Comments of the Human Factors Task Group on ANSI/ASB 053, 

“Standard for Report Content in Forensic Toxicology”

The OSAC Human Factors Task Group has unanimously approved these comments. 

This standard is promising and important, but it is not yet fully consistent with best practices for 

reporting of forensic science findings. Improvements are needed before it is placed on the OSAC 

Registry.

The current version can and should be enhanced by requiring a full and fair acknowledgement of

scientific uncertainty. Although in the past it was common for forensic scientists to report findings 

without discussing possible sources of variability and error, this is no longer considered “best practice,”

and reports that fail to acknowledge uncertainty are likely to be vulnerable to objections when offered 

in courts of law. From a human factors perspective, communicating the sources and degree of

uncertainty in any scientific result is especially critical in assisting finders of fact to understand how to 

integrate the results into an overall decision.

The 2009 report of the National Research Council on Strengthening Forensic Science in the United 

States, a document that has been referenced in a number of cases, declared that forensic science 

reports must describe, at a minimum, “the sources of uncertainty in the procedures and conclusions 

along with estimates of their scale (to indicate the level of confidence in the results).” (p. 186). 

According to the NRC Report, “Forensic science reports, and any courtroom testimony stemming from 

them, must include clear characterizations of the limitations of the analyses, including associated 

probabilities where possible.” (p. 186).

Similarly, the National Commission on Forensic Science declared that: “Reports should clearly state ... 

the estimated uncertainty and variability; and possible sources of error and limitations in the method, 

data, and conclusions.” (Recommendations to the Attorney General: Documentation, Case Record, and 

Report Contents, September 13, 2016).

These recommendations have been incorporated into OSAC’s Instructions for Scientific and Technical 

Review Panels (STRPs). The instructions call for STRPs to verify that a proposed standard “provides for 

estimates and expressions of the uncertainties in all qualitative and quantitative measurements” and 

states that the “potential magnitude of errors in any measurement must be assessed and reported so 

that the measurement can be used for informed decision making.” For binary decisions or other 

classifications, such as reporting that an analyte was “identified” or “detected,” the STRP should verify 

that “it includes guidance on expressing the accuracy of the decision or classification method (or, 

conversely, the risk of a wrong decision or classification).” The FSSB approved the instructions for 

STRPs in part to assure that OSAC standards live up to contemporary norms of scientific accuracy and 

transparency. 

The standard under consideration here, ANSI/ASB 053 (1st Ed. 2019), was developed before 

implementation of the new procedures of OSAC 2.0 and therefore has not had the benefit of STRP 

review. If such a review were conducted, it is likely that the STRP would conclude that this standard fails 

to meet the requirements for scientific rigor and transparency in reporting that the STRPs are tasked to 
enforce. It would allow qualitative “positive results” to be reported without any expression or 

discussion of uncertainty, and would require reporting of “an estimated uncertainty of measurement” 

for quantitative results only when “accreditation, regulation, or internal laboratory procedures require 

an estimated uncertainty of measurement to be calculated.” (Section 5.5). In addition, it would permit

analytic results to be reported using qualitative descriptors without requiring the disclosure of any 

available data on the uncertainty associated with scoring qualitative assays, or their accuracy. This is 

particularly troublesome from a human factors point of view because of the degree to which qualitative 

measures, which often rely in part of subjective judgment, are open to different, unanchored

interpretations. 

The question facing the FSSB is whether such a standard deserves to be on the OSAC Registry when it 

fails to meet the requirements for scientific rigor and transparency that STRPs are now expected to 

apply. Placing this standard on the OSAC Registry would suggest that the FSSB does not take these 

requirements seriously, or views them as merely precatory. It may be seen as setting a precedent under 

which other standards that have these same scientific shortcomings should be tolerated. 

Correcting these shortcomings and developing toxicology standards that incorporate current best 

scientific practices can be accomplished with very little additional effort. Forensic toxicologists are 

already required to estimate uncertainty for common procedures. Indeed, the OSAC Registry includes a 

document, “Standard Practices for Method Validation in Forensic Toxicology” that provides a cogent 

discussion of how to estimate measurement error in many circumstances. Following this guidance, labs 

should already have the data needed to describe the uncertainty in their testing results. All that is left 

to do is to add to the proposed standard language on how to communicate findings regarding 

uncertainty in a concise manner that can be understood by the intended audience. 

The Human Factors Task Group includes a number of scholars with expertise in communicating scientific 

information to lay audiences, and we hereby volunteer to collaborate with the Forensic Toxicology 

Subcommittee to develop reporting standards that acknowledge uncertainty and discuss it in a 

scientifically sound and comprehensible manner. We applaud the effort and progress the Toxicology 

Subcommittee has made in developing this standard, and appreciate its willingness to consider this 

proposed enhancement to its important work.