FY 2011 Government Unique Standards used in lieu of Voluntary Consensus Standards

Agency: Access Board (ACCESS)

Government Standard: 36 CFR Part 1194 Electronic and Information Technology 

Accessibility Standards (December, 2000) [Incorporated: 2006]

Voluntary Standard Rationale

ANSI/IEEE Standard for Hearing Aid 

Compatibility with Wireless Devices

A provision in the Section 508 Standards 

requires that interference to hearing 

technologies be reduced to the lowest possible 

level that allows a user of hearing technologies 

to utilize a telecommunications product. 

Individuals who are hard of hearing use hearing 

aids and other assistive listening devices, but 

they cannot be used if products introduce noise 

into the listening aids because of 

electromagnetic interference. The ANSI/IEEE 

Standard for Hearing Aid Compatibility with 

Wireless Devices was not completed in time for 

reference by the agency in its final rule 

published in FY 2000. However, the agency will 

consider using the Standard in FY 20007. In the 

meantime, because the requirement in the 

agency rule is a performance standard, the 

agency considers compliance with the VCS to 

meet the agency Standard. 

Agency: Consumer Product Safety Commission (CPSC)

Government Standard: 16 CFR 1500.17(a)(13), Metal-Cored Candlewicks Containing 

Lead and Candles With Such Wicks [Incorporated: 2003]

Voluntary Standard Rationale

Voices of Safety International (VOSI) standard 

on lead in candle wicks

The U.S. Consumer Product Safety Commission 

found that the VOSI standard is technically 

unsound, and thus would not result in the 

elimination or adequate reduction of the risk, 

and that substantial compliance with it is 

unlikely. See 68 Fed. Reg. 19145-6, paragraph 

H2, Voluntary Standards for further information 

on this finding.

Government Standard: CPSC 16 CFR Parts 1213, 1500, and 1513 for Bunk 

Beds [Incorporated: 2000]

Voluntary Standard Rationale

ASTM F1427-96 Standard Consumer Safety 

Specification for Bunk Beds

The CPSC rules go beyond the provisions of the 

ASTM voluntary standard to provide increased 

protection to children from the risk of death and 
serious injury from entrapment.

Agency: Department of Labor (DOL)

Government Standard: 29 CFR 1910 Subpart S - Electrical Standard (Incorporated: 

2007) [Incorporated: 2007]

Voluntary Standard Rationale

NFPA 70 - National Electric Code 

NFPA 70E - Electrical Safety Requirement for 

Employee Workplaces. 

ANSI/IEEE C2 - National Electrical Safety 

Code 

ANSI/ASME B30.4 - Portal, Tower, and 

Pedestal Cranes 

NFPA 33 - Spray Application Using 

Flammable or Combustible Materials 

ANSI Z133.1 Arboricultural Operations for 

Pruning, Repairing, Maintaining, and 

Removing Trees, and Cutting Brush

Several voluntary consensus standards were 

relied upon for the various provisions in the 

final rule, however, no single VCS is available 

to cover all the workplace applications that are 

addressed by OSHA. The Agency believes that 

it would be less burdensome for the regulated 

community to use one OSHA standard rather 

than purchase and use the 6 individual 

consensus standards it used to write the rule. 

Government Standard: 29 CFR 1915 Subpart F – General Working Conditions in 

Shipyard Employment (Incorporated: 2011) [Incorporated: 2011]

Voluntary Standard Rationale

• ANSI/IESNA RP–7–01, Recommended 

Practice for Lighting Industrial Facilities 

• ANSI/ISEA Z308.1–2009, Minimum 

Requirements for Workplace First Aid Kits and 

Supplies 

• ANSI Z358.1–2009, Emergency Eyewash and 

Shower Equipment 

• ANSI Z4.1–1995 and Z4.3–1995, Sanitation 

• ANSI/ASME B56.1–1992, Recognition of the 

hazard of powered industrial truck tipover and 

the need for the use of an operator re

Several voluntary consensus standards (VCS) 

were relied upon for the various provisions in 

the final rule, however, no single VCS is 

available to cover all the workplace hazards that 

are addressed by OSHA in this final rule. The 

Agency believes that it is less burdensome for 

the regulated community to use the one OSHA 

standard rather than require the purchase and 

use of numerous individual consensus standards 

it used to write the rule.

Government Standard: 29 CFR 1926 Subpart CC Cranes and Derricks in Construction 

(Incorporated: 2010) [Incorporated: 2010]

Voluntary Standard Rationale

ASME B30.2-2005; ASME B30.5-2004; 

ASME B30.7-2001; ASME B30.14-2004; 

AWS D1.1/D1.1M:2002 ANSI/AWS D14.3-

94; BS EN 13000:2004; BS EN 14439:2006; 

ISO 11660-1:2008(E); ISO 11660-2:1994(E); 

ISO 11660-3:2008(E); PCSA Std. No.2; SAE 

J185; SAE J987; SAE J1063; ANSI B30.5-

1968

Sixteen voluntary consensus standards (VCS) 

were relied upon for the various provisions in 

the final rule, however, no single VCS is 

available to cover all varieties of cranes and 

derricks and their applications.
Government Standard: 29 CFR 1926.1002 Roll-Over Protective Structures (Incorporated: 

2006) [Incorporated: 2006]

Voluntary Standard Rationale

SAE J1194-1999 Many consensus standards were relied upon for 

various provisions in the final rule. The primary 

VCS that applies directly to ROPS is SAE 

J1194-1999 which incorporates by reference 

several other VCSs. If SAE J1194-1999 was 

adopted into the OSHA provisions, the 

regulated community would have to consult not 

only the primary VCS but all of the VCSs that 

are incorporated into it as well. OSHA believes 

it is less burdensome for the regulated 

community to use one OSHA standard rather 

than require the purchase and use of several 

VCSs. 

