914/4 NOT 1 SAE-AMS-T-81914/4

MIL-T-81914/5 NOT 3 SAE-AMS-T-81914/5

MIL-C-81986(1) NOT 2 SAE-AMS-C-81986

MIL-C-85061B(2 ) NOT 1 SAE-AS5356

AN115401THRUAN115450 REV 2 NOT SAE-AS115401THRUAS115450

AN115501THRUAN115550 REV 2 NOT SAE-AS115501THRUAS115550

AN115601THRUAN115650 REV 2 NOT SAE-AS115601THRUAS115650

AN115651THRUAN115700 REV 3 NOT SAE-AS115651THRUAS115700

AN115901THRUAN115950 REV 3 NOT SAE-AS115901THRUAS115950

AN115951THRUAN116000 REV 3 NOT SAE-AS115951THRUAS116000

AN116001THRUAN116050 REV 3 NOT SAE-AS116001THRUAS116050

AN116101THRUAN116150 REV 4 NOT SAE-AS116101THRUAS116150

AN116925THRUAN116960 REV 1 NOT SAE-AS116925THRUAS116960

AN121651THRUAN121700 REV 3 NOT SAE-AS121651THRUAS121700

Society of Automotive Engineers (SAE) AN121701THRUAN121750 REV 3 NOT SAE-AS121701THRUAS121750

AN121851THRUAN121925 REV 3 NOT SAE-AS121851THRUAS121925

AN128687THRUAN128998 REV 2 NOT SAE-AS128687THRUAS128998

AN150301THR UAN150400 NOT 2 SAE-AS150301THRUAS150400

AN151401THRUAN151700 REV 2 NOT SAE-AS151401THRUAS151700

AN151701THRUAN152000 REV 4 NOT SAE-AS151700THRUAS152000

AN153201THRUAN153500 REV 5 NOT SAE-AS153201THRUAS153500
A-23

AN154701THRUAN155000 REV 2 NOT SAE-AS154701THRUAS155000

Effectiveness of Circular A-119 Policy -- The current OMB Circular A-119 provides clear

guidance on using voluntary consensus standards and participating in voluntary consensus

standards bodies. As written, this circular reinforces DOD policies regarding use of voluntary

consensus standards, reliance on performance documents, and encouragement of participation in

voluntary standards bodies. DOD believes the Circular s plain language format greatly enhances

its effectiveness. DOD does not believe additional changes are required at this time.
A-24

NATIONAL COMMUNICATION SYSTEM (NCS)

Dr. Peter M. Fonash, Chief, Technology and Programs Division, and Chair, Federal

Telecommunications Standards Committee (FTSC), is the Office of the Manager, National

Communications System (OMNCS), focal point for telecommunications and related information

system standards. His telephone number is (703) 607-6200, and his email address is

fonashp@ncs.gov.

The OMNCS provides the chair of the FTSC. This interagency committee prepares standards

and recommendations on matters affecting national security and emergency preparedness

(NS/EP) and in other areas of communications approved by the committee on the basis of

requests from members. It also provides advice to members on how to best represent the

Government s NS/EP interests in work in industry and international standards committee.

The FTSC and members of the OMNCS work extensively with voluntary standards organizations

to ensure that Government requirements are considered as the standards are developed. The

OMNCS has 15 employees who participate in industry voluntary standards activities. The

following paragraph lists the committees in which they participate.

Staff of the OMNCS participate in the following voluntary standards related committees:

"Organizations Accredited by the American National Standards Institute (ANSI):

- Committee T1, Telecommunications, and its technical subcommittees

- Telecommunications Industry Association committees TR-8, TR-45

- Institute of Electrical and Electronics Engineers

"Commercial and Multi-National Organizations Not Accredited by ANSI:

- ATM Forum

- Internet Engineering Task Force

- Network Interconnection Interoperability Forum (NIFF)

- Telecommunications and Internet Protocol Harmonization Over Networks (TIPHON)

- TeleManagement Forum

- Electronic Communications Implementation Committee (ECIC)

"Federal, State, and Local Committees:

- Federal Telecommunication Standards Committee (OMNCS furnishes Chair and

Executive Secretary)

- International Telecommunication Advisory Committee and its study groups

(Department of State)
A-25

- Association of Public Safety Communications Officials (APCO)

-- Project 25 (land mobile radio)

-- Project 34 (wireless high-speed data)

"International Organizations:

- International Telecommunications Union-Telecommunications Sector (ITU-T)

(OMNCS heads U.S. delegations to 3 study groups)

- International Telecommunications Union-Radio Sector (ITU-R)
A-26

DEPARTMENT OF EDUCATION (DOED)

For the past several years, DOED has been actively working with the American National

Standards Institute (ANSI) on developing EDI transaction sets through their Accredited

Standards Committee (ASC) X12 committee. This committee is charged with developing

uniform standards for electronic interchange of business transactions. The X12 Committee

develops standards to facilitate electronic interchange relating to such business transactions as

order placement and processing, shipping and receiving, invoicing, payment, and cash

application data associated with the provision of products and services.

DOED s National Center for Education Statistics (NCES) has one voting member and has

sponsored the work of task groups to attend ANSI ASC X12 meetings. Information about the

activities that NCES has been involved in can be obtained at <http://nces.ed.gov/edi>. In

addition, DOED has had another voting member that is part of the Department s Office of

Postsecondary Education. The Department has been involved in developing EDI transaction sets

for Student Financial Aid. These activities fall under the umbrella of Project EASI. For more

information on Project EASI, please visit

<http://easi.ed.gov/inside_projecteasi/HTML/inside_main.html>.

Participation in this voluntary consensus building body has allowed DOED to forge ahead in

developing standards while including the necessary members of the affected communities to help

transition to adoption.

Transaction sets that DOED has promulgated for information about students (both at the

elementary/secondary level and at the postsecondary level) and other aspects of education are the

following:

Transaction Sets Relating to Individual Student Records

TS 130 - Student Educational Record (Transcript)

TS 131 - Student Educational Record (Transcript) Acknowledgment

TS 138 - Testing Results Request and Report

TS 146 - Request for Student Educational Record (Transcript)

TS 147 - Response to Request for Student Educational Record (Transcript)

TS 189 - Application for Admission to Educational Institutions

Implementation Guides

Transaction Sets Relating to Personnel Records

TS 132 - Personnel Information
A-27

Transaction Sets Relating to Student Financial Aid Records

TS 135 - Student Loan Application

TS 139 - Student Loan Guarantee Result

TS 144 - Student Loan Transfer and Status Verification

TS 190 - Student Enrollment Verification

TS 191 - Student Loan Pre-Claims and Claims

TS 810 - Invoice

TS 820 - Payment Order/Remittance Advice

Transaction Sets Relating to Institutional Records

TS 133 - Educational Institutional Profile

TS 152 - Statistical Government Information used to transmit CCD, IPEDS and Library

 surveys to NCES

TS 188 - Educational Course Inventory
A-28

DEPARTMENT OF ENERGY (DOE)

The DOE implements the Federal guidance and requirements of Office of Management and

Budget (OMB) Circular A-119 and the statutory requirements of Public Law (P.L.) 104-113

(15 U.S.C. 272) on the use of voluntary consensus standards through specific Departmental

directives (policy, requirements, guides, and technical standards) and supporting management

systems.

Foremost is DOE's Integrated Safety Management System (ISMS). ISMS incorporates principles

of management that serve to integrate management of DOE's worker, public, and environmental

health and safety with its business management, using standards as one of its primary tools.

DOE also has established internal policies as the top tier of DOE requirements driving the

implementation of Federal Law and Policy. DOE Policy 251.1, Directives System, establishes

a Directives System for managing DOE requirements and guidance documents and incorporates

technical standards (i.e., those standards that are specifically addressed in P.L. 104-113) as a key

element of the Department s directives system hierarchy. The focus of the Directives System is

DOE's environment, safety and health requirements, and guidance. The Directives System policy

clearly states DOE s preference to adopt National Consensus Standards and other commercial

and industry standards . . . in the conduct of DOE's activities. This policy also pertains to the

use of mandated government-unique standards in DOE rulemaking, Orders, and procurement

processes. DOE requirements specified in Orders and rules reference appropriate voluntary

consensus standards when they are acceptable to meet requirements. Another policy, DOE

Policy 410.1A, Promulgating Nuclear Safety Requirements,  also requires notice and comment

to promulgate new nuclear safety requirements. New nuclear safety requirements promulgated

by the Department are performance-based rules and Orders that permit the adoption of

voluntary consensus standards as acceptable methods to implement requirements. DOE also

specifies responsibilities for managers and organizations in managing and implementing

P.L. 104-113 and OMB Circular A-119 requirements in its DOE Manual 411.1-1A, "Safety

Management Functions, Responsibilities, and Authorities Manual (FRAM)."

These Departmental policies, requirements, and responsibilities on the use of voluntary

consensus standards are implemented through a DOE-wide management system and

infrastructure established through DOE Order 252.1, Technical Standards Program, an

accompanying program Guide, DOE Guide 252.1-1, "Technical Standards Program Guide," and

Technical Standards Program Procedures (TSPPs).

DOE Order 252.1 establishes the DOE Technical Standards Program (TSP), and is designed to

implement Federal and DOE technical standards requirements and manage internal standards

development activities across DOE. DOE Order 252.1 updates DOE Order 1300.2A, 
A-29

incorporating references to P.L. 104-113 and the February 1998 revision to OMB

Circular A-119. The new Order reinforces the requirement for DOE elements to use voluntary

consensus standards in preference to Federal and DOE (i.e., government unique) standards,

consistent with P.L. 104-113 and OMB Circular A-119. The TSP further encourages and

supports staff participation in the planning, development, and coordination activities of national

and international standards developing organizations (SDOs).

The TSP Guide and TSPPs provide information on the TSP functions and management, program

resources and services, and the DOE processes and procedures for selecting, developing, and

maintaining DOE Technical Standards and using voluntary consensus standards. The TSP Guide

also provides basic information on reporting the use of government-unique standards in both

regulation (DOE is nominally self-regulating in key areas such as nuclear safety) and

procurement (where most reporting is category-based). The DOE TSP plans to develop further

reporting procedures to assist program officials conducting procurements. The DOE TSPPs

incorporate working level implementation of the technical standards provisions of P.L. 104-113

and OMB Circular A-119, and DOE currently manages its technical standards activities in

conformance with Federal policy and requirements.

Another element serving implementation of P.L. 104-113 and OMB Circular A-119 is DOE s

Department Standards Program. This Program was established to institute standards (in this

application, standards include policy, laws, rules, guides, and technical standards) as the basis

for work throughout the Department. A Department Standards Committee (DSC) was

established in 1994 to establish DOE standards policy and help remove barriers to implementing

a Department-wide standards-based culture. The DSC assists DOE line organizations in the

implementation of this Department Standards Program. The Criteria for the Department s

Standards Program, DOE/EH/-0416, August 1994, describes elements of the standards-based

operating culture envisioned by DOE leadership. Information on the Department Standards

Program and the DSC can be accessed at the following Internet address (Uniform Resource

Locator {URL}):

<http://tis.eh.doe.gov/dsc>

The DSC has sponsored development and implementation of a DOE-wide process that enables

DOE contractors to select voluntary consensus standards as the basis for their work in-lieu-of

DOE-developed or other government-unique standards, when such standards are appropriate for

the work and work-related hazards. This Work Smart standards approach (also referred to as

the necessary and sufficient process) enables DOE laboratory and management and operating

or integrating contractors, with DOE approval, to identify and apply the set of standards

(including technical standards) that best fits their activities and adequately addresses related

hazards. This approach focuses on outcomes and performance, rather than detailing how 

things are to be done within DOE. The process is part of the DOE ISMS and is supported by a

major contract reform effort designed to more closely link performance expectations with

contractual obligations based on standards.
A-30

Key Departmental policy and requirements documents defining the "Work Smart" approach

include DOE Policy 450.3, Authorizing Use of the Necessary and Sufficient Process for

Standards-Based Environment, Safety and Health Management, and DOE Manual 450.3-1,

 The Department of Energy Closure Process for Necessary and Sufficient Sets of Standards. 

Field pilot projects of the approach have been completed, and significant efficiencies and costsavings have been demonstrated. The 

Work Smart standards approach now covers a broad

range of Department programs and facilities. During fiscal year (FY) 1999, DOE developed and

updated additional guidance and standards to support the Work Smart process.

The DOE Standards Executive, Richard L. Black, Director, Office of Nuclear Safety Policy and

Standards, continues to be responsible for developing and implementing the DOE TSP through

DOE's TSP Manager and the TSP. He also advises and provides staff support to the Department

Standards Committee. Through Mr. Black s participation on the Interagency Committee on

Standards Policy (ICSP), DOE supports ICSP activities and policy implementation, and provides

"lessons-learned" information to other Federal agencies on the DOE s approach to establishing a

standards-based culture.

As noted above, DOE Order 252.1 emphasizes the use of voluntary consensus standards within

the Department. DOE's Technical Standards Program Office (TSPO) operates under this Order

to implement program policy, support the conversion of Department standards to voluntary

consensus standards, identify voluntary consensus standards that can suit Department needs,

develop and maintain databases to support the program and meet reporting requirements, and

coordinate day-to-day Department technical standards activities. The TSPO has developed

procedures, methods, and training approaches to implement the DOE TSP; communicate the

policy to use voluntary consensus standards throughout DOE; and support participation in SDO

activities related to DOE missions and functions. The TSPPs establish a 5-year standards review

cycle to check for continued applicability. The procedures also provide guidance on the

conversion of Department standards to voluntary consensus standards.

Information on the TSP and the TSPO can be accessed at the following Internet address (URL):

<http://tis.eh.doe.gov/techstds/>

To coordinate consistent implementation of Federal and DOE policy and requirements at the

working level, DOE senior managers have designated Technical Standards Managers

(approximately 70 individuals) representing the various Department headquarters, field,

laboratory and contractor organizations. Established in 1992, the Technical Standards Managers 

Committee (comprised of these Technical Standards Managers) operates under the DOE TSP,

supports the DOE sites in technical standards activities, facilitates communications on program

implementation issues, and participates in establishing program goals and procedures. 

Publications documenting the voluntary consensus standards adopted by DOE and the personnel

participating in the activities of SDOs are developed by the TSPO. The information in those

publications is electronically posted for Internet access and provided to OMB annually.
A-31

During FY 1999, the TSP continued the recognition of topical standards committees within

DOE. Topical committees provide a venue for DOE-wide coordination with national and

international SDOs in such diverse areas as laboratory accreditation, metrology, fire protection,

environmental management systems, chemical safety, emergency management, and nuclear

safety training. These committees are composed of subject matter experts from across the DOE

community, and serve as focal points for standards activities in specific technical areas. The

topical committees provide a forum for all interested DOE parties to join and participate in

reviewing technical standards produced by counterpart SDOs, address standards application

issues within their area of technical expertise, and work to develop Department and Federal

positions on standards issues. As of November 10, 1999, the TSP has recognized 23 DOE

topical committees. (These committees are identified on the program Internet address listed

above.)

The Department has also established a DOE Information Technology Standards Program

(Internet address is: <http://www-it.hr.doe.gov/Standards/index.html>) that is conducted in

accordance with the DOE TSP. The DOE Information Technology Standards Program is

managed by staff from DOE s Office of the Chief Information Officer with assistance from over

70 designated DOE and contractor Information Technology Points-of-Contact representing key

programs and sites. It coordinates information technology standards activities Department-wide,

including the identification, adoption, implementation, and retirement of non-Government and

Government information technology standards in support of the DOE Information Architecture. 

This program has stressed the use of international and voluntary consensus information

technology standards over development of internal standards in its adoption processes.

The Department also implements a legislatively mandated, multiyear effort to improve the energy

efficiency in the Nation s buildings through energy efficiency standards, codes and guidelines for

buildings, building equipment, and appliances through its Office of Energy Efficiency and

Renewable Energy (Internet address is: <http://www.eren.doe.gov/>). The Department s codes

and standards development efforts in these areas are closely coordinated with SDOs and include

early involvement of industry and state stakeholders and relevant Federal agencies.

DOE continues to take a proactive approach to standards and standards management even as

its mission continues to evolve in response to the conclusion of the Cold War and shrinking

Congressional appropriations. Within DOE, a number of programs and facilities have shifted

their focus from production, research, and/or development to environmental remediation and

restoration, where DOE will literally be breaking new ground and setting standards for others to

follow. In addition, Department staffing levels are declining to meet Congressional budget

constraints. Still, in the face of a changing mission and a reduced workforce, DOE continues to

actively use and support the development of voluntary consensus standards to meet its needs. In

FY 1999, the number of voluntary consensus standards adopted for use increased to 916 (840 in

1998 and 809 in 1997). However, the number of individuals participating in voluntary consensus

standards activities decreased to 668 (681 in 1998 and 871 in 1997), and the number of

documented participations in standards developing groups declined to 1,306 (1,321 in 1998 and
A-32

1,540 in 1997). The Department believes this reflects the very significant downsizing and

budget cuts experienced by DOE in recent years, rather than any reduced interest on the part of

DOE organizations.

Also, DOE (through the TSPO) is continuing its initiative (in response to contacts from SDOs on

how the Department is meeting P.L. 104-113) to better define candidate DOE Technical

Standards for conversion to voluntary consensus standards. The Department is continuing to

work with representatives of the American National Standards Institute (ANSI) Nuclear

Standards Board (NSB) on the conversion of selected DOE Technical Standards to voluntary

consensus standards. (Four candidate standards are in the conversion process.)

Other highlights of DOE s interaction with SDOs include the following:

"From FY 1993 through FY 1997, DOE conducted annual national workshops promoting

the TSP and the use of voluntary consensus standards within the Department. 

Approximately 150 standards developers and users attended each workshop.

"In August 1998, DOE hosted the first-ever Federal Technical Standards Workshop with

the goal of furthering the implementation of P.L. 104-113 throughout the Federal

Government. The Workshop was cosponsored with the National Institute of Standards

and Technology; Environmental Protection Agency; National Aeronautics and Space

Administration; Food and Drug Administration; and the Partnership in Reliability,

Maintainability, and Supportability Standards. More than 200 standards developers and

users attended the workshop. Contingent on receipt of additional program funding as

increased ICSP support, DOE would like to organize and conduct another Federal-level

workshop in FY 2000.

"In addition to the ANSI-NSB, DOE representatives participate on ANSI s Board of

Directors and Executive Standards Council. DOE also participates in a number of

international standards groups such as: International Organization for Standardization

(ISO)/Technical Committee (TC) 85, Nuclear Energy; ISO/TC 176, Quality Assurance;

and ISO/TC 207, Environmental Management.

Reporting Requirements for OMB Circular A-119:

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

- Number of standards bodies: 58

- Number of agency personnel participating: 668

- Total number of agency participation: 1,306
A-33

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

916

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

0

"An evaluation of the effectiveness of this policy and recommendations for any changes:

The guidance in OMB Circular A-119 appears to be sufficient in terms of outlining

the basic functions and responsibilities of Federal agency standards management and

standards participation activities. It allows sufficient latitude for each Federal agency

to develop its own approach tailored to specific agency needs, and places the

emphasis on outcomes rather than processes.

"As required by P.L. 104-113, when the agency used government-unique standards in lieu

of voluntary consensus standards:

There were no recorded cases in FY 1999 where the Department selected to use an

internal standard in lieu of an equivalent, existing voluntary consensus standard.
A-34

DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS)

Food and Drug Administration (FDA)

Summary of the nature and extent of FDA participation in the development and utilization of

voluntary consensus standards:

"The number of instances when the agency used government-unique standards in lieu of

voluntary consensus standards:

0

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

90*

* NOTE: Includes standards recognized under the Food and Drug Administration

Modernization Act of 1997 (FDAMA).

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

0

"The number of voluntary consensus standards bodies in which there is agency

participation:

43

The number of agency employees participating:

255* (on 544 voluntary consensus standards development committees)

* NOTE: Individual employees with specific expertise often participate

simultaneously on two or more standards development committees within

the same or different standards bodies. Therefore, 255 agency employees

participate on 544 standards development committees, within 43 voluntary

consensus standards development bodies.
A-35

"Evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The policy and recommendations contained in Circular A-119 are consistent with

FDA s framework for standards management as announced in the Federal Register of

October 11, 1995, and enhanced by FDAMA. Resource constraints oblige the agency

to focus attention on the highest priority activities and to strive to make its

participation in those activities very effective.