Government Standard: 30 CFR Part 75 - Sealing of Abandoned Areas - Emergency 

Temporary Standard. [Incorporated: 2007]

Voluntary Standard Rationale

ACI 318-05 - Building Code Requirements for 

Structural Concrete and 

Commentary 

ACI 440.2R-02 - Design and Construction of 

Externally Bonded FRP

Systems for Strengthening Concrete Structures 

ASTM E119-07 - Standard Test Methods for 

Fire Tests of Building 

Construction and Materials 

ASTM E162-06 - Standard Test Method for 

Surface Flammability of Materials Using a 

Radiant Heat Energy Source

Four consensus standards were relied upon for 

various provisions in the emergency temporary 

standard, but no one consensus standard is 

available that covered all of the topics covered 

by MSHA's Emergency Temporary Standard. 

Government Standard: 30 CFR Part 75 – Safety Standards for Underground Coal Mines 

(Section 75.403 – Maintenance of Incombustible Rock Dust) – [Incorporated: 

2011] [Incorporated: 2011]

Voluntary Standard Rationale

• ASTM C110-09 – Standard Test Methods for 

Physical Testing of Quicklime, Hydrated Lime, 

and Limestone 

• ASTM C737-08 – Standard Specification for 

Limestone Dusting of Coal Mines

MSHA issued a final rule in June 2011 that 

finalized an Emergency Temporary Standard 

(ETS) on Maintenance of Incombustible 

Content of Rock Dust in Underground 

Bituminous Coal Mines. The basis of the ETS 

and final rule was a recommendation of the 

National Institute for Occupational Safety and 

Health contained in their Report of 
Investigations 9679 published in 2010. The 

ASTM consensus standards do not include the 

NIOSH recommendations or address the 

specific hazard covered in the MSHA ETS and 

final rule.

Government Standard: Electric Motor-Drive Equipment Rule [Incorporated: 2001]

Voluntary Standard Rationale

IEEE Standard 242-1986 Recommended 

Practice for Protection and Coordination of 

Industrial and Commercial Power Systems 

(IEEE Buff Book) and NFPA 70 - national 

Electric Code

The MSHA rule is a design-specific standards. 

The NFPA and IEEE standards were used as a 

source for the rule; however, the exact 

requirements of the rule were tailored to apply 

specifically to electric circuits and equipment 

used in the coal mining industry.

Government Standard: Exit Routes, Emergency Action Plans, and Fire Prevention Plans, 

29 CFR 1910, Subpart E [Incorporated: 2003]

Voluntary Standard Rationale

Life Safety Code, NFPA 101-2000 The OSHA standard addresses only workplace 

conditions whereas the NFPA Life Safety Code 

goes beyond workplaces. However, in the final 

rule OSHA stated that it had evaluated the 

NFPA Standard 101, Life Safety Code, (NFPA 

101-2000) and concluded that it provided 

comparable safety to the Exit Route Standards. 

Therefore, the Agency stated that any employer 

who complied with the NFPA 101-2000 instead 

of the OSHA Standard for Exit Routes would be 

in compliance.

Government Standard: Fire Protection for Shipyards, 29 CFR Part 1915, Subpart 

P [Incorporated: 2004]

Voluntary Standard Rationale

NFPA 312-2000 Standard for Protection of 

Vessels During Construction, Repair, and LayUp 

NFPA 33-2003 Standard for Spray Application 

Using Flammable or Combustible Materials

Many consensus standards were relied on for 

various provisions in OSHA's final rule, 

including 15 consensus standards that are 

incorporated by reference. However, OSHA and 

its negotiated rulemaking committee determined 

that there was no, one consensus standard 

available that covered all the topics in the rule. 

Government Standard: Longshoring and Marine Terminals; Vertical Tandem 

Lifts [Incorporated: 2009]

Voluntary Standard Rationale

ISO 668:1995 - Series 1 freight containers--

Classification, dimensions and ratings. 

Several voluntary consensus standards were 

relied upon for the various provisions in the 
ISO 1161:1984 - Series 1 freight containers--

Corner fittings--Specification. 

ISO 1161:1984/Cor. 1:1990 - Technical 

corrigendum 1:1990 to ISO 1161:1984. 

ISO 1496-1:1990 - Series 1 freight containers--

Specifications and testing--Part 1: General 

cargo containers for general purposes. 

ISO 1496-1:1990/Amd. 1:1993 -

final rule, however, no single VCS is available 

to cover all the workplace applications that are 

addressed by OSHA. The Agency believes that 

it would be less burdensome for the regulated 

community to use one OSHA standard rather 

than purchase and use the nine individual 

consensus standards used in this rule.

Government Standard: Sanitary Toilets in Coal Mines, 30 CFR 71, Subpart 

E [Incorporated: 2003]

Voluntary Standard Rationale

Non-Sewered Waste Disposal Systems--

Minimum Requirements, ANSI Z4.3-1987

The ANSI standard was not incorporated by 

reference because certain design criteria allowed 

in the ANSI standard, if implemented in an 

underground coal mine, could present health or 

safety hazards. For instance, combustion or 

incinerating toilets could introduce an ignition 

source which would create a fire hazard. For 

certain other design criteria found in the ANSI 

standard, sewage could seep into the 

groundwater, or overflow caused by rain or runoff could contaminate portions of the mine. 

Government Standard: Steel Erection Standards [Incorporated: 2002]

Voluntary Standard Rationale

ANSI A10.13 - Steel Erection; ASME/ANSI 

B30 Series Cranes Standards

Many consensus standards were relied upon for 

various provisions in the final rule, but there 

was no one consensus standard available that 

covered all of the topics covered by OSHA's 

final rule.

Agency: Department of Transportation (DOT)

Government Standard: 63 FR 17976; April 13, 1998 - Product Safety Signs and 

Labels [Incorporated: 1998]

Voluntary Standard Rationale

ANSI Z535.4 - ANSI Requirements for Color 

Coded Header Messages for the Different 

Levels of Hazard

NHTSA explained in the NPRM that the 

American National Standard Institute (ANSI) 

has a standard4 for product safety signs and 

labels (ANSI Z535.4) that identifies a hierarchy 

of hazard levels ranging from extremely serious 

to moderately serious and specifies 

corresponding hierarchies of signal words, i.e., 

“danger,” “warning,” and “caution,” and of 

colors. For the header, the ANSI standard 
specifies a red background with white text for 

“danger,” an orange background with black text 

for “warning,” and a yellow background with 

black text for caution.” 

The ANSI standard specifies that pictograms 

should be black on white, with occasional uses 

of color for emphasis, and that message text 

should be black on white. The agency noted in 

the NPRM that when it earlier updated the 

requirements for air bag warning labels to 

require the addition of color and pictograms, it 

had chosen not to adopt the colors specified in 

the ANSI standard. NHTSA chose to use yellow 

instead of orange in the background of the 

heading for the air bag warning label, even 

though the word “warning” was used, because 

of overwhelming focus group preference for 

yellow. Only two of the 53 participants 

preferred orange. Participants generally stated 

that yellow was more eye-catching than orange. 

Participants also noted that red (stop) and 

yellow (caution) had meaning to them, but not 

orange. 

NHTSA asked for comment on three color 

options for the revised utility vehicle rollover 

warning label. Proposed label 1 used the ANSI 

color format with the heading background in 

orange with the words in black. The remainder 

of the label had a white background with black 

text and drawings. Proposed label 2 used a color 

scheme like the air bag warning labels, which is 

the same as the ANSI color format except that 

the background color for the heading in the label 

is yellow. Proposed label 3 employed the color 

scheme used in the focus groups - the heading 

area had a red background with white text. The 

graphic areas had a yellow background with 

black and white drawings. The text area had a 

black background with yellow text. 

Despite focus group preference for the signal 

word “danger,” the agency proposed the use of 

the word “warning” as more appropriate to the 

level of risk. The agency also noted that the 
word “warning” is used in the air bag warning 

label. 

Recognizing that it might encounter additional 

conflicts between focus group preferences and 

the ANSI standard in future rulemakings, 

NHTSA requested comments in the NPRM on 

the extent to which any final choice regarding 

colors and signal words should be guided by the 

focus group preferences instead of the ANSI 

standard. NHTSA also requested comments on 

the broader issue of the circumstances in which 

it would be appropriate for agency rulemaking 

decisions to be guided by focus group results or 

other information when such information is 

contrary to a voluntary consensus standard such 

as the ANSI standard. 

At this time (February 22, 1999), a final 

decision is still pending regarding its proposal to 

upgrade the rollover warning label. As to the 

general questions it posed in the NPRM, 

NHTSA recognizes that ANSI’s mission differs 

somewhat from that of the agency’s focus 

groups with respect to the labeling of hazardous 

situations. ANSI’s mission is to develop and 

maintain a standard for communicating 

information about a comprehensive hierarchy of 

hazards, while the focus groups’ mission is to 

design an effective label for a specific hazard. 

The agency recognizes further that, given the 

difference in their missions, their conclusions 

about the appropriate manner of communication 

might differ on occasion. 

Since agency labeling decisions are highly 

dependent on the facts regarding the specific 

hazard being addressed, NHTSA anticipates 

making case-by-case determinations of the 

extent to which it should follow voluntary 

standards versus information from focus groups 

and other sources. NHTSA will rely on its own 

expertise and judgement in making 

determinations under the NTTAA and the 

statutory provisions regarding vehicle safety 

standards.
Government Standard: Air Bag Warning Label (1997) [Incorporated: 1997]

Voluntary Standard Rationale

ANSI ISO The Air Bag Warning Label uses yellow as the 

background color, instead of orange, in 

accordance with an ANSI standard and uses a 

graphic developed by Chrysler Corporation to 

depict the hazards of being too close to an air 

bag, instead of the graphic recommended by the 

ISO. These decisions were based on focus group 

testing sponsored by the agency which strongly 

indicated that these unique requirements would 

be far more effective with respect to safety than 

the industry standards.