Voluntary consensus standards are most relevant for medical devices, where they are

used extensively in the agency s regulatory work and where the majority of the

agency s standards activities are centered. Voluntary consensus standards are less

relevant in the areas of human and veterinary pharmaceuticals, biologicals, and food,

where such standards are generally neither available nor being developed, and where

standards of other international organizations (World Health Organization (WHO),

Food and Agricultural Organization (FAO), International Conference on

Harmonisation of Technical Requirements for Registration of Pharmaceuticals for

Human Use (ICH)) as well as regulatory standards predominate.

Narrative Summary

The central purpose for FDA involvement in the development and use of standards is to assist the

agency in fulfilling its domestic public health and regulatory missions. The Agency participates

widely in the development of standards, both domestic and international, and adopts or uses

standards when this action will enhance its ability to protect consumers and the effectiveness or

efficiency of its regulatory efforts. Further, using standards, especially international ones, is a

means to facilitate the harmonization of FDA regulatory requirements with those of foreign

governments, and thus to further domestic and global public health protection. Therefore, FDA

encourages participation in the development of standards as a useful adjunct to regulatory

controls.

FDA has been involved in standards activities for more than 20 years. In January 1977, the

Agency promulgated a final regulation now found at 21 CFR 10.95, covering participation by

FDA employees in standards development activities outside the agency. This regulation

encourages FDA participation in standards activities that are in the public interest, and specifies

the circumstances under which FDA employees can participate in various types of standards

bodies.

The Agency built upon that rule with a draft policy statement published in the Federal Register

on November 28, 1994, and a subsequent final policy published on October 11, 1995. Entitled

 International Harmonization; Policy on Standards, it provides the Agency s overall policy on

development and use of standards for all product areas regulated by the Agency. In an initiative

aimed at furthering harmonization, on January 28, 1995, FDA published in the Federal Register a
A-36

proposed rule to facilitate the sharing of draft regulations and other predecisional documents with

State and foreign officials. The final rule, Public Information; Communications with State and

Foreign Government Officials, was published on December 8, 1995.

FDA s development and use of voluntary consensus standards varies within each of the Agency s

centers, because of differing availability and applicability of such standards in each product area. 

Voluntary consensus standards are most relevant to medical devices, and consequently the

majority of the Agency s standards activities addressed by Circular A-119 are centered there.

Center for Devices and Radiological Health (CDRH)

On October 10, 1997, a draft guidance document was made available for public comment on the

Agency s Internet home page, which provided guidance to FDA medical device reviewers on the

use of the International Electrotechnical Commission (IEC) 60601 series of standards, including

declaration of conformity to the standards, during the evaluation of premarket submissions for

electrical medical devices. A notice announcing the availability of the draft guidance entitled

 Use of IEC 60601 Standards - Medical Electrical Equipment was published in the Federal

Register on January 13, 1998. Written comments were due to the Agency by April 13, 1998.

Section 204 of the Food and Drug Administration Modernization Act of 1997 (FDAMA)

(P.L. 105-115, 111 Stat. 2296), November 21, 1997, amended section 514 of the Federal Food,

Drug, and Cosmetic Act (21 U.S.C. 360d), allowing the Agency to recognize consensus

standards established by international and national standards developing organizations that may

be used to satisfy identified portions of device premarket review submissions or other

requirements. In a Federal Register notice published on February 25, 1998, the Agency

announced the availability of a guidance document entitled Recognition and Use of Consensus

Standards describing how FDA planned to implement that part of FDAMA, and providing an

initial list of recognized standards.

The Agency decided not to finalize the draft guidance document entitled Use of IEC 60601

Standards - Medical Electrical Equipment, and withdrew it in a Federal Register notice on

October 16, 1998. In its place, the Agency published modifications to the initial list of standards

(originally published in the February 25, 1998 notice) that will be recognized for use in the

premarket review process. Recognition of the standards became effective on November 16,

1998, and assist manufacturers who elect to declare conformity with consensus standards to meet

all or part of medical device review requirements. Periodic updates are announced.

Due to its extensive participation in voluntary consensus standards activities, CDRH has

maintained a database to track the standards activities of its employees for many years. The

Center recently invested in, and routinely uses, searchable ROM databases of voluntary

consensus standards to facilitate reference to current voluntary consensus standards by agency

reviewers.
A-37

In June 1999, CDRH hosted the Global Harmonization Task Force (GHTF), an

intergovernmental consortium to foster medical device regulatory harmonization. During the

meeting, the CDRH official serving as GHTF Chair signed a Memorandum of Understanding

with the Chair of the Interagency Organization for Standardization (ISO) committee responsible

for many aspects of device standards (Technical Committee 210).

Center for Drug Evaluation and Research (CDER)/Center for Biologics Evaluation and Research

(CBER)

Voluntary consensus standards are less applicable to pharmaceutical and biological products. 

Therefore, CDER and CBER have extremely limited involvement in such activities, but do

participate on relevant committees of at least two voluntary consensus standards bodies.

While the Agency s involvement with voluntary consensus standards development is limited in

these particular areas (mostly because such standards are not available nor under development in

these areas), it should be noted that the Agency does participate in many other types of standards

development activities that are excluded from Circular A-119 reporting requirements.

Numerous employees in CDER and other FDA Centers are involved in the standards

development activities of the United States Pharmacopeia (USP), a private, voluntary, not-forprofit national standard setting body of more than 1,500 health care professionals, recognized

authorities in medicine, pharmacy, and allied sciences. USP publishes and revises the USP and

the National Formulary, the legally recognized compendia of drug standards in the United States.

Both CDER and the CBER participate in the ICH. This ongoing project, started in 1989, has

been undertaken by government agencies responsible for regulation of pharmaceuticals and by

industry trade organizations for the European Union, Japan, and the United States. ICH brings

together regulatory authorities and experts from the pharmaceutical industry in the three regions

to discuss scientific and technical aspects of new product registration. The work products,

created in working groups of experts from the regulatory agencies and industry, consist of a

series of consensus guideline documents to harmonize pharmaceutical testing guidelines. FDA

officials also participate in a consensus standards development activity sponsored by the Council

for International Organizations of Medical Sciences and implemented in ICH, that is aimed at

standardizing the safety-related terminology used in adverse experience reporting.

FDA actively participates with the WHO in developing international standards for ensuring the

quality of pharmaceutical and biological products, and the Organization for Economic

Cooperation and Development (OECD) on good laboratory practices for animal studies. In 1997,

a new hemispheric initiative was launched on pharmaceutical harmonization in the Americas,

with emphasis on relevant ICH and WHO standards. The Pan American Health Organization is

the convener. FDA sent participants to conferences held in January and November 1999, which

helped advance this initiative.
A-38

Although FDA s work with USP is specifically excluded from reporting under Circular A-119,

and ICH, OECD, and WHO do not meet the definition of voluntary consensus standard bodies

under the Circular, substantial agency resources are devoted to the development of these various

standards, and this work is the core part of FDA s overall standards activities for

pharmaceuticals.

Center for Food Safety and Applied Nutrition (CFSAN)/Center for Veterinary Medicine (CVM)

Voluntary consensus standards have limited relevance to food and veterinary medicine products. 

However, the standards activities of multilateral organizations such as the WHO, FAO, World

Trade Organization (WTO), and the OECD are often important in these areas, and CFSAN and

CVM are actively engaged in standards and policy development with these organizations. The

principal international standards activities in the areas of food and veterinary medicine fall under

the activities of the Codex Alimentarius Commission under the FAO and the WHO, and the

Office of International Epizootics (for veterinary medicine). FDA experts from CFSAN, CVM,

the Office of International Programs, and the Office of Regulatory Affairs are heavily involved in

Codex Alimentarius activities, and also in those of methods validation organizations on which

Codex Alimentarius relies such as ISO, AOAC International (formerly the Association of

Official Analytical Chemists), and IDF/FIL (International Dairy Federation).

CVM is very active in a harmonization initiative similar to the ICH for human pharmaceuticals,

that is developing harmonized requirements for the registration of veterinary drugs. It is known

as VICH, for Veterinary ICH. Agency employees participate on numerous committees that are

drafting VICH guidelines.

International/Treaty Standards-Related Activities

FDA takes part in a variety of international standards activities that fall under treaty

organizations, and thus are not reportable under the provisions of Circular A-119. These

standards activities are nonetheless important to the Agency in fulfilling its public health

regulatory mission. Some of these are referred to above; i.e., WHO, FAO, and OECD.

The Agency participates in international trade discussions of the WTO, specifically committees

on the Agreement on Technical Barriers to Trade, the Agreement on Sanitary and Phytosanitary

Measures, and the same counterpart committees of the North American Free Trade Agreement,

to ensure that FDA s requirements are preserved and its regulatory practices can remain focused

on fulfilling the Agency s mission to protect the public health while being supportive of

emerging, broader U.S. Government obligations and policies. FDA has participated in several

initiatives that are part of the Asia Pacific Economic Cooperation forum. FDA topics have

included food safety, food labeling, bulk drugs, standards for latex gloves and condoms, and

medical device regulation.
A-39

FDA Standards Policy and Program Management

It is the intent of FDA s standards policy to: (1) enable the agency to participate in international

standards activities that will assist it in implementing statutory provisions for safeguarding the

public health; (2) increase its efforts to harmonize its regulatory requirements with those of

foreign governments, including setting new standards that better serve the public health; and,

(3) respond to laws and policies that encourage agencies to use voluntary standards that provide

the desired degree of protection.

FDA conducts a comprehensive review of its existing regulations on an ongoing basis. As part

of this review, the Agency considers the appropriateness of existing regulations and policies, as

specified in Circular A-119.

The FDA Standards Policy Committee (SPC) is chaired by the Agency Standards Executive, and

composed of top management representatives from all centers and offices within the Agency. 

The SPC meets periodically to review and discuss both domestic and international standards

issues, and recommend agency-wide standards policy to the Commissioner. The committee

oversees the coordination of FDA standards activities and policies regarding official participation

of employees in standards development endeavors both within and outside FDA; tracks,

compiles, and reports required information; and ensures appropriate standards review when

applicable.

The Agency experts on quality systems and environmental management serve as liaison members

to the FDA SPC, to strengthen agency expertise and participation in issues and activities related

to these areas. The agency also has a contact group of experts on private laboratory issues that

holds meetings as needed to assure coordination of testing and conformity assessment issues.

In November 1999, FDA conducted HHS-wide training on the requirements set forth in Office of

Management and Budget Circular A-119. The FDA Standards Executive also serves as the

Department (HHS) Standards Executive. The training was designed for regulation writers and

employees involved in standards development and management activities in FDA and all other

HHS agencies, which are increasingly involved in the development and use of voluntary

consensus standards. Additional HHS-wide training and coordination activities are planned.

Due to reorganization of the international activities in the Office of the Commissioner, the

Standards Executive responsibility was shifted along with the standards management function,

on January 1, 2000. The current Standards Executive is listed below.
A-40

FDA/HHS Standards Executive:

Janet Showalter Phone: (301) 827-0865

Director, International Scientific Fax: (301) 443-0232

Activities and Standards Staff Email: jshowalt@oc.fda.gov

Office of International Programs

Food and Drug Administration

5600 Fishers Lane, Room 15-22 (HFY-020)

Rockville, MD 20857
A-41

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD)

In response to the requirements of Office of Management and Budget (OMB) Circular A-119,

February 19, 1998, HUD reports the following information:

"There is a total of six HUD employees participating in standards developing

organizations (SDOs). Three employees from the Manufactured Housing & Standards

Division, two employees from the Office of Lead Hazard Control, and one from the

Office of Information Technology, are participating on five voluntary consensus SDOs

and a National Institute of Standards and Technology standards activity. SDOs in which

they participate:

- American Society of Civil Engineers

- ASTM (formerly the American Society for Testing and Materials)

- Council of American Building Officials

- National Committee for Information Technology Standards

- Underwriters Laboratories

Two new voluntary consensus standards have been adopted that resulted from agency

participation in a standards development group.

"No new voluntary consensus standards have been adopted during this period for the

purpose of promoting environmentally sound and energy-efficient materials, products,

systems, services, or practices.

"HUD supports the policy of OMB Circular A-119 and references more ASTM voluntary

consensus standards than any other Federal agency.
A-42

DEPARTMENT OF THE INTERIOR (DOI)

Based on a survey of offices and bureaus, the DOI s response is as follows:

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

54 consensus standards bodies, with 84 agency employees participating

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

144

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of agency review under section 15b(7) of the

Circular:

None

"An evaluation of the effectiveness of the guidelines of Circular A-119 and

recommendations for any changes:

DOI has no recommendations for any changes to the Circular at this time.

"As required by P.L. 104-113, identification of all instances when the agency used

government-unique standards in lieu of voluntary consensus standards:

None
A-43

DEPARTMENT OF JUSTICE (DOJ)

As required by Office of Management and Budget (OMB) Circular A-119 and Public Law

(P.L.) 104-113, DOJ s response follows:

"The Department uses all standards involved in complying with P.L. 102.486, Executive

Orders 12759 and 12845, and Federal Regulation Interim Rule 1 and Bulletin C-35

concerning Energy-Star qualifying computer equipment. The Government also is

required to use the security standards for protection of information unless a waiver is

granted. For example, the following security standards are mandatory:

FIPS 46-2, 46-3 Data Encryption Standard

FIPS 102 Certification and Accreditation

FIPS 112 Password Usage

FIPS 140-1 Cryptographic Modules

FIPS 171 Key Management using ANSI X9.17

FIPS 180-1 Secure Hash Standard

FIPS 185 Escrowed Encryption Standard

FIPS 186-1 Digital Signature Standard

FIPS 196 Entity Authentication Using Public Key Cryptography Secure

Socket Layer (SSL)

ISAKMP X.509 Certificates

NIST PUB 800-18System Security Plans

"The Department has issued 59 consensus standards since October 1, 1998.

"The Department completed the development of technical reference model,

December 1998, which was distributed in 1999. The following standards have been

substituted for government standards:

IETF DCHP Dynamic Configuration Host Protocol

DNS IETF 13/RFC 1034 Domain Name Service

TCP/IP Transmission Control Protocol/Internet Protocol

XML-971208 Extensible Markup Language (XML)

SMTP Simple Mail Transfer Protocol

"The Department has eight individuals that participate in three consensus standards bodies.

"Circular A-119 policy is appropriate and has increased the awareness, value, and usage of

consensus standards.
A-44

DEPARTMENT OF LABOR (DOL)

Below are the responses from the only two agencies within DOL that have activities to report:

Mine Safety and Health Administration (MSHA)

"As required by P.L. 104-113, identification of all instances where the agency used

government-unique standards in lieu of voluntary consensus standards (for each instance

include agency rationale for such use, as well as the specific government-unique standard

used):

Zero. For the most part, MSHA has already used the voluntary consensus standards

that are applicable to mining. Any further action would be to update the revision

referenced.

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

None

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

None

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

MSHA has approximately 35 individuals on 50 separate committees or

subcommittees of various organizations, such as American National Standards

Institute (ANSI); ASTM (formerly the American Society for Testing and Materials);

American Institute of Mining, Metallurgical and Petroleum Engineers/Society for

Mining, Metallurgy, and Exploration; and Society of Automotive Engineers.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

None
A-45

Occupational Safety and Health Administration (OSHA)

"As required by P.L. 104-113, identification of all instances where the agency used

government-unique standards in lieu of voluntary consensus standards (for each instance

include agency rationale for such use, as well as the specific government-unique standard

used):

OSHA issued a standard addressing training for operators of Powered Industrial

Trucks. OSHA drew from the ANSI standard, but did not adopt it because it went

well beyond the scope of OSHA's rulemaking needs.

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

OSHA has used 15 voluntary consensus standards since the last report.

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

OSHA did not substitute any voluntary consensus standards for government-unique

standards as a result of an agency review under section 15b(7) of this circular.

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

OSHA participates in 4 voluntary consensus standards bodies with 34 agency

employees participating.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

OSHA has no comment.
A-46

DEPARTMENT OF STATE

The Department of State has a major policy role in telecommunications standards as obligated by

international treaty, and coordination roles in other areas. The Bureau of Economic and Business

Affairs (EB) represents the Department of State on the Interagency Committee on Standards

Policy (ICSP), the Government Member Council, and the Information Infrastructure

Standardization Panel and its steering committee at the American National Standards Institute

(ANSI). The Department is not involved in the actual development of technical standards.

The Department represents the United States of America administration under the treaty

obligations found in the Convention of the International Telecommunications Union (ITU),

Minneapolis, 1998, and the Inter-American Telecommunications Conference (CITEL). The

Department of State, through the EB Communications and Information Policy Deputate, provides

the forum for development of positions and contributions for presentation at ITU and CITEL

meetings where international telecommunication recommendations (voluntary standards) and

telecommunication standardization policies are written. The Department authorizes and/or hosts

public meetings under the Federal Advisory Committee Act, where advice on telecommunication

standardization and policy issues is offered by the private sector telecommunications industry. 

The Department also bases its decisions on advice from other public sector Agencies

(Department of Defense, National Institute of Standards and Technology (NIST), National

Telecommunications and Information Administration, National Aeronautics and Space

Administration, and the Federal Communications Commission). The Department coordinates,

leads, and/or accredits U.S. delegations to ITU and CITEL technical and policy meetings.

More than 100 U.S. corporations are participating members of the ITU; more than 30 are

associate members of CITEL s permanent Consultative Committee, under the sponsorship of the

State Department. Those companies and interested Government agencies participate and play

major roles in the ITU and CITEL Study Groups and Working Parties that actually write the

standards. Within that process, a great deal of interaction takes place with other standards-setting

organizations, such as the International Organization for Standardization, ANSI,

ANSI-accredited Committee T1, and the Telecommunications Industry Association.

In addition to accrediting and supporting delegations to the ITU and CITEL, the Department s

International Organization Affairs Bureau accredits and funds participation by relevant

specialized agencies (Departments of Agriculture, Commerce, and Transportation, and NIST)

and private sector groups in the deliberations of the Economic Commission for Europe (ECE)

Working Party on Standardization, especially where they have a direct bearing on U.S.

commercial interests. While the standards developed in the ECE are not officially adopted for

use in the United States, they serve as guides for adjusting product design and are widely taken

into account in manufacturing plans.
A-47

DEPARTMENT OF TRANSPORTATION (DOT)

In response to the request by the Office of Management and Budget (OMB) for information

regarding DOT s implementation of OMB Circular A-119, Federal Participation in the

Development and Use of Voluntary Standards, we respectfully submit this report. The included

data represent the fiscal year (FY) 1999 activities for the Department and its agencies.

"As required by Public Law (P.L.) 104-113, identification of all instances when the agency

used government-unique standards in lieu of voluntary consensus standards (for each

instance include agency rationale for such use, as well as the specific government-unique

standard used):

No instances were reported where the agency used government-unique standards in

lieu of voluntary consensus standards.

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

The total reported number of voluntary consensus standards used by DOT since

October 1, 1998, based on the procedures set forth in sections 11 and 12 of the

Circular is 203.

National Highway Traffic Safety Administration (NHTSA) - Since October 1,

1998, NHTSA has proposed to adopt 23 voluntary consensus standards based on

the procedures set forth in sections 11 and 12 of the Circular.

Research and Special Programs Administration (RSPA) - Since October 1, 1998,

RSPA has used approximately 180 voluntary standards based on the procedures

set forth in sections 11 and 12 of the Circular.

"The identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

RSPA - During FY 1999, RSPA adopted 19 new and 9 updated voluntary standards

as a result of its participation in standards-developing groups. In addition, RSPA is

actively considering adoption of numerous new, and updated versions of other,

voluntary consensus standards.
A-48

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

- The total reported number of DOT employees participating in at least one

standards-developing group is approximately 88 although there are 4 operating

administrations not included in this number. With the exception of the FAA and

the FRA, the other Administrations have reported separately. Their reports follow

this one.

- The total number of voluntary standards groups in which DOT employees

participate is 67.

Federal Highway Administration (FHWA) - Ten employees of FHWA participate in

at least one standards-developing group. These employees participate in

12 standards-developing groups.

Maritime Administration (MARAD) - Seven employees of MARAD participate in at

least one standards-developing group. These employees participate in five standardsdeveloping groups.