Government Standard: Brake Performance, 49 CFR 393.52 - FMCSA's PerformanceBased Brake Testers (PBBTs) Requirement [Incorporated: 2002]

Voluntary Standard Rationale

SAE J667 - Brake Test Code Inertia 

Dynamometer (cancelled February 2002) 

SAE J1854 - Brake Force Distribution 

Performance Guide - Trucks and Buses

FMCSA used government-unique standards in 

lieu of voluntary consensus standards when it 

implemented its final rule to allow inspectors to 

use performance-based brake testers (PBBTs) to 

check the brakes on large trucks and buses for 

compliance with federal safety standards and to 

issue citations when these vehicles fail (67 FR 

51770, August 9, 2002). The FMCSA evaluated 

several PBBTs during a round robin test series 

to assess their functional performance and 

potential use in law enforcement. The standard, 

a specific configuration of brake forces and 

wheel loads on a heavy-duty vehicle, was used 

to evaluate the candidate PBBTs and their 

operating protocols. The agency’s rationale for

use of the government-unique standards was to 

verify that these measurements and new 

technology could be used by law enforcement as 

an alternative to stopping distance tests or onroad deceleration tests. PBBTs are expected to 

save time and their use could increase the 

number of commercial motor vehicles that can 

be inspected in a given time. Only PBBTs that 

meet specifications developed by the FMCSA 

can be used to determine compliance with the 

Federal Motor Carrier Safety Regulations. The 

final rule represents a culmination of agency 

research that began in the early 1990s.
Government Standard: Federal Motor Vehicle Safety Standard (FMVSS) No. 226, 

‘‘Ejection Mitigation" (49 CFR 571.226; 49 CFR 585, Subpart K) (2011). [Incorporated: 

2010]

Voluntary Standard Rationale

SAE J2568—Intrusion Resistance of Safety 

Glazing Systems for Road Vehicles; BSI AU 

209—Vehicle Security

NHTSA studied the potential of applying these 

standards, but decided against adopting them for 

several reasons. These standards provide glazing 

intrusion resistance requirements from external 

impact (outside-in) as opposed 

to ejection mitigation (inside-out). Additionally, 

the requirements are not appropriate for vehicles 

with only side 

curtain air bags, given that there is a time 

dependence associated with a curtain’s ejection 

mitigation performance. Once deployed, the 

pressure in the air bag continuously decreases. 

The 16 km/h test is done at 6 seconds to assure 

that the pressure does not decrease too quickly. 

It does not seem that the 40 mm gap test could 

be done after the 6-second impact, in any 

timeframe which is related to rollover and side 

impact ejections. Further, there was no shown 

safety need for applying the suggested 

standards. We cannot show that ejections that 

would not be prevented by the primary 100-mm 

displacement requirement would be prevented 

by a secondary 40-mm requirement. Also, it 

seemed that the 40-mm requirement would 

indirectly require installation of advanced 

glazing. The costs associated with advanced 

glazing installations at the side windows 

covered by the NHTSA standard are substantial 

in comparison to a system only utilizing rollover 

curtains. For these reasons, the agency did not 

accept the standards.

Agency: Environmental Protection Agency (EPA)

Government Standard: EPA Method 1 – Traverse Points, Stationary 

Sources [Incorporated: 2001]

Voluntary Standard Rationale

ASTM D3154-00, Standard Method for 

Average Velocity in a Duct (Pitot Tube 

Method)

1. The standard appears to lack in quality 

control and quality assurance requirements. It 

does not include the following: (1) Proof that 

openings of standard pitot tube have not 
plugged during the test; (2) if differential 

pressure gauges other than inclined manometers 

(e.g., magnehelic gauges) are used, their 

calibration must be checked after each test 

series; and (3) the frequency and validity range 

for calibration of the temperature sensors. 2. 

They are too general, too broad, or not 

sufficiently detailed to assure compliance with 

EPA regulatory requirements.

ASTM D3154-91 (1995), Standard Method for 

Average Velocity in a Duct (Pitot Tube 

Method)

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements.

Government Standard: EPA Method 101 - Mercury Emissions, Chlor-Alkali Plants 

(Air) [Incorporated: 2001]

Voluntary Standard Rationale

ASTM D6216-98 - Standard Practice for 

Opacity Monitor Manufacturers to Certify 

Conformance with Design and Performance 

Specifications.

The EPA is incorporating ASTM D6216 

(manufacturers certification) by reference into 

EPA Performance Specification 1, Sect. 5 & 6 

in another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1.

Government Standard: EPA Method 101a - Mercury Emissions Sewer/Sludge 

Incinerator [Incorporated: 2001]

Voluntary Standard Rationale

ASTM D6216-98 - Standard Practice for 

Opacity Monitor Manufacturers to Certify 

Conformance with Design and Performance 

Specifications.

The EPA is incorporating ASTM D6216 

(manufacturers certification) by reference into 

EPA Performance Specification 1, Sect. 5 & 6 

in another rulemaking. ASTM D6216 does not 

address all the requirements specified in PS-1.

Government Standard: EPA Method 10A – Carbon Monoxide for Certifying 

CEMS [Incorporated: 2001]

Voluntary Standard Rationale

CAN/CSA Z223.21-M1978, Method for the 

Measurement of Carbon Monoxide: 3—Method 

of Analysis by Non-Dispersive Infrared 

Spectrometry.

1. It is lacking in the following areas: (1) 

Sampling procedures; (2) procedures to correct 

for the carbon dioxide concentration; (3) 

instructions to correct the gas volume if CO2 

traps are used; (4) specifications to certify the 

calibration gases are within 2 percent of the 

target concentration; (5) mandatory instrument 

performance characteristics (e.g., rise time, fall 

time, zero drift, span drift, precision); (6) 

quantitative specification of the span value 

maximum as compared to the measured value: 

The standard specifies that the instruments 
should be compatible with the concentration of 

gases to be measured, whereas EPA Method 10 

specifies that the instrument span value should 

be no more than 1.5 times the source 

performance standard. 2. Is too general, too 

broad, or not sufficiently detailed to assure 

compliance with EPA regulatory requirements.

Government Standard: EPA Method 12 – Inorganic Lead, Stationary 

Sources [Incorporated: 2000]

Voluntary Standard Rationale

ASTM D4358-94 (1999), Standard Test 

Method for Lead and Chromium in Air 

Particulate Filter Samples of Lead Chromate 

Type Pigment Dusts by Atomic Absorption 

Spectroscopy

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 

of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

ASTM E1741-95 (1995), Standard Practice for 

Preparation of Airborne Particulate Lead 

Samples Collected During Abatement and 

Construction Activities for Subsequent 

Analysis by Atomic Spectrometry

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 

of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

ASTM E1979-98 (1998), Standard Practice for These ASTM standards do not require the use of 
Ultrasonic Extraction of Paint, Dust, Soil, and 

Air Samples for Subsequent Determination of 

Lead

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 

of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

Government Standard: EPA Method 17 - Particle Matter (PM) In Stack 

Filtration [Incorporated: 2001]

Voluntary Standard Rationale

ASME C00049 EPA looked at this standard for both Pulp and 

Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. 

Contains sampling options beyond which would 

be considered acceptable for Method 5.

ASTM D3685/3685M-95 - Standard Test 

method for Sampling and Determination of 

Particle Matter in Stack Gases 

EPA looked at this standard for both Pulp and 

Paper Hazardous Air Pollutant rules and for the 

Small Municipal Waste Combustion rule. 

Contains sampling options beyond which would 

be considered acceptable for Method 5.

Government Standard: EPA Method 2 – Velocity and S-type Pitot [Incorporated: 1999]

Voluntary Standard Rationale

ASTM D3464-96 (2001), Standard Test 

Method Average Velocity in a Duct Using a 

Thermal Anemometer

Applicability specifications are not clearly 

defined, e.g., range of gas composition, 

temperature limits. Also, the lack of supporting 

quality assurance data for the calibration 

procedures and specifications, and certain 

variability issues that are not adequately 

addressed by the standard limit EPA's ability to 

make a definitive comparison of the method in 

these areas.

ISO 10780:1994, Stationary Source Emissions-

- Measurement of Velocity and Volume 

Flowrate of Gas Streams in Ducts

The standard recommends the use of an Lshaped pitot, which historically has not been 

recommended by EPA. The EPA specifies the 

S-type design, which has large openings that are 
less likely to plug up with dust.

Government Standard: EPA Method 21 - Volatile Organic Compound (VOC) 

Leaks [Incorporated: 2003]

Voluntary Standard Rationale

ASTM E1211-97 - Standard Practice for Leak 

Detection and Location Using SurfaceMounted Acoustic Emission Sensors

This standard will detect leaks but not classify 

the leak as VOC, as in EPA Method 21. In 

addition, in order to detect the VOC 

concentration of a known VOC leak, the 

acoustic signal would need to be calibrated 

against a primary instrument. Background noise 

interference in some source situations could also 

make this standard difficult to use effectively.

Government Standard: EPA Method 25 – Gaseous Nonmethane Organic 

Emissions [Incorporated: 2001]

Voluntary Standard Rationale

EN 12619:1999 Stationary Source Emissions--

Determination of the Mass Concentration of 

Total Gaseous Organic Carbon at Low 

Concentrations in Flue Gases--Continuous 

Flame Ionization Detector Method

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher.

ISO 14965:2000(E) Air Quality--Determination 

of Total Nonmethane Organic Compounds--

Cryogenic Preconcentration and Direct Flame 

Ionization Method

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher.

Government Standard: EPA Method 25A – Gaseous Organic Concentration, Flame 

Ionization [Incorporated: 2001]

Voluntary Standard Rationale

EN 12619:1999 Stationary Source Emissions--

Determination of the Mass Concentration of 

Total Gaseous Organic Carbon at Low 

Concentrations in Flue Gases--Continuous 

Flame Ionization Detector Method

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 

limited to be useful in measuring source 

emissions, which are expected to be much 

higher.

ISO 14965:2000(E) Air Quality--Determination 

of Total Nonmethane Organic Compounds--

Cryogenic Preconcentration and Direct Flame 

Ionization Method

The standards do not apply to solvent process 

vapors in concentrations greater than 40 ppm 

(EN 12619) and 10 ppm carbon (ISO 14965). 

Methods whose upper limits are this low are too 
limited to be useful in measuring source 

emissions, which are expected to be much 

higher.

Government Standard: EPA Method 28 (Section 10.1) – Wood Heaters, Certificate and 

Auditing [Incorporated: 2003]

Voluntary Standard Rationale

ASME Power Test Codes, Supplement on 

Instruments and Apparatus, part 5, 

Measurement of Quantity of Materials, Chapter 

1, Weighing Scales

It does not specify the number of initial 

calibration weights to be used nor a specific 

pretest weight procedure.