NHTSA - Thirty-one employees of NHTSA participate in at least one standardsdeveloping group. These employees participate in four standards-developing groups.

RSPA - Forty employees of RSPA participate in at least one standards-developing

group. These employees participate in 46 standards-developing groups.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The general consensus is that Circular A-119 is working effectively and that the use

of voluntary standards can save both time and money for regulatory agencies. The

only recommended change that was submitted came from the U.S. Coast Guard, 

which suggested that the circular be clarified, particularly with respect to section 12,

to better explain whether reporting should be on a categorical or transactional basis.

Coast Guard FY 1999 Report on Standard Policy Activities (OMB Circular A-119)

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

There has been no change in Coast Guard participation from its FY 1998 report.
A-49

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

In FY 1999, the Coast Guard has used 35 voluntary consensus standards based on the

procedures set forth in section 11 (use of standards in regulations) of the Circular.

Regarding section 12 of the Circular, the Coast Guard s Office of Procurement

Management (G-CPM) reports that there is no database that can provide information

on how Coast Guard procurement offices identify, manage, review, and use voluntary

consensus standards in procurements. Plans are being developed to gather this

information for future FYs.

"The identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

No voluntary consensus standards have been substituted as a result of agency review

under section 15b(7) of the Circular.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The Circular should be rewritten to make it easier to read and understand. More

examples of voluntary consensus standards and voluntary consensus standards bodies

should be given. The Circular should be clarified, with respect to section 12, to

explain when reporting should be on a categorical or transactional basis.

"As required by P.L. 104-113, identification of all instances when an agency used

government-unique standards in lieu of a voluntary consensus standard (for each instance,

include the agency rationale for such use, as well as the specific government-unique

standard used):

No government-unique standards were used in lieu of voluntary consensus standards

during this reporting period.

Federal Transit Administration

Three employees of the Agency participate in the voluntary consensus standards development

activities of the Institute of Electrical and Electronic Engineers (IEEE), Intelligent Transportation

Systems (ITS) of America, and the American Public Transit Association (APTA). Some of the

current activities are: (1) development of Rail Transit Vehicle Interface Standards in association 
A-50

with IEEE (five standards have been adopted so far), (2) development of technical specifications

and procurement guidelines for transit buses in association with APTA, and (3) development of

standards for the transit component of ITS. A modified version of J-1708, a standard of the

Society of Automotive Engineers for information sharing in heavy trucks has been adopted as a

standard by the transit industry for transit bus ITS application, and has also been submitted to the

International Organization for Standardization for acceptance as an international standard.

The agency acts in the best interests of public transit agencies who use applicable standards in

their procurements. The Agency itself does not build or operate transit systems.

Transit standards evolved over the course of time and the Agency has not promoted any

government-unique standards. The five standards adopted by IEEE are expected to be used by

the transit industry voluntarily.

OMB Circular A-119 and P.L. 104-113, the National Technology Transfer and Advancement

Act of 1995, which encouraged Federal participation in the development of voluntary industry

standards resulted in greater Agency participation for development of voluntary standards for

public transit.

No government-unique standards are promoted in lieu of voluntary consensus standards.
A-51

DEPARTMENT OF THE TREASURY (TREASURY)

The Department of the Treasury reports the following:

"As required by Public Law (P.L.) 104-113, identification of all instances when the agency

used government-unique standards in lieu of voluntary consensus standards (for each

instance include agency rationale for such use, as well as the specific government-unique

standards used):

Customs continues to support two government-unique standards, which are Customs

and Trade Automated Interface Requirements (CATAIR) (Amendment 1, April 1996;

Amendment 2, December 1996; Amendment 3, September 1997; and Amendment 4,

1998) and Customs Automated Manifest Interface Requirements (CAMIR) format

(Amendment 1, April 1997; and Amendment 2, July 1998). CATAIR is used by the

Customs brokerage industry and CAMIR is used by some parties in the transportation

sector. The maintenance of the government-unique standards within Customs

applications (the CATAIR and CAMIR formats), are at the request of the

participating industry groups that use those standards.

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

The Department used six voluntary consensus standards. In addition, an unknown

number of voluntary consensus standards are used as a result of implementing

commercial off-the-shelf hardware and software.

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

No voluntary consensus standards have been substituted for government-unique

standard as a result of our Department-wide review of existing standards.

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

The Department participated in 9 voluntary consensus standards bodies that

accounted for approximately 19 employees participating.
A-52

"An evaluation of the effectiveness of A-119 policy and recommendations for any

changes:

The Department believes that the guidelines prescribed in Circular A-119 are

effective. Circular A-119 has placed the focus on using voluntary consensus

standards as opposed to the development of government-unique standards. Wide use

of voluntary consensus standards promotes the development of an increased number

of standards compliant products facilitating the use of new technology and increasing

flexibility to meet new requirements.
A-53

DEPARTMENT OF VETERANS AFFAIRS (VA)

As required by Office of Management and Budget (OMB) Circular A-119, VA reports the

following:

"As required by Public Law (P.L.) 104-113, identification of all instances when the agency

used government-unique standards in lieu of voluntary consensus standards (for each

instance include agency rationale for such use, as well as the specific government-unique

standard used):

None

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

36

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

None

"The number of voluntary consensus standard bodies in which there is agency

participation, as well as the number of agency employees participating:

VA has 12 employees participating in 26 voluntary consensus standard bodies.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The Circular has no side effects to our present Department goal. VA accepts and

conforms to the standards developed by the Joint Commission on Accreditation of

Hospitals Organization (JCAHO) for the VA health care system in order to obtain

JCAHO certification of VA health care facilities. Standards as outlined in the

accreditation program for hospitals, psychiatric facilities mental health centers, longterm and hospice programs, ambulatory health care facilities, community and nursing

homes under VA contract, State home facilities, hospital-based care programs, and

various JCAHO accreditation standards (National Fire Protection Association, Life

Safety Code requirements, and other building, plumbing, electrical, mechanical, and 
A-54

equipment standards/requirements) continue to be utilized in the regulatory,

contractual, and grant determinations executed by the Veterans Health

Administration.
B-1

Appendix B:

Other Agency and Commission

Reports
B-2

AGENCY FOR INTERNATIONAL DEVELOPMENT (USAID)

The nature of the activities funded by USAID greatly limits the Agency s use of standards in its

procurement. USAID procures mostly professional and technical services. To the extent that

USAID uses standards for its procurement or financing of commodities, the standards are

industry standards.

"The Agency has not used government-unique standards in lieu of voluntary consensus

standards.

"The Agency has not used any voluntary consensus standards based on the procedures in

sections 11 and 12 of the Circular.

"N/A.

"None.

"No recommendations for changes to A-119.
B-3

CONSUMER PRODUCT SAFETY COMMISSION (CPSC)

The Consumer Product Safety Act, as amended, requires the Commission to defer to issued

voluntary standards, rather than promulgate mandatory standards, when the voluntary standards

would eliminate or adequately reduce the risk of injury addressed and it is likely that there will be

substantial compliance with the voluntary standards. In addition, the Commission is required,

after any notice or advance notice of proposed rulemaking, to provide technical and

administrative assistance to persons or groups who propose to develop or modify an appropriate

voluntary standard. Additionally, the Commission is encouraged to provide technical and

administrative assistance to groups developing product safety standards and test methods, taking

into account Commission resources and priorities.

Since its inception in 1973, the Commission has promoted the development of voluntary product

safety standards. Policy statements in support of voluntary standards were published by the

CPSC in 1975 and 1978. These policy statements were updated in 1988 (16 U.S.C. 1031), and a

staff directive on implementation of portions of these policy statements was promulgated in

October 1989.

Since the principles set forth in the Office of Management and Budget (OMB) Circular A-119

were published, they have been consistently supported by the Commission. The CPSC Voluntary

Standards Coordinator also serves as CPSC s Standards Executive for the purpose of

implementing OMB Circular A-119 and provides general oversight for staff involvement in

existing standards projects. The Voluntary Standards Coordinator establishes agency views on

standards issues and decisions through Commission response to staff briefing packages and

recommendations. These views are reflected in the Commission's Operating Plan and Budget. 

Coordinating participation within the Commission and with others in voluntary standards

activities is a responsibility of the Voluntary Standards Coordinator. Likewise, the Voluntary

Standards Coordinator is responsible for meeting reporting requirements applicable to voluntary

standards involvement of Commission staff.

The Commission had 25 employees directly participating in 65 voluntary standards development

projects during fiscal year (FY) 1999. Since October 1, 1998, the Commission incorporated, by

reference, portions of four voluntary standards in CPSC regulations. During FY 1999, there were

no voluntary consensus standards that were substituted for government-unique standards as a

result of an agency review of existing standards.

During FY 1999, the Commission's efforts to enhance voluntary standards development was

complemented by the overall Federal policy set forth in the Circular. CPSC involvement in

voluntary standards activities was consistent with Circular A-119. There are no

recommendations for changes in the Circular at this time.
B-4

For further information, please contact the CPSC s Standards Executive:

Mr. Colin B. Church

Voluntary Standards and International

Activities Coordinator

U.S. Consumer Product Safety Commission

Room 600C

Washington, D.C. 20207

Telephone: 301-504-0554, ext. 2229

Fax: 301-504-0407

E-mail: cchurch@cpsc.gov
B-5

ENVIRONMENTAL PROTECTION AGENCY (EPA)

EPA is pleased to forward the following report to the National Institute of Standards and

Technology for submission to the Office of Management and Budget (OMB) and Congress. The

report details EPA s fiscal year (FY) 1999 implementation of Public Law (P.L.) 103-114,

section 12(d), The National Technology Transfer and Advancement Act (NTTAA), and the

corresponding OMB Circular A-119, Federal Participation in the Development and Use of

Voluntary Standards and Conformity Assessment Activities. 

Highlights

"In the FY 1999 reporting period, EPA promulgated 617 final rules, of which 207

(33.5 percent) referenced the NTTAA. In addition to these, the Agency published a variety of

proposed rules, many of which also addressed compliance with the NTTAA. The total

number of final and proposed rules that contained reference to the NTTAA was 326. This

number reflects an increase of more than 300 percent over the 1998 report on the number of

final and proposed rules referencing the NTTAA. This increase reflects both the increasingly

successful implementation of the NTTAA and OMB Circular within the Agency and the use

of the interim Rule Writer s Guide made available last year.

In FY 1999, 10 final rules and 6 proposed rules adopted (or proposed for adoption) more than

45 voluntary consensus standards. Within 10 final rules, EPA found 83 instances where 18

voluntary consensus standards were found to be impracticable for agency use. Not all

adopted standards were new standards or newly referenced by EPA. In several cases, the

references included standards that had been previously adopted by EPA in other rulemaking

activities.

"One of the most notable examples of Agency rulemaking integrating the spirit as well as the

letter of the OMB Circular is found in the regulatory activities of the Office of Air and

Radiation (OAR) in the area of National Emission Standards for Hazardous Air Pollutants

(NESHAP). The following notation occurs in several OAR Federal Register notices this

year:

As part of a larger effort, the Agency is undertaking a project to cross-reference existing

voluntary consensus standards in testing, sampling, and analysis, with current and future

EPA test methods. When completed, this project will assist us in identifying potentially

applicable voluntary consensus standards that can then be evaluated for equivalency and

applicability in determining compliance with future regulations.
B-6

Required Reporting Elements under OMB Circular A-119

"The number of voluntary consensus standards bodies in which there is Agency participation,

and the number of employees participating:

Currently, 197 EPA employees participate in 15 standards organizations, including:

The American National Standards Institute (ANSI)

The American Gas Association

The American Petroleum Institute (API)

The American Society of Quality Control (ASQ)

The American Society for Mechanical Engineers (ASME)

ASTM (formerly known as the American Society of Testing and Materials)

The National Fire Protection Association (NFPA)

NSF International

The Society of Automotive Engineers (SAE)

The Technical Association of the Pulp and Paper Industry (TAPPI)

Underwriters Laboratories, Inc. (UL)

The International Organization for Standardization (ISO)

The International Electrotechnical Commission (IEC)

NACE International (formerly National Association of Corrosion Engineers)

Standard Methods (the American Water Works Association, the Water Environment

 Federation, and the American Public Health Association jointly publish Standard

 Methods for the Examination of Water and Wastewater )

In addition to participation, EPA employees serve as officers on Boards and Committees. 

These include but are not limited to:

Board of Directors, American National Standards Institute

Technical Advisory Board, Society of Automotive Engineers

Chairman s Advisory Council, Underwriters Laboratories, Inc.

ANSI Accredited Standards Committee Z-1 on Quality and Environmental

 Management

American Society for Quality Standards Committee, Convener for revision of ANSI/

 ASQC E4-1994

U.S. Technical Advisory Group to ISO Technical Committee 176 on Quality

 Management

U.S. Technical Advisory Group to ISO Technical Committee 207 on Environmental

 Management
B-7

"The number of voluntary consensus standards the Agency has used since October 1, 1998:

In FY 1999, EPA adopted or incorporated by reference greater* than 34 voluntary

consensus standards in final rulemaking actions. In 1998, EPA proposed the adoption of

more* than eight specific voluntary consensus standards in proposed rulemaking

activities.

In 22 proposed and final rules in 1998, EPA requested comment on, or assistance in

identifying, voluntary consensus standards.

* In several rules, EPA noted that the Agency was using, or continuing its use of,

voluntary consensus standards included in cited tables of test methods and other

standards in the Federal Register. These rules did not specify the exact number of

newly added or proposed voluntary consensus standards. For this reason, it is

difficult to provide a precise answer to this requirement in A-119 to identify the

number of voluntary consensus standards the Agency uses each year.

"Identification of voluntary consensus standards that have been substituted for governmentunique standards as a result of an Agency review of existing standards:

In 1999, EPA did not specifically identify in its Federal Register publications situations

where it substituted voluntary consensus standards for government-unique standards, but

in seven proposed and final rules requested assistance in identification of any standards

that would allow such substitution that the Agency could use in future rulemakings.

"Agency use of government-unique standards in lieu of voluntary consensus standards:

Within 10 final rules in FY 1999, excerpts of which follow starting on page B-8, in 83

instances, EPA rejected 18 existing voluntary consensus standards based on

impracticability, citing issues such as lack of validation data or, in the case of one

International Organization for Standardization (ISO) standard (8178), based on the

inability of the standard to accommodate broad application because the standard relies

too heavily on reference test conditions. Because the test procedures in the regulations

need to be used not only for certification, but also for production line testing, selective

enforcement audits and in-use testing, they must be broadly based. The Agency

determined that the ISO procedures are not sufficiently broadly usable in their current

form and thus could not be adopted by reference.

There has been a dramatic increase in EPA s instances reported of government unique

standards used in lieu of voluntary consensus standards from the previous report. This is

due, in part, to two different phenomena. First, from 1997 to 1999, EPA put a series of

tools in place that have improved its rule writers  ability to find and evaluate standards.

Second, EPA s use of voluntary consensus standards cannot be analyzed by comparing
B-8

absolute numbers from year to year. Since the Agency s regulatory agenda varies

annually in the number and kinds of regulations promulgated. Because of this fluctuation

each year, the Agency s opportunity to use voluntary consensus standards in regulation

will vary.

In one NESHAP rule, more than 12 of these standards were rejected in lieu of

government- unique standards. EPA s reasoning and justification are consistent with the

NTTAA. The Federal Register notice states:

Candidate voluntary consensus standards for materials analysis were identified for

free-formaldehyde content. Consensus comments provided by industry experts were

that the candidate standards did not meet industry materials analysis requirements. 

Therefore, EPA has determined these voluntary consensus standards are impractical

for the mineral wool production NESHAP. The EPA, in consultation with the North

American Insulation Manufacturers Association (NAIMA) has formulated an

industry-specific materials analysis consensus standard for free-formaldehyde content,

which is promulgated in this rule.

Excerpts from Preambles to Final Rules Published by EPA During FY 1999 Pertaining to

Compliance with the National Technology Transfer and Advancement Act of 1995

(Prepared as a Supplement to EPA s 1999 Report on The Implementation of The National

Technology Transfer and Advancement Act, Sec. 12(d), and OMB Circular A-119")

1. National Emission Standards for Hazardous Air Pollutants: Pesticide Active Ingredient

Production, FR 33550, June 23, 1999.

 I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA),

P.L. 104-113 (March 7, 1996), directs all Federal agencies to use voluntary consensus standards

in regulatory and procurement activities unless to do so would be inconsistent with applicable

law or otherwise impracticable. Voluntary consensus standards are technical standards (e.g.,

materials specifications, test methods, sampling procedures, and business practices) developed or

adopted by one or more voluntary consensus bodies. The NTTAA requires Federal agencies to

provide Congress, through annual reports to OMB, with explanations when an agency does not

use available and applicable voluntary consensus standards. This section summarizes the EPA's

response to the requirements of the NTTAA for the analytical and test methods to be required by

today's final rule.

Consistent with the NTTAA, the EPA conducted a search to identify voluntary consensus

standards. The search identified 22 voluntary consensus standards that appeared to have possible

use in lieu of EPA standard reference methods in this rule. However, after reviewing available

standards, EPA determined that 14 of the candidate consensus standards identified for measuring
B-9

emissions of the HAP or surrogates subject to emission standards in the rule would not be

practical due to lack of equivalency, documentation, validation data or other important technical

and policy considerations. Eight of the remaining candidate consensus standards are new

standards under development that EPA plans to follow, review, and consider adopting at a later

date.

One consensus standard, ASTM Z7420Z, is potentially practical for EPA use in lieu of EPA

Method 18 (See 40 CFR Part 60, Appendix A). At the time of EPA's search, the ASTM standard

was still under development and EPA had provided comments on the method. The EPA also

compared a draft of this ASTM standard to methods previously approved as alternatives to EPA

Method 18 with specific applicability limitations. These methods, designated as ALT-017 and

CTM-028, are available through EPA's Emission Measurement Center Internet site at

www.epa.gov/ttn/emc/tmethods.html. The proposed ASTM Z7420Z standard is very similar to

these approved alternative methods. When finalized and adopted by ASTM, the standard may be

equally suitable for specific applications. However, this rule does not adopt the ASTM standard

as it is not practical to do so until the potential candidate is final and EPA has reviewed the final

standard. The EPA plans to continue to follow the progress of the standard and will consider

adopting the ASTM standard at a later date.

This final rule requires standard EPA methods known to the industry and States. Approved

alternative methods also may be used with prior EPA approval. 

2. National Emission Standards for Hazardous Air Pollutants: Oil and Natural Gas

Production and National Emission Standards for Hazardous Air Pollutants: Natural Gas

Transmission and Storage, 64 FR 32610, June 17, 1999.

 J. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA),

P.L. 104-113 (March 7, 1996), directs all Federal agencies to use voluntary consensus standards

in regulatory and procurement activities unless doing so would be inconsistent with applicable

law or otherwise impracticable. Voluntary consensus standards are technical standards (e.g.,

materials specifications, test methods, sampling procedures, and business practices) developed or

adopted by one or more voluntary consensus bodies. The NTTAA requires Federal agencies to

provide Congress, through annual reports to OMB, with explanations when an agency does not

use available and applicable voluntary consensus standards. This section summarizes the EPA's

response to the requirements of the NTTAA for the analytical and test methods required by this

final rule.

Consistent with the NTTAA, the EPA conducted a search to identify voluntary consensus

standards. The search identified 16 voluntary consensus standards that appeared to have possible

use in lieu of EPA standard reference methods. However, after reviewing available standards,

the EPA determined that eight of the candidate consensus standards identified for measuring
B-10

HAP or surrogate pollutant emissions subject to the emission standards in the rule would not be

practical due to lack of equivalency, documentation, validation data and other important

technical and policy considerations. Seven of the remaining candidate consensus standards are

new standards under development that the EPA plans to follow, review, and consider adopting at

a later date.

One consensus standard, ASTM Z7420Z, is potentially practical for EPA use in lieu of EPA

Method 18 (See 40 CFR part 60, appendix A). At the time of the EPA's search, the ASTM

standard was still under development and the EPA had provided comments on the method. 