ASTM E319-85 (Reapproved 1997), Standard 

Practice for the Evaluation of Single-Pan 

Mechanical Balances

This standard is not a complete weighing 

procedure because it does not include a pretest 

procedure.

Government Standard: EPA Method 29 – Metals Emissions from Stationary 

Sources [Incorporated: 2001]

Voluntary Standard Rationale

ASTM D4358-94 (1999), Standard Test 

Method for Lead and Chromium in Air 

Particulate Filter Samples of Lead Chromate 

Type Pigment Dusts by Atomic Absorption 

Spectroscopy

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 

of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

ASTM E1741-95 (1995), Standard Practice for 

Preparation of Airborne Particulate Lead 

Samples Collected During Abatement and 

Construction Activities for Subsequent 

Analysis by Atomic Spectrometry

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 
of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

ASTM E1979-98 (1998), Standard Practice for 

Ultrasonic Extraction of Paint, Dust, Soil, and 

Air Samples for Subsequent Determination of 

Lead

These ASTM standards do not require the use of 

glass fiber filters as in EPA Method 12 and 

require the use of significantly different 

digestion procedures that appear to be milder 

than the EPA Method 12 digestion procedure. 

For these reasons, these ASTM standards cannot 

be considered equivalent to EPA Method 12. 

Also, the subject ASTM standards do not 

require the use of hydrogen fluoride (HF) as in 

EPA Method 29 and, therefore, they cannot be 

used for the preparation, digestion, and analysis 

of Method 29 samples. Additionally, Method 29 

requires the use of a glass fiber filter, whereas 

these three ASTM standards require cellulose 

filters and other probable nonglass fiber media, 

which cannot be considered equivalent to EPA 

Method 29.

CAN/CSA Z223.26-M1987, Measurement of 

Total Mercury in Air Cold Vapour Atomic 

Absorption Spectrophotometeric Method

It lacks sufficient quality assurance and quality 

control requirements necessary for EPA 

compliance assurance requirements.

Government Standard: EPA Method 306 - Chromium Emissions, Electroplating and 

Anodizing [Incorporated: 2002]

Voluntary Standard Rationale

ASTM D4358-94 (1999) - Standard Test 

Method for Lead and Chromium in Air 

Particulate Filter Samples of Lead Chromate 

Type Pigment Dusts by Atomic Absorption 

Spectroscopy

This MACT standard (Petroleum Refineries) 

only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 

not Method 12 and 306: Method 29 requires the 

use of hydrofluoric acid (HF) in its process of 

digestion of the sample. ASTM D4358-94 

(1999) does not require the use of HF; therefore, 

it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. 

Additionally, Method 29 requires the use of a 

glass fiber filter, whereas the subject ASTM 

standard requires cellulose filters and other 

probable non-glass fiber media, and this further 

negates their use as Method 29 equivalent 

methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979).
Government Standard: EPA Method 306a - Chromium Emissions, Electroplating --

Mason Jar [Incorporated: 2002]

Voluntary Standard Rationale

ASTM D4358-94 (1999) - Standard Test 

Method for Lead and Chromium in Air 

Particulate Filter Samples of Lead Chromate 

Type Pigment Dusts by Atomic Absorption 

Spectroscopy

This MACT standard (Petroleum Refineries) 

only cites Method 29. Therefore, the following 

EPA comment is only applicable for Method 29 

not Method 12 and 306: Method 29 requires the 

use of hydrofluoric acid (HF) in its process of 

digestion of the sample. ASTM D4358-94 

(1999) does not require the use of HF; therefore, 

it cannot be used in the preparation, digestion, 

and analysis of Method 29 samples. 

Additionally, Method 29 requires the use of a 

glass fiber filter, whereas the subject ASTM 

standard requires cellulose filters and other 

probable non-glass fiber media, and this further 

negates their use as Method 29 equivalent 

methods. (Same comment as provided for 

ASTM E1741 and ASTM E1979).

Government Standard: EPA Method 3A – Carbon Dioxide and Oxygen Concentrations, 

IAP [Incorporated: 1999]

Voluntary Standard Rationale

ISO 12039:2001, Stationary Source Emissions-

- Determination of Carbon Monoxide, Carbon 

Dioxide, and Oxygen--Automated Methods

This ISO standard is similar to EPA Method 3A, 

but is missing some key features. In terms of 

sampling, the hardware required by ISO 

12039:2001 does not include a 3-way 

calibration valve assembly or equivalent to 

block the sample gas flow while calibration 

gases are introduced. In its calibration 

procedures, ISO 12039:2001 only specifies a 

two-point calibration while EPA Method 3A 

specifies a three-point calibration. Also, ISO 

12039:2001 does not specify performance 

criteria for calibration error, calibration drift, or 

sampling system bias tests as in the EPA 

method, although checks of these quality control 

features are required by the ISO standard.