The EPA also compared a draft of this ASTM standard to methods previously reviewed as

alternatives to EPA Method 18 that were approved with specific applicability limitations. These

methods are designated as ALT-017 and CTM-028 and available through EPA's Emission

Measurement Center Internet site at www.epa.gov/ttn/emc/tmethods.html. The proposed ASTM

Z7420Z standard is very similar to these approved alternative methods. When finalized and

adopted by ASTM, the standard may be equally suitable for the same applications as the

approved *32628 alternatives. However, this rule does not adopt the ASTM standard since it is

not practical to do so until the potential candidate is final and the EPA has review the final

standard. The EPA plans to continue to follow the progress of the standard and will consider

adopting the ASTM standard at a later date.

Similarly, the Gas Research Institute has developed a sampling method for glycol dehydration

units, the "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions"

(GRI-95/0368.1). The development of this procedure included a field evaluation program and

technical review by the EPA. A report documenting this procedure has been available to the

public from the GRI since 1996. This procedure provides a simpler, cheaper, and technically

appropriate means of determining HAP emissions from glycol dehydration unit process vents

when direct measurement is necessary. Consistent with the Agency's commitment to reduce

costs to the private sector where technically feasible and in accordance with Clean Air Act

requirements, the EPA has included the "Atmospheric Rich/Lean Method for Determining

Glycol Dehydrator Emissions" as an alternative control device performance test procedure. This

rule requires standard EPA methods known to the industry and States. Approved alternative

methods also may be used with prior EPA approval. 

3. National Emission Standards for Hazardous Air Pollutants for Source Categories: Wool

Fiberglass Manufacturing, 64 FR 31695, June 14, 1999.

 I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA),

P.L. 104-113 (March 7, 1996), directs the EPA to use voluntary consensus standards in

regulatory and procurement activities unless to do so would be inconsistent with applicable law

or otherwise impractical. Voluntary consensus standards are technical standards (such as

materials specifications, test methods, sampling procedures, and business practices) which are
B-11

developed or adopted by voluntary consensus standard bodies. Where available and potentially

applicable voluntary consensus standards are not used by EPA, the Act requires the Agency to

provide Congress, through the OMB, an explanation for not using such standards. This section

summarizes the EPA's response to the requirements of the NTTAA for the analytical test

methods promulgated as part of this final rule.

Consistent with the NTTAA, the EPA conducted searches to identify voluntary consensus

standards for the EPA's emissions sampling and analysis reference methods and industry

recommended materials analysis procedures cited in this rule. Candidate voluntary consensus

standards for materials analysis were identified for product loss on ignition (LOI), product

density, and free formaldehyde content. Consensus comments provided by industry experts were

that the candidate standards did not meet industry materials analysis requirements. Therefore,

EPA has determined these voluntary consensus standards were impractical for the wool

fiberglass manufacturing NESHAP. The EPA, in consultation with the North American

Insulation Manufacturers Association (NAIMA), has formulated industry-specific materials

analysis, consensus standards which are promulgated in this rule. *31708

The EPA search to identify voluntary consensus standards for the EPA's emissions sampling and

analysis reference methods cited in this rule identified 17 candidate standards that appeared to

have possible use in lieu of EPA standard reference methods. However, after reviewing available

standards, EPA determined that 12 of the candidate consensus standards identified for measuring

emissions of the HAPs or surrogates subject to emission standards in the rule would be not be

practical due to lack of equivalency, documentation, validation data and other important

technical and policy considerations. Five of the remaining candidate consensus standards are

new standards under development that EPA plans to follow, review and consider adopting at a

later date. This rule requires standard EPA emission test methods known to the industry and

States. Approved alternative methods also may be used with prior EPA approval. 

4. National Emission Standards for Hazardous Air Pollutants for Source Categories: Portland

Cement Manufacturing Industry, 64 FR 31898, June 14, 1999.

 Voluntary Consensus Standards

Comment: One commenter (IV-D-17) stated that EPA's actions (in developing and proposing the

precursor to EPA Fourier Transform Infrared Spectroscopy [FTIR] test method 320) directly

conflict with the guidance of and directives of the 1995 National Technology Transfer and

Advancement Act and the Office of Management and Budget (OMB) Circular A-119 because: 

(1) the American Society of Testing and Materials (ASTM) FTIR consensus based test method is

available, and (2) the EPA Emission Measurement Center (EMC) representatives were made

aware of the development of the ASTM method and chose duplicative measures in developing

and proposing the precursor to EPA FTIR test method 320. (The OMB Circular states

specifically that "If a voluntary consensus standards body is in the process of developing or

adopting a voluntary consensus standard that would likely be lawful and practical for an agency
B-12

to use, and would be developed on a timely basis, an agency should not be developing its own

government unique standard and instead should be participating in the activities of the voluntary

consensus standards body.")

Response: The Agency has been actively developing extractive FTIR-based methods for HAPs

since 1992. Methods 320 and 321 are direct products of this long-term effort to apply an

innovative approach to emissions measurement in the form of extractive FTIR. The Agency has

tested these methods in the laboratory and in the field extensively (conducting testing at two

portland cement facilities), and has conducted multiple validation tests of these methods. The

Portland Cement Association (PCA), in representing various members of the regulated industry,

has conducted its own series of validation tests of these methods. Actually, Method 321 was

developed and validated by PCA, and has been adopted by the Agency as Method 321. Agency

personnel informed ASTM in 1996 that the Agency methods were in active development, and an

ASTM standard seemed redundant. Additionally, the ASTM standard has not undergone field

validation, which is essential in establishing the precision and accuracy of any test method. The

Agency has conducted a review of the ASTM method. While the ASTM method is in some ways

similar to Method 320, the ASTM method is not sufficiently detailed to document proper

application, and does not contain the quality assurance procedures the Agency requires in

compliance methods. Specifically, the ASTM method does not address specific calibration

transfer standards, nor does it address the preparation of reference spectra. Therefore, EPA has

determined that it is impractical to adopt the ASTM method at this time and is promulgating

Method 320.

..........

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA) directs all

Federal agencies to use voluntary consensus standards in regulatory and procurement activities

unless to do so would be inconsistent with applicable law or otherwise impracticable. Voluntary

consensus standards are technical standards (e.g., materials specifications, test methods, sampling

procedures, and business practices) developed or adopted by one or more voluntary consensus

bodies. The NTTAA requires Federal agencies to provide Congress, through annual reports to

OMB, with explanations when an agency does not use available and applicable voluntary

consensus standards.

Consistent with the NTTAA, the EPA conducted a search to identify voluntary consensus

standards. The search identified 21 voluntary consensus standards that appeared to have possible

use in lieu of EPA standard reference methods. However, after reviewing available standards,

EPA determined that 14 of the candidate consensus standards identified for measuring emissions

of the HAPs or surrogates subject to emission standards in the rule would not be practical due to

lack of equivalency, documentation, validation data and other important technical and policy

considerations. Six of the remaining candidate consensus standards are new standards under

development that EPA plans to follow, review and consider adopting at a later date.
B-13

One consensus standard, ASTM D6216-98, appears to be practical for EPA use in lieu of EPA

Performance Specification 1 (See 40 CFR Part 60, Appendix B). On September 23, 1998, EPA

proposed incorporating by reference ASTM D6216-98 under a separate rulemaking

(63 FR 50824) that would allow broader use and application of this consensus standard. EPA

plans to complete this action in the near future. For these reasons, EPA defers taking action in

this rulemaking that would adopt D6216-98 in lieu of PS-1 requirements as it would be

impractical for EPA to act independently from other rulemaking activity already undergoing

notice and comment.

Additionally, EPA received comments that ASTM FTIR Standard D6348 should be used in lieu

of EPA's proposed Fourier transform infrared spectroscopy (FTIR) emission test methods. EPA

has determined for a number of reasons that the ASTM Standard D6348 is one of the

14 standards determined to be impractical to adopt for the purposes of this rulemaking. EPA

review comments on ASTM Standard D6348 are included in the docket for this rulemaking and

summarized in the response to comments section of this preamble. ASTM has also been advised

of the reasons for impracticality and ASTM Subcommittee D22-03 is now undertaking a revision

of the ASTM standard. Upon demonstration of technical equivalency with the EPA FTIR

methods, the revised ASTM standard could be incorporated by reference for EPA regulatory

applicability at a later date.

This rule requires standard EPA methods known to the industry and States. Approved alternative

methods also may be used with prior EPA approval. 

5. National Emission Standards for Hazardous Air Pollutants: Phosphoric Acid Manufacturing

and Phosphate Fertilizers Production, 64 FR 31358, June 10, 1999.

 H. National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA), directs all

Federal agencies to use voluntary consensus standards in regulatory and procurement activities

unless to do so would be inconsistent with applicable law or otherwise impracticable. Voluntary

consensus standards are technical standards (e.g., materials specifications, test methods, sampling

procedures, and business practices) developed or adapted by one or more voluntary consensus

bodies. The NTTAA requires Federal agencies to provide Congress, through annual reports to

OMB, with explanations when an agency does not use available and applicable voluntary

consensus standards.

.

Consistent with the requirements of the NTTAA, today's rulemaking incorporates the analytical

methods of two consensus standard bodies. Instead of developing its own methods for

determining the phosphate content of feedstocks to the processes covered by the standards, the

Agency is incorporating by reference into today's rules certain analytical protocols of the

Association of Official Analytical Chemists and of The Association of Florida Phosphate

Chemists.
B-14

Also, consistent with the NTTAA, the EPA conducted a search to identify voluntary consensus

standards for emissions test methods. The search identified 17 voluntary consensus standards

that appeared to have possible use in lieu of EPA standard reference methods. However, after

reviewing available standards, EPA determined that 12 of the candidate consensus standards

identified for measuring emissions of the HAPs or surrogates subject to emission standards in the

rule would not be practical due to lack of equivalency, documentation, validation data and other

important technical and policy considerations. Five of the remaining candidate consensus

standards are new standards under development that EPA plans to follow, review and consider

adopting at a later date. This rule requires standard EPA methods known to the industry and

States. Approved alternative methods also may be used with prior EPA approval. 

6. National Emission Standards for Hazardous Air Pollutants for Source Categories: National

Emission Standards for Hazardous Air Pollutants for Mineral Wool Production,

64 FR 29420, June 1, 1999.

 J. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA),

P.L. 104-113 (March 7, 1996), directs the EPA to use voluntary consensus standards in

regulatory and procurement activities unless to do so would be inconsistent with applicable law

or otherwise impractical. Voluntary consensus standards are technical standards (such as

materials specifications, test methods, sampling procedures, and business practices) which are

developed or adopted by voluntary consensus standard bodies. Where available and potentially

applicable voluntary consensus standards are not used by EPA, the Act requires the Agency to

provide Congress, through the OMB, an explanation for not using such standards. This section

summarizes the EPA's response to the requirements of the NTTAA for the analytical test

methods promulgated as part of this final rule.

Consistent with the NTTAA, the EPA conducted searches to identify voluntary consensus

standards for the EPA's emissions sampling and analysis reference methods and industry

recommended materials analysis procedures cited in this rule. Candidate voluntary consensus

standards for materials analysis were identified for free-formaldehyde content. Consensus

comments provided by industry experts were that the candidate standards did not meet industry

materials analysis requirements. Therefore, EPA has determined these voluntary consensus

standard are impractical for the mineral wool production NESHAP. The EPA, in consultation

with the North American Insulation Manufacturers Association (NAIMA), has formulated an

industry-specific materials analysis, consensus standard for free-formaldehyde content which is

promulgated in this rule.

The EPA search to identify voluntary consensus standards for the EPA's emissions sampling and

analysis reference methods cited in this rule identified 17 voluntary consensus standards that

appeared to have possible use in lieu of EPA standard reference methods. However, after

reviewing available standards, EPA determined that 12 of the candidate consensus standards
B-15

identified for measuring emissions of the HAPs or surrogates subject to emission standards in the

rule would not be practical due to lack of equivalency, documentation, validation data and other

important technical and policy considerations. Five of the remaining candidate consensus

standards are new standards under development that EPA plans to follow, review and consider

adopting at a later date. This rule requires standard EPA emission test methods known to the

industry and States. Approved alternative methods also may be used with prior EPA approval. 

7. National Emission Standards for Hazardous Air Pollutants for Polyether Polyols Production, 

64 FR 29420, June 1, 1999.

 J. National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and Advancement Act (NTTAA),

P.L. 104-113 (March 7, 1996), directs all Federal agencies to use voluntary consensus standards

in regulatory and procurement activities unless to do so would be inconsistent with applicable

law or otherwise impracticable. Voluntary consensus standards are technical standards (e.g.,

materials specifications, test methods, sampling procedures, and business practices) developed or

adopted by one or more voluntary consensus bodies. The NTTAA requires Federal agencies to

provide Congress, through annual reports to OMB, with explanations when an agency does not

use available and applicable voluntary consensus standards. This section summarizes the EPA's

response to the requirements of the NTTAA for the analytical and test methods to be required by

this final rule.

Consistent with the NTTAA, the EPA conducted a search to identify voluntary consensus

standards. The search identified 15 voluntary consensus standards that appeared to have possible

use in lieu of EPA standard reference methods in this rule. However, after reviewing available

standards, EPA determined that eight of the candidate consensus standards identified for

measuring emissions of the HAP or surrogates subject to emission standards in the rule would

not be practical due to lack of equivalency, documentation, validation data or other important

technical and policy considerations. Seven of the remaining candidate consensus standards are

new standards under development that EPA plans to follow, review and consider adopting at a

later date. *29439

One consensus standard, ASTM Z7420Z, is potentially practical for EPA use in lieu of EPA

Method 18 (See 40 CFR part 60, appendix A). At the time of EPA's search, the ASTM standard

was still under development and EPA had provided comments on the method. The EPA also

compared a draft of this ASTM standard to methods previously approved as alternatives to EPA

Method 18 with specific applicability limitations. These methods, designated as ALT-017 and

CTM-028, are available through EPA's Emission Measurement Center Internet site at

www.epa.gov/ttn/emc/tmethods.html. The proposed ASTM Z7420Z standard is very similar to

these approved alternative methods. When finalized and adopted by ASTM, the standard may be

equally suitable for specific applications. However, today's rule does not adopt the ASTM

standard at this time as it is not practical to do so until the potential candidate is final and EPA
B-16

has reviewed the final standard. The EPA plans to continue to follow the progress of the

standard and will consider adopting the ASTM standard at a later date.

This rule requires standard EPA methods known to the industry and States. Approved alternative

methods also may be used with prior EPA approval. 

8. Phase 2 Emission Standards for New Nonroad spark-Ignition Nonhandheld Engines At or

Below 19Kilowatts, 64 FR 15208, March 30, 1999.

 F. National Technology Transfer and Advancement Act 

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 ("NTTAA"),

Public Law No. 104-113, Section 12(d) (15 U.S.C. 272 note), directs EPA to use voluntary

consensus standards in its regulatory activities unless doing so would be inconsistent with

applicable law or otherwise impractical. Voluntary consensus standards are technical standards

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are

developed or adopted by voluntary consensus standards bodies. The NTTAA directs EPA to

provide Congress, through OMB, explanations when the Agency decides not to use available and

applicable voluntary consensus standards.

This final rule involves technical standards. While commenters suggested the use of ISO 8178

test procedures for measuring emissions, the Agency has decided not to rely on the ISO

procedures in this rulemaking. The Agency has determined that these procedures would be

impractical because they rely too heavily on reference testing conditions. Since the test

procedures in these regulations need to be used not only for certification, but also for production

line testing, selective enforcement audits, and in-use testing, they must be broadly based. In-use

testing is best done outside tightly controlled laboratory conditions so as to be representative of

in-use conditions. EPA has determined that the ISO procedures are not sufficiently broadly

usable in their current form for this program, and therefore cannot be adopted by reference. EPA

has instead chosen to continue to rely on the procedures outlined in 40 CFR Part 90. EPA is

hopeful that future ISO test procedures will be developed that are usable for the broad range of

testing needed, and that such procedures could then be adopted by reference. 

9. National Primary Drinking Water Regulations: Interim Enhanced surface Water Treatment,

63 FR 69478, December 16, 1998.

 D. National Technology Transfer and Advancement Act

Under section 12(d) of the National Technology Transfer and Advancement Act ("NTTAA"), the

Agency is required to use voluntary consensus standards in its regulatory activities unless to do

so would be inconsistent with applicable law or otherwise impractical. Voluntary consensus

standards are technical standards (e.g., materials specifications, test methods, sampling

procedures, business practices, etc.) that are developed or adopted by voluntary consensus
B-17

standards bodies. Where available and potentially applicable voluntary consensus standards are

not used by EPA, the Act requires the Agency to provide Congress, through the Office of

Management and Budget, an explanation of the reasons for not using such standards.

Today's rule requires the use of previously approved technical standards for the measurement of

turbidity. In previous rulemakings, EPA *69510 approved three methods for measuring turbidity

in drinking water. Turbidity is a method-defined parameter and therefore modifications to any of

the three approved methods requires prior EPA approval. One of the approved methods was

published by the Standard Methods Committee of American Public Health Association, the

American Water Works Association, and the Water Environment Federation, a voluntary

consensus standard body. That method, Method 2130B is published in Standard Methods for the

Examination of Water and Wastewater (19th ed.). Standard Methods is a widely used reference

which has been peer-reviewed throughout the scientific community. In addition to this voluntary

consensus standard, EPA approved Great Lakes Instrument Method 2 as an alternate test

procedure for the measurement of turbidity. Finally, the Agency approved a revised EPA

Method 180.1 for turbidity measurement in August 1993 in Methods for the Determination of

Inorganic Substances in Environmental Samples (EPA- 600/R-93-100).

In 1994, EPA reviewed and rejected an additional technical standard for the measurement of

turbidity, the ISO 7027 standard, which measures turbidity at a higher wavelength than the

approved test measurement standards. The ISO 7027 is an analytical method for the

measurement of turbidity. ISO 7027 measures turbidity using either 90degrees scattered or

transmitted light depending on the turbidity concentration evaluated. Although instruments

conforming to ISO 7027 specifications are similar to the GLI instrument, only the GLI

instrument uses pulsed, multiple detectors to simultaneously read both 90degrees scattered and

transmitted light. EPA has no data upon which to evaluate whether the separate 90degrees

scattered or transmitted light measurement evaluations according to the ISO 7027 method would

produce results that are equivalent to results produced using GLI Method 2, Standard Method

2130B, or EPA Method 180.1.

Today's final rule also requires continuous individual filter monitoring for turbidity and requires

PWSs to calibrate the individual turbidimeter according to the turbidimeter manufacturer's

instructions. These calibration instructions may constitute technical standards as that term is

defined in the NTTAA. EPA has looked for voluntary consensus standards with regard to

calibration of turbidimeter. The American Society for Testing and Materials (ASTM) is

developing such voluntary consensus standards; however, there do not appear to be any voluntary

consensus standards available at this time. 

 10. Control of Emissions of Air Pollution From Nonroad Diesel Engines, 63 FR 56968,

October 23, 1998.

 F. National Technology Transfer and Advancement Act
B-18

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 ("NTTAA"),

Public Law 104-113, section 12(d) (15 U.S.C. 272 *56994 note) directs EPA to use voluntary

consensus standards in its regulatory activities unless doing so would be inconsistent with

applicable law or otherwise impractical. Voluntary consensus standards are technical standards

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are

developed or adopted by voluntary consensus standards bodies. The NTTAA directs EPA to

provide Congress, through OMB, explanations when the Agency decides not to use available and

applicable voluntary consensus standards.

This final rule involves technical standards. While commenters suggested the use of ISO 8178

test procedures for measuring emissions, the Agency has decided not to rely on these ISO

procedures in this rulemaking. The Agency has determined that these procedures would be

impracticable because they rely too heavily on reference testing conditions. Because the test

procedures in these regulations need to represent in-use operation typical of operation in the

field, they must be based on a range of ambient conditions. EPA has determined that the ISO

procedures are not broadly usable in their current form, and therefore cannot be adopted by

reference. EPA has instead chosen to continue to rely on the procedures outlined in 40 CFR

Part 89. EPA is hopeful that future ISO test procedures will be developed that are usable for the

broad range of testing needed, and that such procedures could then be adopted by reference. 