Government Standard: EPA Method 515.4 – Chlorinated Acids in DW by LL Fast 

CG/ECD [Incorporated: 2003]

Voluntary Standard Rationale

ASTM D5317-98 -- Standard Test Method For 

Determination of Chlorinated Organic Acid 

Compounds in Water by Gas Chromatography 

ASTM D5317-98 specifies acceptance windows 

for the initial demonstration of proficiency for 

laboratory fortified blank samples that are as 
With an Electron Capture Detector small as 0 percent to as large as 223 percent 

recovery for picloram, with tighter criteria for 

other regulated contaminants. Therefore, this 

method permits unacceptably large control 

limits, which include 0 percent recovery.

Standard Method 6640 B for the chlorinated 

acids

The use of this voluntary consensus standard 

would have been impractical due to significant 

shortcomings in the sample preparation and 

quality control sections of the method 

instructions. Section 1b of Method SM 6640 B 

states that the alkaline wash detailed in section 

4b2 is optional. The hydrolysis that occurs 

during this step is essential to the analysis of the 

esters of many of the analytes. Therefore, this 

step is necessary and cannot be optional. In 

addition, the method specifies that the quality 

control limits for laboratory-fortified blanks are 

to be based upon plus or minus three times the 

standard deviation of the mean recovery of the 

analytes, as determined in each laboratory. 

Therefore, this method permits unacceptably 

large control limits, which may include 0 

percent recovery.

Government Standard: EPA Method 531.2 – N-Methylcarbamoylozimes/ates, Aqueous 

In/HPLC [Incorporated: 2003]

Voluntary Standard Rationale

Standard Method 6610, 20th Edition Standard Method 6610, 20th Edition has 

recently been approved for compliance 

monitoring. Standard Method 6610, 20th 

Supplemental Edition permits the use of a 

strong acid, hydrochloric acid (HCL), as a 

preservative. The preservatives in all of the 

other approved EPA and Standard Methods 

procedures for these analytes are weak acids 

that adjust the pH to a specific value based upon 

the pKa of the preservative. The use of HCL 

would require accurate determinations of the pH

of the sample in the field and could be subject to 

considerable error and possible changes in pH 

upon storage. Although not specifically 

observed for oxamyl or carbofuran during the 

development of similar methods, structurally 

similar pesticides have been shown to degrade 

over time when kept at pH 3. Therefore, 

approval of this method is impractical because it 
specifies the use of a strong acid (HCL) when 

positive control of the pH is critical.

Standard Method 6610, 20th Supplemental 

Edition

Standard Method 6610, 20th Edition has 

recently been approved for compliance 

monitoring. Standard Method 6610, 20th 

Supplemental Edition permits the use of a 

strong acid, hydrochloric acid (HCL), as a 

preservative. The preservatives in all of the 

other approved EPA and Standard Methods 

procedures for these analytes are weak acids 

that adjust the pH to a specific value based upon 

the pKa of the preservative. The use of HCL 

would require accurate determinations of the pH 

of the sample in the field and could be subject to 

considerable error and possible changes in pH 

upon storage. Although not specifically 

observed for oxamyl or carbofuran during the 

development of similar methods, structurally 

similar pesticides have been shown to degrade 

over time when kept at pH 3. Therefore, 

approval of this method is impractical because it 

specifies the use of a strong acid (HCL) when 

positive control of the pH is critical.

Government Standard: EPA Method 5i - Low Level Particulate Matter, Stationary 

Sources [Incorporated: 2001]

Voluntary Standard Rationale

ASTM D6331-98 This standard does not have paired trains as 

specified in method 5 and does not include some 

quality control procedures specified in the EPA 

method and which are appropriate to use in this 

rule.

Government Standard: EPA Method ALT 004 [Incorporated: 2002]

Voluntary Standard Rationale

ASTM D5835-95 - Standard Practice for 

Sampling Stationary Source Emissions for 

Automated Determination of Gas 

Concentration

Similar to Methods 3a, 6c, 7e, 10, ALT 004, 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396.

ISO 10396:1993 - Stationary Source 

Emissions: Sampling for the Automated 

Determination of Gas Concentrations 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, 

CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to 

ASTM D5835. 

Government Standard: EPA Method CTM 022 [Incorporated: 2002]

Voluntary Standard Rationale
ASTM D5835-95 - Standard Practice for 

Sampling Stationary Source Emissions for 

Automated Determination of Gas 

Concentration

Similar to Methods 3a, 6c, 7e, 10, ALT 004, 

CTM 022. Lacks in detail and quality assurance 

and quality control requirements. Very similar 

to ISO 10396.

ISO 10396:1993 - Stationary Source 

Emissions: Sampling for the Automated 

Determination of Gas Concentrations 

Duplicates Method 3a, 6c, 7e, 10, ALT 004, 

CTM 022. Lacks in detail and quality assurance 

plus quality control requirements. Similar to 

ASTM D5835. 

Government Standard: EPA Performance Specification 2 (nitrogen oxide portion 

only) [Incorporated: 2001]

Voluntary Standard Rationale

ISO 10849:1996, Determination of the Mass 

Concentration of Nitrogen Oxides--

Performance

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements.

Government Standard: EPA Performance Specification 2 (sulfur dioxide portion 

only) [Incorporated: 2001]

Voluntary Standard Rationale

ISO 7935:1992, Stationary Source Emissions--

Determination of the Mass Concentration of 

Sulfur Dioxide--Performance Characteristics of 

Automated Measuring Methods"

Is too general, too broad, or not sufficiently 

detailed to assure compliance with EPA 

regulatory requirements.