EPA also expects that any development of revised test procedures will be done in accordance

with ISO procedures and in a balanced manner and thus include the opportunity for involvement

of a range of interested parties (potentially including parties such as industry, EPA, state

governments, and environmental groups) so that the resulting procedures can represent these

different interests

"Evaluation of the effectiveness of OMB Circular A-119 policy and recommendations for any

changes:

EPA finds that the policies of the Circular work well, and does not recommend any

changes at this time. However, EPA would welcome clarification on the issue of whether

or not Departments and Agencies may use appropriated funds for membership in

voluntary standards bodies. While it is implied, particularly in section 7, it may be

helpful to provide specific language in future revisions.
B-19

EPA Standards-related Activities

EPA is integrating voluntary consensus standards into an increasingly broad area of activities. In

some instances, this integration is possibly as important to the intent of the NTTAA and OMB

Circular as EPA s actual incorporation of standards into regulations. That is: EPA s influence

goes beyond the borders of regulation. By using existing voluntary standards in setting up

 excellence programs or engaging standards organizations to identify pollution prevention

opportunities, EPA not only avoids re-creating the wheel, but leverages the interests,

economics, and expertise of the entire community to reach environmental goals of the

Administration.

The Office of Prevention Pesticides and Toxic Substances demonstrates this through the

collaborative efforts between its Pollution Prevention Division and one U.S. standards

developing organization (SDO), Underwriters Laboratories (UL). EPA and UL are working to

develop standards that incorporate the best environmental information into product standards

available for the general consumer and also government procurement. Another good example is

found in the Office of Underground Storage Tanks (USTs) within the Office of Solid Waste and

Emergency Response. While the UST program used no voluntary standards in rulemaking,

several ASTM standards were distributed to States and EPA Regional Offices with a memo

noting the extent to which the standards were consistent with EPA s goals and guidance.

In addition, EPA serves an important role in encouraging the use of international voluntary

consensus standards in key organizations with which it works, including the Organization for

Economic Cooperation and Development, the United Nations Environmental Program, and the

United Nations Conference on Trade and Development. This encouragement is not only

important to achieving environmental goals but means that U.S. business and industry

stakeholders have a vested interest in, and opportunity to participate in, the international

standards that reflect harmonization among governments as well as industry users.

Inside the Agency, EPA s Voluntary Standards Network, which internally coordinates standards

activities, is serving an expanded role of making standards activities in the Agency more visible

to senior management. This is largely due to three factors: officially designated EPA Standards

Coordinators from each Office and Region; the Administrator s emphasis on seeking

performance-based measures as a basis for regulatory compliance, and the visibility of standards

issues in context of the trade agreements.

Additional specifics on some of these areas are provided below:

Performance-Based Measurement System Initiative

EPA s Administrator Browner announced 2 years ago that EPA would, where possible,

move from prescribed measurement methods to a flexible selection process whereby the

regulated community might adopt alternative methods as long as they could be
6

 The International Organization for Standardization (ISO) is a standards developing body

composed of national standards bodies representatives from around the world, as well as liaison

and nonvoting members from a wide variety of international organizations. The American

National Standards Institute (ANSI) is the official U.S. member.

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demonstrated to meet agreed upon performance objectives. EPA is working with ASTM

Committees through a facilitated, accelerated process to develop voluntary consensus

standards that will meet the needs of the Administration and public confidence in this

important area.

Representatives from EPA s Offices of: Research and Development, Air and Radiation,

Solid Waste, and Enforcement and Compliance Assurance, are working through ASTM

to develop a standard concerning the demonstration of validity of analytical data. The

purpose of this standard is to ensure the scientific and legal defensibility of the

compliance monitoring data gathered by the regulated community. EPA hopes that once

the standard is completed, the Agency will be able to cite it in the implementation of the

Performance-Based Measurement System Initiative.

Child Resistant Packaging (CRP) and Pesticides Registrants

EPA uses ASTM D3475 Standard Classification of Child-Resistant Packages as part of

the Agency s identification of CRP. Additionally, EPA is constantly referring pesticide

registrants to ASTM for standards related to their packaging (e.g., weathering of

packages) as concerns CRP testing.

One area where EPA does not use a possible ISO6 standard is in the area of child-resistant

packaging. EPA and the U.S. Consumer Product Safety Commission (CPSC) both have

regulations internally consistent in the United States. There is no U.S. voluntary standard

that might be applicable as a testing procedure, but there is an ISO standard. EPA, CPSC,

and other U.S. representatives (manufacturers, testing organizations, etc.) to the ISO

technical committee on this matter all agree that the ISO standard does not meet the

stringency required and desired for United States purposes.

Voluntary Standards, Sustainability, Products and Government Procurement

An EPA employee chairs the task group at ASTM, a major SDO that is developing data

collection standards to assess sustainability of building products.

EPA is charged, under Executive Order 13101 (1998 & 1993) with providing guidance to

Federal agencies on Environmentally Preferable Purchasing. By working with the diverse

sectors of the building industry that comprise ASTM s Buildings Performance Committee

to develop voluntary consensus standards on sustainability, EPA hopes to not only

contribute to promoting environmentally preferable purchasing in construction, but also
B-21

encourage improved environmental performance on the part of suppliers of building

products.

One of the tools EPA has developed to assist purchasers in implementing

environmentally preferable purchasing is a database of environmental standards and

environmental attributes. The database, which will be expanded in the next year, includes

product-specific information developed by government programs, both U.S. and

international as well as nongovernmental organizations. The standards included in the

database have been developed through a wide variety of processes, not limited to

voluntary consensus standards.

Office of Air: Voluntary Consensus Standards Save Cost to EPA

EPA s Emission Measurement Center (EMC) within the Office of Air Quality Planning

Standards has interacted closely with ASTM subcommittee D22-03, which is responsible

for developing and approving new emission measurement techniques. An EMC

representative has joined D22-03 and worked closely with its task groups in developing

and modifying ASTM standards such that they can be incorporated by reference  in

applicable Federal regulations. This cooperative effort between EPA and ASTM has had

immediate beneficial results in the recognition of many new emission test methods at

essentially zero cost to EPA.

EMC has several actions ongoing with ASTM. Two that were completed in 1999 are: 

(1) EPA s Performance Standard No.1 (PS-1) was formally revised to include ASTM

D6216-98, which greatly increases the stringency of quality assurance by manufacturers

of Continuous Opacity Monitoring Systems; and (2) ASTM method measure total and

speciated mercury emissions at coal-fired utilities was adopted by EMC as the official

method under a special EPA-industry project involving 84 coal-fired utilities throughout

the nation.

Organization for Economic Cooperation and Development (OECD)

Although the Organization for Cooperation and Development is not, strictly speaking, a

standards developing body under the definition of the OMB Circular A-119, it has a Test

Guidelines Program (TGP) that develops consensus documents to which the United

States as a member of OECD subscribes. The Agency believes participation in the

development of the Test Guidelines (TGs) to be consistent with the intent of the Circular.

The OECD is a formal intergovernmental organization that currently consists of

29 member countries with advanced market economies producing and using over

75 percent of the world s chemicals. The OECD s TGP was established in 1981 with

their publication of 51 consensus TGs for the conduct of a variety of test methods to

assess the characteristics of chemicals (e.g., solubility in water, toxicity to rodents, to fish,
B-22

etc.). The purpose of the OECD s TGs is to help minimize nontariff trade barriers

between member countries, avoid the duplication of testing, and to minimize the use of

animals in testing. There are currently 95 OECD TGs.

The U.S. National Coordinator has a contact list of about 60 groups, organizations, and/or

individuals with expertise who have indicated an interest in providing expert comments

on some or all of the OECD TGs distributed to the United States. This list includes

distributions to expert contacts at several Federal and State agencies, industry

associations, chemical industry and testing laboratories and a variety of expert contacts at

nongovernmental organizations such as academic institutions.

The U.S. comments received on any OECD TG are included in the U.S. responses to the

OECD. The OECD s TGs are consensus documents and the U.S. comments, and those of

all member countries, are considered in developing that consensus. The OECD s TGs are

likely to be among the most widely used to test chemicals in the industrialized world.

Participation in International Standards Development

The Agency actively participates in a number of standards development and revision

committees within ISO. Examples include ISO committees on environmental

management systems, quality systems, and those dealing with air and water quality

testing. In addition, personnel from the Office of Mobile Sources participate in two ISO

technical committees relevant to the Office of Air. In the case of environmental

management systems, the Agency has recently established a policy group to test-out and

coordinate programs and pilot projects that research and evaluate the viability of

ISO 14001 and other standards as the basis for effective environmental management,

including compliance management.

What follows is a table which further explicates the voluntary consensus standards found

impractical in EPA FY 1999 regulations.
TABLE 1

IDENTIFICATION OF SPECIFIC VOLUNTARY CONSENSUS STANDARDS 

& DETERMINATIONS OF IMPRACTICABILITY FOR EACH VCS

IN EPA FY 1999 RULEMAKINGS (BY RULE)

Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

(1) The Pesticide Active Ingredient NESHAP

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition, T limits). It appear

calibration procedures and speci

supporting data. Some of the va

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91 - Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

but lacks quality assurance and q

ASTM 3796-90 (Reapproved 1996) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. However, this method will no

measurements like EPA Method 

temperature control on the filter 

ambient levels). There is no EPA 

to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

Method (ALT) 004, Conditional 

but lacks in detail and quality as

requirements. Similar to ASTM 
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

Method (ALT 004), Conditional 

but lacks in detail and quality as

requirements. Very similar to IS

ASTM E337-84 (Reapproved 1996) - Standard Test

Method for Measuring Humidity with a Psychrometer

(the Measurement of Wet- and Dry-Bulb

Temperatures)

EPA Method 4 This will only cover a small port

for EPA Method 4.

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of

particles Performance characteristics, test methods

and specifications.

EPA Performance Specification 11 -

Particulate Matter Continuous Monitoring

System

This international standard is on

specific basis by direct correlatio

ISO 9096 (which does not produ

measurements like EPA Method 

PM CEMS performance specific

Performance Specification 11, b

RATA procedures. Also, EPA d

performance specification to com

ASME PTC-38-80 R85 or

C00049 - Determination of the concentration of

particulate matter in gas streams

EPA Method 5, 17 Essentially duplicates EPA Meth

flexible. Allows more train conf

ASTM D3685/D3685M-98 - Standard Test method

for sampling and determination of particulate matter in

stack gases

EPA Method 5, 17 Similar to EPA Methods 5 and 1

options beyond that which woul

for EPA Method 5 (example: pa

Alundum thimble probes leak).

ASTM D4536-96 - Particulate (Particulate Matter)

Modified High Volume

EPA Method 5 Basically, duplicate of EPA s Co

(CTM) 003 and has been validat

pressure fabric filters only. This 

alternative.

ASTM D6060-96 - Practice for Sampling of Process

Vents with a Portable Gas Chromatograph

EPA Method 18 This method lacks key quality co

required for Method 18 - Examp

for calibration, details on using o

solid sorbents), and reporting/do
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

PREN 1911-1,2,3 - Stationary Source EmissionsManual Method of Determination of HCl - Part 1: 

Sampling of Gases Ratified European Text - Part 2: 

Gaseous Compounds Absorption Ratified European

Text - Part 3: Absorption Solutions Analysis and

Calculation Ratified European Text

EPA Method 26, 26a Part 3 of this method cannot be c

EPA Method 26 or 26a. The sam

(water) would be expected to cap

gas, if present, without the abilit

two. Methods 26 and 26a use an 

solution to first separate HCl and 

can be selectively absorbed, anal

separately. In addition, the effic

chlorine gas fraction would be e

the absorbing solution changed.

(2) Oil and Natural Gas Production and Natural Gas Transmission and Storage MA

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition, T limits). It appear

calibration procedures and speci

supporting data. Some of the va

adequately addressed. This cann

to EPA Method 2 without suppo

ASTM D3154-91- Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

4, but lacks quality assurance an

requirements.

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. However, this method will no

measurements like EPA Method 

temperature control on the filter 

ambient levels). There is no EP

to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wi

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

(ALT) 004 and Conditional Test 

lacks in detail and quality assura

requirements. Similar to ASTM 
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

(ALT) 004, Conditional Test Me

in detail and quality assurance an

requirements. Very similar to IS

ASTM D6060-96 - Practice for sampling of Process

Vents with a Portable Gas Chromatograph

EPA Method 18 This method lacks key quality co

required for Method 18 - Examp

for calibration, details on using o

solid sorbents), and reporting/do

(3) The Wool Fiberglass Production NESHAP

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition limits, T limits). It 

calibration procedures and speci

supporting data. Some variabili

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91 - Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

4, but lacks in quality assurance 

requirements.

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. However, this method will no

measurements like EPA Method 

temperature control on the filter 

ambient levels). Also, EPA doe

compare this to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

Method (ALT) 004, Conditional 

but lacks in detail and quality as

requirements. Similar to ASTM 
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

(ALT) 004, Conditional Test Me

in detail and quality requirement

10396.

ASTM E337-84 (Reapproved 1996) - Standard Test

Method for Measuring Humidity with a Psychrometer

(the Measurement of Wet- and Dry-Bulb

Temperatures)

EPA Method 4 This will only cover a small port

for EPA Method 4.

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of

particles Performance characteristics, test methods

and specifications.

EPA Performance Specification 11 -

Continuous Monitoring System for

Particulate Matter

This international standard is on

specific basis by direct correlatio

ISO 9096 (which does not produ

measurements like EPA Method 

particulate matter (PM) CEMS p

similar to EPA Performance Spe

contain detailed RATA procedur

a final performance specification 

ASME PTC-38-80 R85 or

C00049 - Determination of the concentration of

particulate matter in gas streams

EPA Method 5, 17 Essentially duplicates Methods 5 

Allows more train configuration

ASTM D3685/D3685M-98 - Standard Test method

for sampling and determination of particulate matter in

stack gases

EPA Method 5, 17 Similar to EPA Methods 5 and 1

options beyond that which woul

for EPA Method 5 (example: pa

Alundum thimble probes leak).

ASTM D4536-96 - Particulate (Particulate Matter)

Modified High Volume

EPA Method 5 Basically, duplicate of Condition

and has been validated for testin

filters only. This is not an EPA 

(4) The Portland Cement MACT

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition, T limits). It appear

calibration procedures and speci

supporting data. Some of the va

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91 - Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

4, but lacks quality assurance an

requirements.
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. This method will not produce 

measurements like EPA Method 

temperature control on the filter 

ambient levels). EPA does not h

this to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

(ALT) 004, Conditional Test Me

in detail and quality assurance an

requirements. Similar to ASTM 

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

(ALT) 004, Conditional Test Me

in detail and quality assurance a

requirements. Very similar to IS

ASTM E337-84 (Reapproved 1996) - Standard Test

Method for Measuring Humidity with a Psychrometer

(the Measurement of Wet- and Dry-Bulb

Temperatures)

EPA Method 4 This will only cover a small port

for EPA Method 4.

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of

particles Performance characteristics, test methods

and specifications.

EPA Performance Specification 11 -

Particulate Matter Continuous Monitoring

System

This international standard is on

specific basis by direct correlatio

ISO 9096 (which does not produ

measurements like EPA Method 

Particulate Matter (PM) CEMS p

similar to EPA Performance Spe

not contain detailed RATA proc

have a final performance specifi

ASME PTC-38-80 R85 or

C00049 - Determination of the concentration of

particulate matter in gas streams

EPA Method 5, 17 Essentially duplicates Methods 5 

Allows more train configuration

ASTM D3685/D3685M-98 - Standard Test method

for sampling and determination of particulate matter in

stack gases

EPA Method 5, 17 Similar to EPA Methods 5 and 1

options beyond that which woul

for EPA Method 5 (example: pa

Alundum thimble probes leak).
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D4536-96 - Particulate (Particulate Matter)

Modified High Volume

EPA Method 5 Basically, duplicate of Condition

and has been validated for testin

filters only. This is not a Metho

CEN EN 1948-1,2,3

(European Committee for Standardization) -

Determination of the mass concentration of PCDD S

/PCDF S - Part 1,2,3

EPA Method 23 Provides sampling options beyon

considered acceptable for EPA M

ASTM(Z6263Z) - Draft Method 320 EPA Method 320 (FTIR) See attached comments provided 

(5) The Phosphoric Acid Phosphate Fertilizer MACT

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition, T limits). It appear

calibration procedures and speci

supporting data. Some of the va

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91 - Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

4, but lacks detailed quality assu

requirements.

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

This method will not produce pa

measurements like EPA Method 

temperature control on the filter 

ambient levels). Also, there is n

this to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method s 3a, 6c

Method (ALT) 004, and Conditi

022, but lacks in detail and quali

control requirements. Similar to 
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

Method (ALT) 004, Conditional 

detail and quality assurance and 

requirements. Very similar to IS

ASTM E337-84 (Reapproved 1996) - Standard Test

Method for Measuring Humidity with a Psychrometer

(the Measurement of Wet- and Dry-Bulb

Temperatures)

EPA Method 4 This will only cover a small port

for EPA Method 4.

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of

particles Performance characteristics, test methods

and specifications.

EPA Performance Specification 11 -

Particulate Matter Continuous Monitoring

System

This international standard is on

specific basis by direct correlatio

ISO 9096 (which does not produ

measurements like EPA Method 

PM CEMS performance specific

Performance Specification (PS) 

detailed RATA procedures. Als

performance specification to com

ASME PTC-38-80 R85 or

C00049 - Determination of the concentration of

particulate matter in gas streams

EPA Method 5, 17 Essentially duplicates Methods 5 

Allows more train configuration

ASTM D3685/D3685M-98 - Standard Test method

for sampling and determination of particulate matter in

stack gases

EPA Method 5, 17 Similar to EPA Methods 5 and 1

options beyond that which woul

for EPA Method 5 (example: pa

Alundum thimble probes leak).

ASTM D4536-96 - Particulate (Particulate Matter)

Modified High Volume

EPA Method 5 Basically, duplicate of Condition

and has been validated for testin

filters only. This is not an EPA 

(6) The Mineral Wool Production NESHAP

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition limits, T limits). It 

calibration procedures and speci

supporting data. Some variabilit

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91 - Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Covers EPA s Part 60 Methods 

lacks in quality assurance and qu
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. However, this method will no

measurements like EPA Method 

temperature control on the filter 

ambient levels). EPA does not h

this to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Methods 3a, 6c, 

Method (ALT) 004, Conditional 

but lacks in detail and quality as

requirements. Similar to ASTM 

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

(ALT) 004, Conditional Test Me

in detail and quality requirement

10396.

ASTM E337-84 (Reapproved 1996) - Standard Test

Method for Measuring Humidity with a Psychrometer

(the Measurement of Wet- and Dry-Bulb

Temperatures)

EPA Method 4 This will only cover a small port

for EPA Method 4.

ISO 10155:1995 - Stationary source emissions. 

Automated monitoring of mass concentration of

particles Performance characteristics, test methods

and specifications.

EPA Performance Specification 11 -

Continuous Monitoring System for

Particulate Matter

This international standard is on

specific basis by direct correlatio

ISO 9096 (which does not produ

measurements like EPA Method 

particulate matter (PM) CEMS p

similar to EPA Performance Spe

not contain detailed RATA proc

have a final performance specifi

ASME PTC-38-80 R85 or

C00049 - Determination of the concentration of

particulate matter in gas streams

EPA Method 5, 17 Essentially duplicates Methods 5 

Allows more train configuration

ASTM D3685/D3685M-98 - Standard Test method

for sampling and determination of particulate matter in

stack gases

EPA Method 5, 17 Similar to EPA Methods 5 and 1

options beyond that which woul

for EPA Method 5 (example: pa

Alundum thimble probes leak).
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

ASTM D4536-96 - Particulate (Particulate Matter)

Modified High Volume

EPA Method 5 Basically, duplicate of Condition

and has been validated for testin

filters only. This is not an EPA 

(7) Polyether Polyols Production NESHAP

ASTM D3464-96 - Standard Test Method Average

Velocity in a Duct Using a Thermal Anemometer

EPA Method 2 There is no EPA Method to com

specifications are not clearly def

composition, T limits). It appear

calibration procedures and speci

supporting data. Some variabilit

adequately addressed. EPA cann

EPA Method 2 without supportin

ASTM D3154-91- Standard Method for Average

Velocity in a Duct (Pitot Tube Method)

EPA Method 1, 2, 2c, 3, 3b, 4 Appears to cover EPA s Part 60 

4, but lacks quality assurance an

requirements.

ASTM 3796-90 (Reapproved 1994) - Standard

Practice for Calibration of Type S Pitot Tubes

EPA Method 2 This is a very good detailed proc

S pitot tubes, but it is not a comp

EPA Method 2.

ISO 9096:1992 - Determination of concentration and

mass flow rate of particulate matter in gas carrying

ducts - Manual gravimetric method.

EPA Method 1, 2, 5 Some portions of this method re

2. This method will not produce 

measurements like EPA Method 

temperature control on the filter 

ambient levels.) There is no EPA 

to.

PTC 19-10-1981 or

ASME C00031 - Part 10 Flue and Exhaust Gas

Analyses

EPA Method 3, 6, 7, 15 Too broad to be useful in regula

EPA Methods 3, 6, 7, and 15 wit

ISO 10396:1993 - Stationary Source Emissions: 

Sampling for the automated determination of gas

concentrations

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

Method (ALT) 004, Conditional 

but lacks in detail and quality as

requirements. Similar to ASTM 

ASTM D5835-95 - Standard practice for sampling

stationary source emissions for automated

determination of gas concentration.

EPA Method 3a, 6c, 7e, 10 Similar to EPA Method 3a, 6c, 7

Method (ALT) 004, Conditional 

but lacks in detail and quality as

requirements. Very similar to IS

ASTM D6060-96 Practice for Sampling of Process

Vents with a Portable Gas Chromatography

EPA Method 18 This method lacks key quality co

required for Method 18 - Examp

for calibration, details on using o

Solid sorbents), and reporting/do
Voluntary Consensus Standard

Similar EPA Standard

Reference Method

EPA Comm

Voluntary Conse

(8) New Nonroad Spark-Ignition Nonhandheld Engines At or Below 19 Kilowatts

ISO 8178 EPA Procedures Outlined in 40 CFR Part 90 Voluntary consensus standard re

reference testing conditions. Sin

these regulations need to be used 

but also for production line testin

audits, and in-use testing, they m

use testing is best done outside t

conditions so as to be representa

EPA has determined that the ISO 

sufficiently broadly usable in the

program, and therefore cannot b

(9) Interim Enhanced Surface Water Treatment

ISO 7027 GLI Method 2, Standard Method 2130B,

EPA Method 180.1

EPA has no data upon which to 

separate 90 degrees scattered or 

measurement evaluations accord

would produce results that are eq

produced by the other methods.

(10) Nonroad Diesel Engines

ISO 8178 EPA Procedures Outlined in 40 CFR Part 89 The Agency has determined that 

impractical because they rely too 

testing conditions. Because the 

regulations need to represent in-

operation in the field, they must 

ambient conditions. EPA has de

procedures are not broadly usab

therefore cannot be adopted by r

* Most voluntary consensus standard searches were conducted through the Enhanced National Standard

(NSSN) Database which is maintained by the American National Standards Institute (ANSI). The vo

standards identified through these searches and via other means were reviewed to determine if they co

EPA s standard reference methods or government-unique standards.

B-35

FEDERAL COMMUNICATIONS COMMISSION (FCC)

The Commission has not used or adopted any government-unique standards in lieu of voluntary

consensus standards since October 1, 1998.

The Commission has not used or adopted any voluntary consensus standards since October 1,

1998.

No voluntary consensus standards have replaced government-unique standards as a result of

Agency review of existing standards since October 1, 1998.

FCC participates in a variety of organizations that develop telecommunications standards. The

actual level of participation with each organization varies depending on the need for Commission

involvement and importance of the work relative to our objectives. The Commission presently

has approximately 50 employees involved in more than 24 standards bodies and approximately

100 subgroups within these bodies. The Commission uses voluntary standards in several

different ways:

- to satisfy industry and user requirements where it appears that mandatory standards are

unnecessary. Examples include telephone industry standards for network protocols and

interfaces, International Special Committee on Radio Interference standards to control

radio emission from automobiles, Telecommunications Industry Association (TIA)

standards for digital cellular radio protocols, and TIA/T1 standards for protocols in the

personal communications service.

- to correct problems that might otherwise require regulation. For example, the

Commission has strongly encouraged compliance with Electronics Industry Association

(EIA) standards on television susceptibility to interference rather than moving swiftly to

mandatory regulations. It has worked with the industry and local governments to develop

measurement standards for testing the signal quality of cable systems, and is working

with TIA to encourage development and voluntary implementation of a standard for

telephone immunity to interference.

- as the basis for mandatory requirements, either by incorporating voluntary standards by

reference, or including the normative portion of the standard in the FCC rules. Examples

include American National Standards Institute (ANSI) measurement procedures for radio

noise emitted by digital devices; ANSI/EIA standards on AM broadcast transmission

specifications; EIA standards for telephone compatibility with hearing aids; International

Telecommunications Union Radiocommunications Standardization Sector

recommendations on digital selective equipment for use in ship and cost stations; EIA
B-36

task force recommendations on standards for displaying closed-captioning information on

television receivers, and an EIA/TIA standard for protection of microwave systems from

interference from personal communications systems.

The Commission continues to increase its use of voluntary standards. In many instances, the

Commission has chosen not to implement regulations (or more detailed regulations) because

adequate voluntary industry standards already exist or are under development. For example,

the regulations for Personal Communications Service do not include transmission protocol

standards because industry has voluntarily developed these standards. In other instances

where the adoption of a standard is, or may be, in the public interest, the Commission has

attempted to use voluntary standards whenever possible. For example, the Commission is

allowing the industry to establish a spectrum etiquette policy for devices operating at

millimeter wavelengths and are working with and looking to industry to develop standards

for the transmission of digital radio. In addition, the Commission regularly works close with

industry through the negotiated rulemaking process to resolve technical compatibility issues.

The Commission recognizes the benefits of using voluntary consensus standards when applicable

and endeavors to comply with the guidance provided in Office of Management and Budget

Circular A-119 and the mandates of Public Law 104-113. The Commission s current standards

Executive is:

Dale N. Hatfield

Chief, Office of Engineering and Technology

Federal Communications Commission

445 12th Street, S.W.

Washington, D.C. 20554

Telephone (202) 418-2470
B-37

FEDERAL EMERGENCY MANAGEMENT ASSOCIATION (FEMA)

As required by Public Law (P.L.) 104-113, identification of all instances when the agency used

government-unique standards in lieu of voluntary consensus standards:

FEMA continues to use Military Standard (MIL-STD) 188.141B for HF radio, although the

agency is working on a voluntary standard for transmitting e-mail via HF radio if landlines

are not available.

Developers of the National Emergency Management Information System used and continue

to use MIL-STD 498, Software Development and Documentation; MIL-STD 490A,

Specification Practices; MIL-STD 1521B, Technical Reviews and Audits for Systems,

Equipment and Computer Programs; and MIL-STD 2168, Defense System Software Quality

Program, et al. The Agency used these standards as part of a large project started in 1995. At

that time, the Agency wanted to use standards with which contractors were familiar. A solid,

proven standard that worked and would keep costs in line.

Number of voluntary consensus standards the agency has used since October 1, 1998, based on

the procedures set forth in sections 11 and 12 of the Circular:

"All desktop computers are configured with the TCP/IP and the IPX and SPX protocols.

"FEMA makes extensive use of Institute of Electrical and Electronics Engineers standards.

"Real audio player is used for voice messages.

"Norton anti-virus and other generally available standards are used extensively.

"Asynchronous transfer mode is being implemented as part of the upgrade for the FEMA

Switched Network.

"Digital Line Graph Level 3 as the standard data model for the distribution and storage of

digital flood insurance rate map products.

"Hypertext Markup Language (HTML) as the standard for FEMA s Web site; discussion is

underway to replace HTML with Extensible Markup Language.

"Multi-purpose Internet Mail Extension is used to encode e-mail attachments. FEMA uses

standard protocols to run the e-mail operations.

"Portable Document Format is used to retrieve and post formatted documents between

differing computing environments.
B-38

"Visio is the Agency s standard for automated visual graphics.

Identification of voluntary standards that have been substituted for government-unique standards

as a result of an agency review under section 15b(7) of the Circular:

Voluntary standards are preferred, but because FEMA is a small agency, no formal review

has been imposed on the program directors.

The number of voluntary consensus standards bodies in which there is agency participation, as

well as the number of agency employees participating:

FEMA participates in the HF industry association working group to resolve HF standards

problems, as well as the HF e-mail working group.

An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The use of consensus standards is official FEMA policy and the mainstay of the information

technology architecture.
B-39

GENERAL SERVICES ADMINISTRATION (GSA)

GSA has 49 employees participating in 79 voluntary consensus standards bodies. The number of

employees increased slightly over the previous year, while the number of standards bodies

decreased as the Agency became more selective in its participation. GSA continues to expand its

emphasis on the procurement of commercial off-the-shelf products and services.

As a result of the review of existing standards, the following voluntary standards have been

substituted for government-unique standards. Acronyms are spelled out following this list.

Voluntary Standard Government Standard *

ANSI B212.15 GGG-D-650

ANSI Z87.1 A-A-1110, A-A-1770 and A-A-1813

ANSI Z89.1 A-A-2269 and A-A-2270

ANSI Z89.2 A-A-2271

ASME A112.18.1M A-A-240

ASTM D98 A-A-169

ASTM D458 A-A-41

ASTM D632 A-A-1545

CGA Std. G-6.2 A-A-2869

FMR 6031 A-A-2079

FMVSS No. 125 A-A-2128

GPA Std. 2140 A-A-2897

NFPA Std. A-A-2156

* Includes Federal specifications, standards, and commercial item descriptions.

Acronyms

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

CGS Compressed Gas Association

FMR Factory Mutual Research

FMVSS Federal Motor Vehicle Safety Standards (National Highway Traffic Safety

 Association)

GPA Gas Processors Association

NFPA National Fire Protection Association
B-40

The Agency has no comments or recommendations for changes concerning Office of

Management and Budget Circular A-119.

No government-unique standards are being used in lieu of existing voluntary standards.
B-41

GOVERNMENT PRINTING OFFICE (GPO)

The GPO utilizes the following internally-developed standards on a regular basis for the

preparation and development of printing and microform contracts. The information contained in

these standards is unique to GPO and cannot be found in any other voluntary consensus

standards.

"Quality Assurance Through Attributes Program for Printing and Binding, GPO

Publication 310.1, Effective May 1979 (Revised April 1996)

"Quality Assurance Through Attributes Program for Microforms, GPO Publication 310.3,

Effective August 31, 1988

"Quality Assurance Through Attributes Program for Composition, GPO Publication 310.4,

December 1985

"GPO Guidelines for Specifying Quality and Determining Compliance of MICR, OCR,

and OMR, Quality Assurance Through Attributes Program, GPO Publication 310.5,

January 1993

GPO has used 469 voluntary consensus standards since October 1, 1998.

GPO has not substituted any voluntary consensus standards for government-unique standards as a

result of an agency review.

The number of standards bodies in which GPO participates:

"American National Standards Institute - one employee

"Association for Information and Image Management - two employees

Office of Management and Budget Circular A-119 is effective in that it advocates use of existing

resources rather than inefficiently re-inventing the wheel. No recommendations for changes.
B-42

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

NASA policy for technical standards is documented in NASA Policy Directive (NPD) 8070.6

(Revised 1998). It reflects the requirements of Public Law (P.L.) 104-113 and Office of

Management and Budget (OMB) Circular A-119. NPD 8070.6 specifically cites the preference

for use of voluntary consensus standards, encourages participation in voluntary consensus

standards development to meet NASA needs, establishes responsibilities for standards

management in NASA, and references OMB Circular A-119 for detailed requirements.

The NASA Chief Engineer is the NASA Standards Executive. Policy level issues are

coordinated through NASA s Engineering Management Council (EMC), an Agency-wide group

of senior management officials from NASA s Engineering and Safety and Mission Assurance

(S&MA) functions. The Chief Engineer has overall responsibility for administration of the

NASA Technical Standards Program. Implementation and management responsibility for the

NASA Technical Standards Program has been assigned to the Marshall Space Flight Center,

which chairs an Agency-wide Engineering Standards Steering Council responsible for

procedures, coordination of internal document development, and adoption of voluntary

consensus standards.

NASA s use of technical standards is for internal engineering and procurement purposes. The

Agency has no regulatory responsibilities and therefore has chosen a categorical or standards

management system approach for reporting, which is an option provided in OMB Circular

A-119. The NASA Technical Standards Management System currently contains listings of

NASA Preferred Technical Standards, lists of NASA participants in voluntary consensus

standards activities, and extensive links to other sources of technical standards. The home

page for the NASA Technical Standards Management System can be found on the Internet at

<http://standards.msfc.nasa.gov>.

"As required by P.L.104-113, identification of all instances when the Agency used

government-unique standards in lieu of voluntary consensus standards (for each instance

include Agency rationale for such use, as well as the specific government-unique standard

used):

Because NASA uses the categorical  method of reporting, use of governmentunique standards is reported in terms of additions to the NASA Technical

Management System, as opposed to tracking use in individual procurement

transactions. During 1999, NASA has developed 11 internal standards, all of which

were either unique to NASA needs or were internal procedures for program

management or for the implementation of standards.
B-43

"The number of voluntary consensus standards the Agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

In 1998, NASA began an intensive effort to identify voluntary consensus standards

currently being used on NASA programs and to review them as candidates for formal

adoption. Since October 1, 1998, NASA has identified an additional 430 voluntary

consensus standards products based on current use by one or more NASA

installations. These are now in the final stages of the review process for formal

adoption by NASA. This will bring the total number of voluntary consensus

standards the Agency has adopted to 1,032. Approximately 74 percent of the

voluntary consensus standards adopted are in the area of materials and processes

specifications. The adoptions were based on staff recommendations, concurrence of

the NASA Engineering Standards Steering Council, and formal approval by the

NASA EMC and the NASA Standards Executive. There are 201 voluntary consensus

standards identified by the Office of Safety and Mission Assurance called out in

existing S&MA documents previously approved through the S&MA process. This

list of standards products is being reviewed for inclusion as NASA Preferred

Technical Standards.

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an Agency review under section 15b(7) of the

Circular:

There is a two-phase effort underway for identification and substitution of

government-unique standards. The first phase involved an extensive review of

Government standards currently in use, including both NASA internal technical

standards and standards of other Government agencies, such as the Department of

Defense. The objective of this review is to identify all Government standards used

across the Agency for inclusion in the NASA Technical Standards Management

System on an interim basis. So far, 190 military specifications and standards have

been identified and are now in the final stages of the review process for NASA

adoption. The second phase is to identify which government-unique technical

standards in the system can be eliminated or replaced with voluntary consensus

standards. There were eight data communications standards that were converted in

1999 from international intergovernmental standards to International Organization for

Standardization standards. The Agency will continue to identify and screen its

internal standards. Completion of this review is a major objective for the Technical

NASA Standards Program during fiscal year (FY) 2000.
B-44

"The number of voluntary consensus standards bodies in which there is Agency

participation, as well as the number of Agency employees participating:

In FY 1999, NASA had 145 employees participating in 45 voluntary consensus

standards developing bodies, both domestic and international. This is approximately

2 percent less than reported in FY 1998, largely due to corrections that deleted the

names of employees who were members of professional societies but not directly

involved in the development of standards. The relative constancy of the number of

participants was remarkable given that the total turnover of participants in the past

year was approximately 43 percent.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

OMB Circular A-119 continues to provide stimulus for NASA's effort to improve its

technical standards management system, enhance the use of voluntary consensus

standards products, and challenge the need for NASA-unique technical standards

requirements. It is an integral part of the NASA Technical Standards Program. It is

an effective guideline to implement the law and NASA has no recommendations for

any changes.
B-45

NATIONAL ARCHIVES AND RECORDS ADMINISTRATION (NARA)

The NARA continues to be active in the area of voluntary standards. Based on the reporting

requirements of Office of Management and Budget (OMB) Circular A-119, NARA submits the

following report:

"As required by Public Law (P.L.) 104-113, identification of all instances when the agency

used government-unique standards in lieu of voluntary consensus standards:

While NARA has adopted many voluntary standards, we are using a governmentunique standard from the U.S. Marshal Service because there is no suitable voluntary

consensus standard to classify and secure government facilities. The U.S. Marshal

Service security guidelines are from the 1995 Vulnerability Assessment of Federal

Facilities and related Interagency Security Committee implementation guidance.

During the reporting period, NARA endorsed the Department of Defense

Standard 5015.2, Design Criteria for Electronic Records Management Software

Applications, for use across the Federal Government as one possible approach to

managing electronic records. There are currently no voluntary consensus standards in

place that address this issue.

"The number of voluntary consensus standards the agency has used since October 1, 1998,

based on the procedures set forth in sections 11 and 12 of the Circular:

During fiscal year 1999, the agency published a proposed rule relating to the

operation of records centers. In this regulation, NARA incorporates, by reference,

22 voluntary consensus standards. This regulation was published as a final rule on

December 2, 1999.

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15b(7) of the

Circular:

No new voluntary consensus standards were adopted for use during the reporting

period.
B-46

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating:

There are a total of eight NARA employees actively involved in a variety of voluntary

consensus standards organizations, committees, and subcommittees, either as official

NARA representatives or alternates. They serve on the following entities:

American Society of Testing and Materials

American National Standards Institute

Association for Information and Image Management

National Fire Protection Association

National Information Standards Organization

Photographic and Imaging Manufacturers Association

Audio Engineering Society

Society of Motion Picture and Television Engineers

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

NARA supports the policy of OMB Circular A-119 and will continue to adopt

voluntary consensus standards in our policies and regulations.
B-47

NATIONAL SCIENCE FOUNDATION (NSF)

The required information as outlined in Office of Management and Budget Circular A-119

follows:

"NSF has not used any government-unique standards in lieu of voluntary consensus

standards during this reporting period.

"The number of voluntary consensus standards the agency has used since October 1, 1998

is zero.

"No voluntary consensus standards that have been substituted for government-unique

standards as a result of agency review under section 15b(7) of the Circular.

"There are three voluntary consensus standards bodies in which there is agency

participation, with three employees participating.

"An evaluation of the effectiveness of the guidelines in section 7 of the proposed revision

of the Circular and recommendations for any changes.

The proposed guidelines allow appropriate agency participation in standards activities. No

changes are recommended.
7SECY-99-029, 

NRC Participation in the Development and Use of Consensus

Standards, January 28, 1999.

8Staff Requirements, SECY-99-029, February 17, 1999.

9Management Directive 6.5, 

NRC Participation in the Development and Use of

Consensus Standards, issued November 1999.

B-48

NUCLEAR REGULATORY COMMISSION (NRC)

The NRC has been an active participant in the development and use of consensus standards since

its establishment in 1975. The Commission s Strategic Assessment and Rebaselining Initiative

in 1996 further increased NRC s focus on the use of standards. For nuclear reactor and nuclear

materials safety, the strategy is to increase the involvement of licensees and others in the NRC

regulatory process consistent with Public Law (P.L.) 104-113, National Technology Transfer

and Advancement Act of 1995. To do this, NRC will continue to encourage industry to develop

codes, standards, and guides that NRC can endorse and the industry can carry out.

In fiscal year (FY) 1999, NRC took several actions to increase the effectiveness and efficiency of

our process for implementing P.L. 104-113 and Office of Management and Budget (OMB)

Circular A-119, Federal Participation in the Development and Use of Voluntary Consensus

Standards and in Conformity Assessment Activities. The NRC staff used information gained

from the stakeholder meeting it held in Chicago in September 1998, to prepare a

Recommendation7

 to the Commission to develop guidance for staff use when participating in the

development and utilization of consensus standards. The Commission supported the staff

Recommendation.8

 In May 1999, the NRC held a follow-up to the Chicago meeting to focus on

communications with standards developing organizations (SDOs). This meeting demonstrated

the value of bringing representatives from different SDOs and the NRC staff together to discuss

the current needs, priorities, and constraints of each organization. Based on the success of this

meeting, future meetings will be held periodically. The next meeting is scheduled for January

2000.

During the period for this annual report, the NRC staff prepared a management directive9 to

provide direction for staff to support the NRC standards strategy. The management directive

defines NRC organizational responsibilities for standards activities and provides direction for

staff participation in the development and use of consensus standards. Specifically, the

management directive provides direction for identifying and prioritizing needed new and revised

technical standards, selecting and nominating staff as authorized agency representatives on SDO

committees, and coordinating standards activities with SDOs and other stakeholders. It provides

direction for identifying and prioritizing standards for timely endorsement, annual reporting, 
10NRC regulatory guides provide methods acceptable to the NRC staff for meeting NRC

regulations.

11NUREG-1556, which provides consolidated guidance for material licensees.

12See Footnote 10.

B-49

taking exception to using a consensus standard, and monitoring and assessing the NRC standards

program. The management directive requires periodic training of staff involved with standards

activities to provide updates on Federal requirements for standards development and to discuss

lessons learned.

The NRC response to the reporting provisions of OMB Circular A-119 is as follows:

"Identification of all instances when the agency used government-unique standards in lieu

of voluntary consensus standards (for each instance include agency rationale for such use,

as well as the specific government-unique standard used):

No government-unique standards were used by NRC in lieu of existing voluntary

consensus standards.

"The number of voluntary standards the agency has used since October 1, 1998, based on

the procedures set forth in sections 11 and 12 of the Circular:

During this reporting period, seven consensus standards were incorporated by

reference into NRC regulations. Six American Society of Mechanical Engineers

(ASME) standards were incorporated by reference into 10 CFR 50.55a, Codes and

Standards (see table below for a list of the standards). During proposed rulemaking,

the proposed uses of the ASME standards were identified and, in some instances,

NRC defined exceptions or supplemental requirements. The public comment period

provided the opportunity for stakeholders to comment, which resulted in a revision to

some of the NRC defined exceptions and supplemental requirements. In all instances,

the six consensus standards provide the basis for the NRC regulation. In addition, one

Institute of Electrical and Electronics Engineers standard was incorporated by

reference into 10 CFR 50.55a(h), Protection Systems, to supplement the existing

reference (see table).

The NRC also endorsed 30 standards in three final regulatory guides10 and eight

standards in one final NUREG11 (see table for identification of these standards with

the specific method of endorsement).

Final direction12 to address rulemaking (section 11 of the Circular) and procurement

(section 12) activities was developed during this reporting period. Proposed
B-50

rulemakings that have incorporated previous interim guidance to implement

section 11 procedures have not completed final rulemaking.

"Identification of voluntary consensus standards that have been substituted for

government-unique standards as a result of an agency review under section 15(b)(7) of

the Circular:

Generic Letter 90-05, Guidance for Performing Temporary Non-Code Repair of

ASME Code Class 1, 2, and 3 Piping, December 1994, provides guidance that NRC

staff consider in evaluating relief requests submitted by licensees for temporary

non-Code repairs of Code Class 1, 2, and 3 piping. ASME Section XI Code Cases

N-513, Evaluation Criteria for Temporary Acceptance of Flaws in Class 3 Piping, 

and N-523-1, Mechanical Clamping Devises for Class 2 and 3 Piping, have been

incorporated by reference into 10 CFR 50.55a to allow licensees to substitute

applicable related provisions for temporary non-Code repairs in these Code cases for

the guidance in Generic Letter 90-05.

"The number of voluntary consensus standards bodies in which there is agency

participation, as well as the number of agency employees participating.:

During FY 1999, 141 NRC staff participated on 18 SDOs on a total of 267 standards

writing, consensus, and board-level committees.

"An evaluation of the effectiveness of Circular A-119 policy and recommendations for any

changes:

The policy guidelines provided in OMB Circular A-119 for participating in voluntary

consensus standards bodies and using voluntary consensus standards are generally

consistent with longstanding NRC practices. The staff believes that these guidelines

provide appropriate direction and encouragement for Federal agencies to develop

internal agency-wide guidelines to implement P.L. 104-113 and OMB

Circular A-119. These guidelines also provide sufficient and reasonable flexibility

for each agency to make an independent case-by-case determination as to the usability

of a particular standard within that agency s scope and responsibility.
STANDARDS ENDORSED BY NRC

OCTOBER 1, 1998 - SEPTEMBER 30, 1999

SDO

1

Standard

Identifier Year Title

ASME Boiler &

Pressure

Vessel Code

Section III

1992, 1995

Editions; 1989 -

1996 annual

addenda

Rule for Construction of Nuclear Power Plant Components 

ASME Boiler &

Pressure

Vessel Code

Section XI

1992, 1995

Editions; 1989 -

1996 annual

addenda

Rules for Inservice Inspection of Nuclear Power Plant Components 

ASME O&M Code 1995 Edition with

1996 Addenda

Operation and Maintenance of Nuclear Power Plants 

ASME Code Case

N-513

1996 Evaluation Criteria for Temporary Acceptance of Flaws in Class 3 Piping 

ASME Code Case

N-523-1

1996 Mechanical Clamping Devices for Class 2 and 3 Piping 

ASME Code Case

OMN-1

1996 Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operat

Valve Assemblies in Light-Water-Reactor Power Plants

IEEE 603 1991 Criteria for Safety Systems for Nuclear Power Generating Stations 

ASME N-60-5 1994 Material for Core Support Structures (Section III, Division 1) 

ASME Code Case

N-62-7

1994 Internal and External Valve Items, Class 1, 2, and 3 (Section III, Division 1) 

ASME Code Case

N-71-16

1993 Additional Materials for Subsection NF, Class 1, 2, 3 and MC Component Supports

Fabricated by Welding (Section III, Division 1)

ASME Code Case 

N-122-2

1994 Procedure for Evaluation of the Design of Rectangular Cross Section Attachments on C

1 Piping (Section III, Division 1)

ASME Code Case

N-249-13

1994 Additional Material for Subsection NF, Classes 1, 2, 3 and MC Component Supports

Fabricated Without Welding (Section III, Division 1) 

ASME Code Case

N-318-5

1994 Procedure for Evaluation of the Design of Rectangular Cross-Section Attachments on C

2 or 3 Piping (Section III, Division 1)

ASME Code Case

N-389-1

1993 Alternative Rules for Repairs, Replacements, or Modifications (Section XI, Division 1) 
SDO

1

Standard

Identifier Year Title

ASME Code Case

N-392-2

1992 Procedure for Evaluation of the Design of Hollow Circular Cross-Section Welded

Attachments on Classes 2 and 3 Piping (Section III, Division 1) 

ASME Code Case

N-408-3

1993 Alternative Rules for Examination of Class 2 Piping (Section XI, Division 1) 

ASME Code Case

N-409-3

1993 Procedure and Personnel Qualification Requirements for Ultrasonic Detection and Sizin

Flaws in Piping Welds (Section XI, Division 1)

ASME Code Case

N-416-1

1994 Alternative Pressure Test Requirements for Welded Repairs or Installation of Replacem

Items by Welding, Class 1, 2, and 3 (Section XI, Division 1)

ASME Code Case

N-441-1

1992 Use of 20Cr-18Ni-6Mo (Alloy UNS S31254) Fittings, Class 2 and 3 Construction (Sect

III, Division 1)

ASME Code Case

N-474-2

1993 Design Stress Intensities and Yield Strength Values for UNS N06690 With a Minimum

Specified Yield Strength of 35 ksi, Class 1 Components (Section III, Division 1)

ASME Code Case

N-492-1

1994 Grade 9 Titanium Alloy, Class 1, 2, and 3 (Section III, Division 1) 

ASME Code Case

N-497-1

1993 Use of Fe-Ni-Cr-Mo-N (CN-3MN) Cast Materials, Class 2 and 3 Construction (Section 

Division 1)

ASME N-505 1992 Alternative Rules for the Examination of Butt Welds Used as Closure Welds for Electri

Penetration Assemblies in Containment Structures (Section III, Division 1)

ASME N-509 1992 Alternative Rules for the Selection and Examination of Class 1, 2, and 3 Integrally Wel

Attachments (Section XI, Division 1)

ASME N-510 1993 Borated Stainless Steel for Class CS Core Support Structures and Class 1 Components

(Section III, Division 1)

ASME N-511 1993 Design Temperature for Atmospheric and 0 - 15 PSI Storage Tanks (Section III, Divisio

ASME N-512 1993 Assessment of Reactor Vessels With Low Upper Shelf Charpy Impact Energy Levels 

ASME N-514 1993 Low Temperature Overpressure Protection (Section XI, Division 1) 

ASME N-515 1993 Class 1 Mechanical Joint Pressure Test (Section XI, Division 1) 

ASME N-516 1993 Underwater Welding (Section XI, Division 1) 

ASME N-520 1993 Alternative Rules for Renewal of N-Type Certificates for Plants Not in Active Construc

(Section III, Division 1)

ASME N-521 1993 Alternative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, Inside Radius

Sections, and Nozzle-to-Safe End Welds of a Pressurized Water Reactor (PWR) Vessel

(Section XI, Division 1)

ASME N-522 1993 Pressure Testing of Containment Penetration Piping (Section XI, Division 1) 
SDO

1

Standard

Identifier Year Title

ASME N-524 1993 Alternative Examination Requirements for Longitudinal Welds in Class 1 and 2 Piping

(Section XI, Division 1)

ASME N-525 1993 Design Stress Intensities and Yield Strength Values for UNS N06690 with a Minimum

Specified Yield Strength of 30 ksi, Class 1 Components (Section III, Division 1)

ASME N-537 1995 Location of Ultrasonic Depth-Sizing Flaws (Section XI, Division 1) 

ASME N-541 1995 Alternative Requirements for Performance Demonstration in Accordance with Appendi

VIII, Supplements 4 and 6 (Section XI, Division 1)

HPS N13.30 1996 Performance Criteria for Radiobioassay 

IAEA Safety 

Series 1

1973 Radionuclides Classified According to Relative Toxicity (Excerpted from IAEA Safety

Standard Safe Handling of Radionuclides )

1 SDO: Standards Developing Organization

ASME: American Society of Mechanical Engineers

HPS: Health Physics Society

IEEE: Institute of Electrical and Electronics Engineers

IAEA: International Atomic Energy Agency

2

10 CFR 50.55a, Codes and Standards, September 1999

10 CFR 50.55a(h), Protection Systems, January 1999

R.G. 1.84: Regulatory Guide 1.84, Design and Fabrication Code Case Acceptability, ASM

Division 1, Revision 31, May 1999

R.G. 1.85: Regulatory Guide 1.85, Materials Code Case Acceptability, ASME Section X

Revision 31, May 1999

R.G. 1.147: Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME 

Division 1, Revision 12, May 1999

NUREG-1556: Consolidated Guidance About Materials Licensees (Program-specific guidance 

Volume 11, April 1999

C-1

Appendix C:

Charter of the

Interagency Committee

on

Standards Policy (ICSP)
C-2

DEPARTMENT OF COMMERCE

CHARTER

OF THE

INTERAGENCY COMMITTEE ON STANDARDS POLICY

Establishment

1. The Interagency Committee on Standards Policy (herein after referred to as the Committee) is

established to advise the Secretary of Commerce and the heads of other Federal agencies in

matters relating to standards policy.

2. The Committee fulfills the mandates set out in paragraph 8.a.2 of the Office of Management

and Budget (OMB) Circular No. A-119, "Federal Participation in the Development and Use

of Voluntary Standards," in its revision of October 20, 1993.

3. The Committee reports to the Secretary of Commerce through the Director of the National

Institute of Standards and Technology.

Purpose

The purpose of the Committee is to ensure effective participation by the Federal Government in

domestic and international standards activities and to promote the adherence to uniform policies

by Federal agencies in the development and use of standards. Well-considered Federal policies

reflecting the public interest can expedite the development and adoption of standards that

stimulate competition, promote innovation, and protect the public safety and welfare. The

establishment and application of appropriate standards for the characteristics or performance of

goods, processes, and services can contribute significantly to national and international

prosperity, economic growth, and public health and safety. The establishment of such standards

can also further national goals for environmentally sound and energy efficient materials,

products, systems, services, or practices. Heightened national and international awareness of the

importance of standards activities, as reflected by enactment of the National Technology Transfer

and Advancement Act of 1995 (P.L. 104-113, signed into law March 7, 1996), and

recommendations presented in the National Research Council s report "Standards, Conformity

Assessment, and Trade into the 21st Century" (National Academy Press, 1995) call for the

Committee to intensify its efforts to identify the broad roles and appropriate interactions of

agencies in exercising the Government's authority.
C-3

Objective

The objective of the Committee shall be to promote effective and consistent standards policies in

furtherance of U.S. domestic and foreign goals and, to this end, to foster cooperative

participation by the Federal Government and U.S. industry and other private organizations in

standards activities, including the related activities of product testing, quality system registration,

certification, and accreditation programs.

Functions

1. As appropriate, the Committee shall gather, analyze, and maintain current information about

standards, product testing, quality system registration, accreditation and certification, and

related regulations, rules, policies, and activities:

a. conducted within or established by Federal agencies;

b. conducted by private domestic and foreign national standards bodies and by regional and

international private and intergovernmental organizations engaged in such programs; and

c. pertaining to the relationships among agencies of the Federal Government with industry

and the various national, regional, and international organizations engaged in such

programs.

2. On the basis of such information and when appropriate with respect to the activities named in

paragraph 1 above, the Committee shall make recommendations to the Secretary of

Commerce to:

a. strengthen coordination of the standards-related policies and activities among the Federal

agencies;

b. improve the efficiency within the Federal Government of standardization efforts with the

U.S. private sector, as well as with regional and international organizations, both private

and governmental;

c. promote standards-related policies, including directory of personnel participating in

standards activities, within the Federal Government consistent with statutory obligations

in regard to interactions with non-Federal Government organizations;

d. ensure effective representation of the Federal Government at significant regional and

international standards-related meetings and conferences;

e. promote the use of internationally acceptable standards and related activities with a view

to increasing trade and economic integration and development;

f. monitor U.S. technical obligations as a signatory to the World Trade Organization, the

U.S.-Canada Free Trade Agreement, the North American Free Trade Agreement, and

other treaties encompassing standards-related trade issues;

g. encourage the development of agency strategic plans for managing and monitoring use of

voluntary standards and participation in standards-related activities;
C-4

h. promote the use of standards that serve national goals related to increased use of the

metric system of measurement and environmentally sound and energy efficient materials,

products, systems, services, and practices; and

i. assess and improve the adequacy of such agency plans and activities.

Membership

1. Together with the Department of Commerce, the following agencies constitute the

membership of the Committee:

Department of Agriculture

Department of Defense

Department of Education

Department of Energy

Department of Health and Human Services

Department of Housing and Urban Development

Department of the Interior

Department of Justice

Department of Labor

Department of State

Department of Transportation

Department of the Treasury

Department of Veterans Affairs

Office of Consumer Affairs

Consumer Product Safety Commission

Environmental Protection Agency

Federal Communications Commission

Federal Emergency Management Agency

Federal Trade Commission

General Services Administration

International Trade Commission

Office of Management and Budget

National Aeronautics and Space Administration

National Archives and Records Administration

National Communications Systems (Dept. of Defense) - (nonvoting member)

National Science Foundation

Nuclear Regulatory Commission

U.S. Agency for International Development

U.S. Government Printing Office - (legislative liaison - nonvoting member)

U.S. Postal Service

Office of the U.S. Trade Representative
C-5

The head of each member agency shall ensure representation by a responsible high level

policy official (Senior Executive Service or higher) who serves as the agency representative

on the Committee. Such agency representative shall also serve as the "Standards Executive"

as defined in section 8.b.2 of OMB Circular No. A-119. Appointments to the Committee

shall be for an indefinite term.

2. Agency representatives may designate alternates of equivalent senior status to serve in their

absence.

3. Experts from organizations within the member agency may be designated by agency

representatives to serve on task groups established by the Committee.

4. Other Federal agencies may become members of the Committee upon application to or

invitation by the Secretary of Commerce.

Administrative Provisions

1. The Director of the National Institute of Standards and Technology (NIST) or the Director's

designee shall chair the Committee.

2. NIST shall provide administrative arrangements for the Committee including secretarial

services, calling of meetings, arranging for a meeting place, and preparation of an agenda,

discussion material, and reports.

3. The Committee shall meet at least three times each year. Other meetings may be called at the

discretion of the Chair or at the written request of five (5) members of the Committee.

4. The Committee may establish task groups as appropriate.

5. Attendance at Committee meetings by at least one-half of the designated members of the

Committee shall constitute a quorum. Decisions internal to the Committee's operations, such

as formation of a task group, shall be made by a majority of those present and voting. Voting

on Committee business and proposals shall be limited to designated agency members. 

Decisions concerning Committee recommendations to the Secretary of Commerce on

governmental policy or other matters set out in paragraph two of the section entitled

"Functions" shall require ratification by two-thirds of the members present and voting. 

Dissenting positions of the decision may be made a matter of record. The Chair shall not

vote except in the case of a tie vote.

6. The annual cost of operating the Committee is estimated at $31,000 (with overhead) which

includes 0.20 staff year for staff support.
C-6

7. The Committee shall submit an annual report to the Secretary of Commerce so that the

Secretary may satisfy the reporting requirements set forth in OMB Circular No. A-119, as

applicable to the Secretary, and in P.L. 104-113, as applicable to the head of each agency. 

Each such report shall also summarize the Committee's activity during the period covered and

shall include a listing of all recommendations formulated by the Committee during that

period.

Duration

The need and mission of the Committee shall be reexamined three years after the date of this

Charter to determine the need for the Committee's continuation.

/signed/

Secretary of Commerce

Dated: October 29, 1997
D-1

Appendix D:

Membership of the

Interagency Committee on

Standards Policy (ICSP)

------

Fiscal Year 1999
D-2

AGENCY MEMBER REPRESENTATIVE

Agency for International Development, U.S. (USAID) Ms. Kathleen O'Hara

Acting Deputy Director, Office of Procurement

U. S. Agency for International Development

Ronald Reagan Building

Washington, DC 20523-7804

Phone: 202-712-5040

Fax: 202-216-3136

Email: kohara@usaid.gov

Agriculture, Department of (USDA) Mr. Joseph Leo*

Chief Information Officer

Department of Agriculture

Room 416-W

Jamie L. Whitten Federal Building

1400 Independence Avenue, SW

Washington, DC 20250-7603

Phone: 202-720-8833

Fax: 202-720-1031

Email: joe.leo@usda.gov

*for the FY 1999 reporting period--Anne F. Thomson Reed

Commerce, Department of (DOC) Dr. Belinda L. Collins

Director, Office of Standards Services

Department of Commerce

National Institute of Standards and Technology

100 Bureau Drive, Stop 2100

Gaithersburg, MD 20899-2100

Phone: 301-975-4000

Fax: 301-963-2871

Email: belinda.collins@nist.gov

Consumer Product Safety Commission (CPSC) Mr. Colin B. Church

Voluntary Stnds & Int l Activities Coordinator

Consumer Product Safety Commission

4340 East-West Highway

Room 604-C

Bethesda, MD 20207

Phone: 301-504-0554, x-2229

Fax: 301-504-0407

Email: cchurch@cpsc.gov

Alternate: Ms. Jacquie Elder

Deputy Assistant Executive Director

Consumer Product Safety Commission

4340 East-West Highway

Room 702

Bethesda, MD 20207

Phone: 301-504-0554, x-2254

Fax: 301-504-0407

Email: jelder@cpsc.gov

Defense, Department of (DOD) Mr. Gregory E. Saunders

Director, Defense Standardization Program Office

Department of Defense

ATTN: DLSC-LM

8725 John J. Kingman Road, Suite 4235

Fort Belvoir, VA 22060-6221

Phone: 703-767-6880

Fax: 703-767-6876

Email: gregory_saunders@hq.dla.mil

Alternate: Ms. Trudie Williams

Defense Standardization Program Office
D-3

Department of Defense

ATTN: DLSC-LM

8725 John J. Kingman Road, Suite 4235

Fort Belvoir, VA 22060-6221

Phone: 703-767-6875

Fax: 703-767-6876

Email: trudie_williams@hq.dla.mil

Education, Department of (DOEd) Mr. Gerald Malitz

National Center for Education Statistics

Department of Education

555 New Jersey Avenue, NW

Washington, DC 20208

Phone: 202-219-1364

Fax: 202-219-1728

Email: gerald_malitz@Ed.gov

Energy, Department of (DOE) Mr. Richard L. Black

Director, Office of Nuclear Safety Policy and

 Standards (EH-31)

Department of Energy

Room A-430, GTN

Washington, DC 20854

Phone: 301-903-3465

Fax: 301-903-6172

Email: richard.black@eh.doe.gov

Alternate: Mr. Richard Serbu

Manager, DOE Technical Standards Program (EH-31)

Department of Energy

19901 Germantown Road

Germantown, MD 20874-1290

Phone: 301-903-2856

Fax: 301-903-6172

Email: richard.serbu@eh.doe.gov

Environmental Protection Agency (EPA) Ms. Mary McKiel

Director, EPA Standards Program

Environmental Protection Agency

Office of Prevention, Pesticides & Toxic Substances

401 M Street, SW, MC 7101

Washington, DC 20460

Phone: 202-260-3584

Fax: 202-260-6906

Email: mckiel.mary@epa.gov

Alternate: Mr. Craig Annear

Office of General Counsel (232A)

Environmental Protection Agency

401 M Street, SW

Washington, DC 20460

Phone: 202-564-5538

Fax: 202-564-5541

Email: annear.craig@epa.gov
D-4

Federal Communications Commission (FCC) Mr. Julius P. Knapp

Chief, Office of Engineering and Technology

Federal Communications Commission

1919 M Street, NW

Mail Stop Code 1300

Washington, DC 20554

Phone: 202-418-2468

Fax: 202-418-1944

Email: jknapp@fcc.gov

Federal Emergency Management Agency (FEMA) Dr. Edward Kernan*

Director, Management Division

Information Technology Services Directorate

Federal Emergency Management Agency

500 C Street SW, Room 251 FCP

Washington, DC 20472

Phone: 202-646-2986

Fax: 202-646-3074

Email: edward.kernan@fema.gov

*for the FY 1999 reporting period--Rosetta Bowsky

Federal Trade Commission (FTC) Mr. Alain Sheer

Director of Marketing Practices

Federal Trade Commission

Bureau of Consumer Protection

6th and Pennsylvania Avenue, NW

Room 4200

Washington, DC 20580

Phone: 202-326-3321

Fax: 202-326-3392

Email: asheer@ftc.gov

General Services Administration (GSA) Mr. William N. Gormley

Assistant Commissioner

Office of Acquisition, Federal Supply Service (FC)

General Services Administration

1941 Jefferson Davis Highway

Room 710

Arlington, VA 22202

Phone: 703-305-7901

Fax: 703-305-6851

Email: william.gormley@gsa.gov

Alternate: Mr. Charles P. Gallagher

Director, Environmental & Engineering Policy (FCOE)

General Services Administration

1941 Jefferson Davis Highway

Room 703

Arlington, VA 22202

Phone: 703-305-6930

Fax: 703-305-6731

Email: charles.gallagher@gsa.gov

Government Printing Office, U.S. (GPO) Mr. Robert H. Thomas

Manager, Quality Control and Technical Department

U. S. Government Printing Office

North Capital & H Street

Washington, DC 20401

Phone: 202-512-0766

Fax: 202-512-0015

Email: rthomas@gpo.gov
D-5

Health and Human Services, Department of (HHS) Ms. Janet J. Showalter*

Director, International Scientific Activities

 and Standards Staff

Department of Health and Human Services

Food and Drug Administration, HHS

5600 Fishers Lane, Room 15-22, HFY-20

Rockville, MD 20857

Phone: 301-827-0865

Fax: 301-443-0232

Email: jshowalt@oc.fda.gov

*for the FY 1999 reporting period--Linda R. Horton

Alternate: Dr. John P. Lucas*

Associate Director for Standards

Office of International Programs

Department of Health and Human Services

Food and Drug Administration, HHS

5600 Fishers Lane, Room 15A16, HFG-1

Rockville, MD 20857

Phone: 301-827-0917

Fax: 301-443-0235

Email: jlucas@oc.fda.gov

*for the FY 1999 reporting period--Kathleen Hastings

Housing and Urban Development, Department of (HUD) Ms. Ayse Can Talen*

Deputy Assistant Secretary for Research,

 Evaluation, and Monitoring

Office of Policy Development & Research

Department of Housing and Urban Development

451 7th Street, SW, Suite 8146

Washington, DC 20410

Phone: 202-708-4230, x-3666

Fax: 202-708-3141

Email: Ayse_Can_Talen@hud.gov

*for the FY 1999 reporting period--Xavier de Souza Briggs

Alternate: Mr. Roy Mullinax*

Departmental Policy & Oversight Support

Department of Housing and Urban Development

451 7th Street, SW, Suite 3182

Washington, DC 20410-3600

Phone: 202-708-0614, x-6075

Fax: 202-708-1559

Email: Roy_P._Mullinax@hud.gov

*for the FY 1999 reporting period--Warren Friedman

Interior, Department of the (DOI) Mr. David Shearer

Chief, IRM Program Policy Review, and

 Standards Division

Department of the Interior

1849 C Street, NW, Mail Stop-5312

Washington, DC 20240

Phone: 202-208-4281

Fax: 202-501-2360

Email: david_shearer@ios.doi.gov

International Trade Commission (ITC) Mr. Stephen A. McLaughlin

Director, Office of Administration

International Trade Commission

Room 414

500 E Street, SW

Washington, DC 20436

Phone: 202-205-3131

Fax: 202-205-2034
D-6

Justice, Department of (DOJ) Dr. M. Wayne Shiveley

Information Management and Security Staff

Department of Justice

1001 G Street, NW, Suite 850

Washington, DC 20530

Phone: 202-305-4107

Fax: 202-616-5455

Email: wayne.m.shiveley@usdoj.gov

Labor, Department of (DOL) Mr. Roland G. Droitsch

Deputy Assistant Secretary for Policy

Department of Labor

Room S 2312

200 Constitution Avenue, NW

Washington, DC 20210

Phone: 202-219-9058

Fax: 202-219-9216

Email: droitsch_roland@dol.gov

National Aeronautics and Space Administration (NASA) Mr. W. Brian Keegan*

National Aeronautics and Space Administration

Mail Code AE

NASA Headquarters

300 E Street, SW

Washington, DC 20546-0001

Phone: 202-358-1823

Fax: 202-358-3296

Email: brian.keegan@hq.nasa.gov

*for the FY 1999 reporting period--Daniel R. Mulville

Alternate: Mr. Richard H. Weinstein

National Aeronautics and Space Administration

Mail Code AE

NASA Headquarters

300 E Street, SW

Washington, DC 20546-0001

Phone: 202-358-0538

Fax: 202-358-3296

Email: richard.weinstein@hq.nasa.gov

National Archives and Records Administration (NARA) Ms. Mary Ann Hadyka

National Archives and Records Administration

Policy and Communication Staff

Suite 4100

8601 Adelphi Road

College Park, MD 20740-6001

Phone: 301-713-7360, x-222

Fax: 301-713-7270

Email: maryann.hadyka@arch2.nara.gov

National Communications System (NCS) Mr. Dale Barr

Chief, Technology and Standards Division

National Communications System

Office of the Manager

701 South Court House Road

Arlington, VA 22204-2198

Phone: 703-607-6200

Fax: 703-607-4830

Email: barrd@ncs.gov
D-7

National Science Foundation (NSF) Dr. William S. Butcher

Senior Engineering Advisor

Engineering Education and Centers Division

National Science Foundation

4201 Wilson Boulevard, Suite 585

Arlington, VA 22230

Phone: 703-306-1380

Fax: 703-306-0289

Email: wbutcher@nsf.gov

Nuclear Regulatory Commission (NRC) Mr. Michael E. Mayfield*

Acting Director, Engineering Technology

Nuclear Regulatory Commission

Office of Nuclear Regulatory Research

Mail Stop T-10D20

Washington, DC 20555-0001

Phone: 301-415-5678

Fax: 301-415-5074

Email: mem2@nrc.gov

*for the FY 1999 reporting period--John W. Craig &

Alternate: Gilbert C. Millman

Office of Management and Budget (OMB) Liaison Mr. Ed Springer*

Office of Management and Budget

Office of Information and Regulatory Affairs

NEOB, Room 10236

Washington, DC 20503

Phone: 202-395-3562

Fax: 202-395-5167

Email: edward_springer@omb.eop.gov

*for the FY 1999 reporting period--Virginia A. Huth

Postal Service, U.S. (USPS) Mr. Charles W. Newman*

Manager, Configuration Management

U.S. Postal Service

Engineering Research and Development

Merrifield, VA 22082-8149

Phone: 703-280-7649

Fax: 703-280-8414

Email: cnewman@email.usps.gov

*for the FY 1999 reporting period--Myles A. Jackson

Alternate: Mr. Bill Griggs*

Acting Manager, Configuration Management

U.S. Postal Service

Engineering Research and Development

Merrifield, VA 22082-8149

Phone: 703-280-7276

Fax: 703-280-8414

Email: wgriggs@email.usps.gov

*no Alternate for the FY 1999 reporting period

State, Department of (STATE) Ms. Marian Gordon

Director for Telecommunications and

 Information Standards

Department of State

2201 C Street, NW, Room 2529

Washington, DC 20520

Phone: 202-647-0197

Fax: 202-647-7407

Email: gordonmr@state.gov
D-8

Alternate: Mr. Julian Minard*

Department of State

EB/CIP/MA

2201 C Street, NW, Room 2529

Washington, DC 20520

Phone: 202-647-0965

Fax: 202-647-7407

Email: minardje@state.gov

*no Alternate for the FY 1999 reporting period

Transportation, Department of (DOT) Ms. Kate Hallahan*

Office of the Deputy Secretary

Department of Transportation

400 Seventh Street, SW

Suite 10200

Washington, DC 20590

Phone: 202-366-2222

Fax: 202-366-7202

Email: kate.hallahan@ost.dot.gov

*for the FY 1999 reporting period--Julie Abraham

Alternate: Ms. Julie Abraham

Director of International Harmonization

National Highway Traffic Safety Administration

Department of Transportation

400 Seventh Street, SW

Suite 5208

Washington, DC 20590

Phone: 202-366-2114

Fax: 202-366-2559

Email: jabraham@nhtsa.dot.gov

Treasury, Department of (Treasury) Mr. James J. Flyzik

Deputy Assistant Secretary (Information

 Systems) & Chief Information Officer

Department of Treasury

1500 Pennsylvania Avenue, NW

Room 2464

Washington, DC 20220

Phone: 202-622-1200

Fax: 202-622-2224

Email: jim.flyzik@cio.treas.gov

Meeting Correspondence to: Mrs. Helen W. Whatley

Office of Information Resources Management

Department of Treasury

1425 New York Avenue, NW

Washington, DC 20220

Phone: 202-622-1541

Fax: 202-622-1595

Email: helen.whatley@cio.treas.gov

U.S. Trade Representative (USTR) Ms. Suzanne Troje

Director, Technical Trade Barriers

U.S. Trade Representative

600 17th Street, N.W.

Washington, DC 20508

Phone: 202-395-9444

Fax: 202-395-5674

Email: stroje@ustr.gov
D-9

Veterans Affairs, Department of (VA) Mr. Gary J. Krump

Deputy Assistant Secretary for Acquisition &

 Material Management (90)

Department of Veterans Affairs

810 Vermont Avenue, NW

Washington, DC 20420

Phone: 202-273-6029

Fax: 202-273-6163

Email: krugar@mail.va.gov

Alternate: Mr. Pierre Lundy

Department of Veterans Affairs

810 Vermont Avenue, NW

Washington, DC 20420

Phone: 202-273-6102

Fax: 202-273-6236

Email: pierre.lundy@mail.va.gov

National Institute of Standards and Technology (NIST) Ms. Maureen Breitenberg

National Institute of Standards and Technology

100 Bureau Drive, Stop 2100

Gaithersburg, MD 20899-2100

Phone: 301-975-4031

Fax: 301-963-2871

Email: maureen.breitenberg@nist.gov

National Institute of Standards and Technology (NIST) Mr. David Alderman

National Institute of Standards and Technology

100 Bureau Drive, Stop 2140

Gaithersburg, MD 20899-2140

Phone: 301-975-4171

Fax: 301-926-2884

Email: david.alderman@nist.gov

National Institute of Standards and Technology (NIST) Mr. Patrick Cooke

National Institute of Standards and Technology

100 Bureau Drive, Stop 2150

Gaithersburg, MD 20899-2150

Phone: 301-975-4033

Fax: 301-926-1559

Email: patrick.cooke@nist.gov

National Institute of Standards and Technology (NIST) Ms. Krista Johnsen-Leuteritz

National Institute of Standards and Technology

100 Bureau Drive, Stop 2100

Gaithersburg, MD 20899-2100

Phone: 301-975-5104

Fax: 301-963-2871

Email: krista.leuteritz@nist.gov

National Institute of Standards and Technology (NIST) Ms. JoAnne Overman

National Institute of Standards and Technology

100 Bureau Drive, Stop 2150

Gaithersburg, MD 20899-2150

Phone: 301-975-4037

Fax: 301-926-1559

Email: joanne.overman@nist.gov

E-1

APPENDIX E:

LIST OF NIST PUBLICATIONS

RELATED TO P. L. 104-113
E-2

STANDARDS AND CONFORMITY ASSESSMENT RELATED

PUBLICATIONS

Office of Standards Services

National Institute of Standards and Technology

Gaithersburg, Maryland 20899-2100

NTTAA PUBLICATIONS:

The National Technology Transfer and Advancement Act - Plan for Implementation

(NISTIR 5967)

Toward a National Standards Strategy - Conference Report (NISTIR 6290)

Toward A National Standards Strategy: Conference Summary Report (NISTIR 6259) by

Walter G. Leight and Krista J. Johnsen Leuteritz, published September 23, 1998

Towards Strategic Management of Standards Activities at NIST (NISTIR 6292)

Conference on Using Voluntary Standards in the Federal Government - September 8, 1997

Using Voluntary Standards in the Federal Government (NISTIR 6086)

1998 Federal Standards Workshop: Standards Management - A World of Change and

Opportunities Conference Handbook -- A joint DOE, NIST, EPA, NASA, Partnership in

RMS, FDA publication

1998 Federal Technical Standards Workshop Proceedings (CONF-980822) A joint DOE,

NIST, EPA, NASA, Partnership in RMS, FDA publication

INTRODUCTORY PUBLICATIONS ON STANDARDS AND CONFORMITY

ASSESSMENT ACTIVITIES:

The ABC's of Standards-Related Activities in the United States (NBSIR 87-3576)

The ABC's of Certification Activities in the United States (NBSIR 88-3821)

The ABC's of the U.S. Conformity Assessment System (NISTIR 6014)

Laboratory Accreditation Activities in the United States (NISTIR 4576)

Questions and Answers on Quality, the ISO 9000 Standard Series, Quality System Registration,

and Related Issues (NISTIR 4721)
E-3

More Questions and Answers on the ISO 9000 Standard Series and Related Issues

(NISTIR 5122)

The U.S. Certification System from a Governmental Perspective (NISTIR 6077)

ISO Environmental Management Standardization Efforts (NISTIR 5638-1)

NACLA PUBLICATIONS:

Report on the Open Forum on Establishment of the National Council for Laboratory

Accreditation (NACLA) at the National Institute of Standards and Technology,

January 7, 1997 (NISTIR 6008)

Examination of Laboratory Accreditation Programs in the United States and the Potential Role

for a National Laboratory Accreditation System (NIST GCR 97-714)

Proceedings of the Open Forum on Laboratory Accreditation at the National Institute of

Standards and Technology, October 13, 1995 (NIST SP 902)

DIRECTORIES:

Directory of International and Regional Organizations Conducting Standards-Related Activities

(NIST SP 767)

Directory of European Regional Standards-Related Organizations (NIST SP 795)

Standards Activities of Organizations in the United States (NIST SP 806, 1996 Edition)

Directory of Federal Government Certification and Related Programs (NIST SP 739,

1999 Edition)

Directory of U.S. Private Sector Product Certification Programs (NIST SP 903)

Directory of Federal Government Laboratory Accreditation/Designation Programs

(NIST SP 808)

Directory of State and Local Government Laboratory Accreditation/Designation Programs

(NIST SP 815)

Directory of Professional/Trade Organization Laboratory Accreditation/Designation Programs

(NIST SP 831)

Standards Setting in the European Union - Standards Organizations and Officials in EU

Standards Activities (NIST SP 891, 1997 Edition)
E-4

Profiles of National Standards-Related Activities (NIST SP 912)

An Overview of the Development of Technical Infrastructure in the Asia-Pacific Region: The

Work of the Asia-Pacific Economic Cooperation (APEC) Sub-committee on Standards and

Conformance (SCSC) and the Specialist Regional Bodies (SRBs) (NISTIR 6325)

Free Trade Area of the Americas (FTAA) Conformity Assessment Infrastructure (NIST SP 941)

Semi-Annual Listing of North American Quality System Registration Organizations (NAQSRO)

Annual Directory of DOC Memberships on Outside Standards Committees

NVLAP PUBLICATIONS:

NIST Handbook 150: NVLAP Procedures and General Requirements

Directory of Accredited Laboratories

NVLAP Program-Specific Handbooks

NVLAP Policy Guides:

PG-1-1998: NVLAP Traceability Policy (March 1998)

PG-2-1998: Accreditation Documents for Laboratories Whose Accreditation Has Been

Suspended, Revoked, or Otherwise Terminated (May 1998)

PG-3-1999: Delegation of Authority from the Director of NIST to the Chief of NVLAP

(November 1999)

NVLAP NEWS:

Summer/Fall 1999

Winter 1999

Summer/Fall 1998

Winter/Spring 1998

Summer/Fall 1997
E-5

MISCELLANEOUS PUBLICATIONS:

TBT Agreement Activities of the National Institute of Standards and Technology

Environmental Management Systems Voluntary Project Evaluation Guidance (NISTIR 6120)

A Selective Review of Testing Laboratory Accreditation Movements in the United States

(NIST GCR 98-740)

Survey on the Implementation of ISO/IEC Guide 25 by National Laboratory Accreditation

Programs (NISTIR 5473)

Government s Role in Standards-Related Activities: Analysis of Comments (NISTIR 4367)

MAGAZINE ARTICLES:

Leight, W.G., Collins, B.L., Setting the Standards. Mechanical Engineering, 122, No. 2,

February 2000, pp. 46-52.

Collins, B.L., A Standards Infrastructure for the Future. Enjeuex, 200, January 2000, pp. 63-74.

Collins, B.L., Federal Government Coordination on Standards - The Role of NIST and the

Interagency Committee on Standards Policy. The Standards Forum, 7, No. 3,

December 1999, pp. 1, 15-16.

Collins, B.L., Standards and Government Regulations in the United States. Warnings and Risk

Communications, Chapter 12. Taylor and Francis Ltd., 1999.

Collins, B.L., Federal Government Coordination on Standards - The Role of NIST and the

Interagency Committee on Standards Policy. ASTM Standardization News, 27, May 1999,

pp. 20-21.

Collins, B.L., Update on the activities of the National Cooperation for Laboratory Accreditation. 

Accreditation and Quality Assurance: Journal for Quality, Comparability and Reliability in

Chemical Measurement, 3, September 1998, pp. 351-355.

Collins, B.L., National Cooperation of Laboratory Accreditation, Radioactivity &

Radiochemistry, A Journal of Applied Radioactivity Measurements, 8, No. 4, 1997.

Collins, B.L., NIST to Lead in NTTAA Implementation. ANSI Reporter, April 1997, p. 3.

Collins, B.L., The National Technology Transfer and Advancement Act - Plan for

Implementation. NISTIR 5967, January 1997.
E-6

Collins, B.L., National Cooperation of Laboratory Accreditation. CIRMS Annual Meeting

Abstracts, Radioactivity & Radiochemistry, 8, 1997, pp. 16-17.

Collins, B.L., Laboratory Accreditation: The Need for a National Infrastructure. Cal Lab,

November-December 1996, pp. 18-22.

Collins. B.L., Helping Reduce Technical Barriers to Trade. Proceedings of CPSC Conference on

Bringing Standards Together: An International Framework. July 18, 1996, pp. 48-53.

Collins, B.L., The Consensus Process in Standards Development. Proceedings of the Joint

Conference on Standard Setting in Large-Scale Assessments. 1995, pp. 203-219.

Breitenberg, M., Conformity Assessment: An Important Policy Issue, ASTM Standardization

News, November 1997, pp. 20-23.

Johnsen Leuteritz, K., Toward Strategic Management of Standards Activities at NIST, ASTM

Standardization News, December 1999, cover article. Reprinted in DOE s "The Standards

Forum," March 2000.

Leight, W. G., Preserving the Miracle, Partnership in RMS Standards: A Newsletter for

Professionals, January 2000, pp. 1-6.