Government Standard: SW846-6010b [Incorporated: 2002]

Voluntary Standard Rationale

ASTM C1111-98 (1998) - Standard Test 

Method for Determining Elements in Waste 

Streams by Inductively Coupled PlasmaAtomic Emission Spectrometers 

This standard lacks details for instrument 

operation QA/QC, such as optimizing plasma 

operating conditions; upper limit of linear 

dynamic range; spectral interference correction; 

and calibration procedures, which include initial 

and continuous calibration verifications. Also 

lacks internal standard and method of standard 

addition options for samples with interferences. 

ASTM D6349-99 (1999) - Standard Test 

Method for Determining Major and Minor 

Elements in Coal, Coke, and Solid Residues 

from Combustion of Coal and Coke by 

Inductively Coupled Plasma-Atomic Emission 

Spectrometers

This standard lacks details for instrument 

operation QA/QC, such as optimizing plasma 

operating conditions, upper limit of linear 

dynamic range, spectral interference correction, 

and calibration procedures, that include initial 

and continuous calibration verifications. Also 

lacks details for standard preparation, and 

internal standard and method of standard 

addition options for samples with interferences.

Agency: General Services Administration (GSA)
Government Standard: Federal Specification KKK-A-1822E - Federal Specification for 

Ambulances [Incorporated: 2003]

Voluntary Standard Rationale

ASTM F2020 - Standard Practice for Design, 

Construction, and Procurement of Emergency 

Medical Services Ambulances

The ASTM Standard Practice for Design, 

Construction, and Procurement of Emergency 

Medical Services (EMSS) Ambulances (ASTM 

F2020) is not practical for use, and therefore 

GSA uses the Federal Specification for 

Ambulances (KKK-A-1822E). GSA has 

determined the ASTM document is not practical 

for use for the following reasons: 

1) GSA has determined that ASTM F2020 

contains specific practices that are technically 

and economically impractical to use for the 

acquisition of commercial based vehicles 

because the document is financially burdensome 

and technically ineffective. Specifically at issue 

is the ASTM Standard Specification for Medical 

Oxygen Delivery Systems for EMS Ground 

Vehicles, F1949-99 which is inclusive to ASTM 

F2020. 

2) GSA has determined that ASTM F2020 is 

impractical because it is defined as a standard 

practice which is ambiguous and an ineffective 

substitution for specifications or requirements 

for use in GSA contract documents. ASTM 

F1949-99, a Standard Specification for Medical 

Oxygen Delivery Systems for EMS Ground 

Vehicles is included in ASTM F2020. ASTM 

F1949-99 is defined as a “standard 

specification”. 

3) GSA has determined that ASTM F2020 is 

impractical because ASTM International does 

not provide interpretations and written guidance 

to their publications which is inadequate and 

less useful. ASTM members may only offer 

personal opinions. ASTM offers no mechanism 

to support timely resolution of conflicts between 

contractor and procurement organizations on 

technical subject matter. GSA provides 

interpretations, clarifications and engineering 

determinations when required. This is one of the 

most important concerns presented by the 
Ambulance Manufacturers Division (AMD). 

4) The AMD has determined through consensus 

that it is impractical to replace the Federal 

Specification for Ambulances, KKK-A-1822E 

with the ASTM Standard Practice, F2020. GSA 

initiated a survey to collect public responses 

from a wide range of constituent users of the 

Federal Ambulance Specification. The National 

Association of Emergency Medical Technicians 

(NAEMT), the International Association of Fire 

Chiefs (IAFC), the National Association of 

State EMS Directors (NASEMSD) and the 

National Association of EMS Physicians 

universally accept and support the continued use 

of the Federal Specification. The AMD and 

constituent users have determined that it is 

impractical to replace the Federal Specification 

for Ambulances, KKK-A-1822E with the 

ASTM Standard Practice, F2020 because rule 

promulgation is burdensome and costly. Staff 

and administration resources would need to be 

diverted in each state EMS office to implement 

the change in statutes, public health codes, rules 

and regulations. 

5) GSA has determined that ASTM F2020 is 

impractical because it is burdensome to GSA 

procurement efforts. While the current ASTM 

document recites many of the requirements from 

the Federal Specification, a future ASTM 

document would likely have diverging 

requirements unacceptable to the Government. 

This was verified by a member of the ASTM 

F2020 subcommittee at the September 4, 2003 

meeting of the Federal Interagency Committee 

on Emergency Medical Services.

Government Standard: FF-L-2937 [Incorporated: 2006]

Voluntary Standard Rationale

UL 768 Federal Specification FF-L-2937 – Combination 

Lock, Mechanical used in lieu of UL 768 

Combination Locks. The lock covered by the 

GUS is used for the protection of classified 

information and weapons. The UL specification 

did not meet identified government needs for 
dialing tolerance and bolt end pressure.

Government Standard: MIL-G-9954 - Glass Beads for Cleaning and 

Peening [Incorporated: 2000]

Voluntary Standard Rationale

SAE/AMS 2431 - Peening Media, General 

Requirements

This government-unique standard contains 

specific size & performance required for Air 

Force critical applications that are not present in 

the voluntary standards.

Agency: Department of Health and Human Services (HHS)

Government Standard: FDA Guidelines on Asceptic Processing (2004) [Incorporated: 

2004]

Voluntary Standard Rationale

ISO 13408-1 Asceptic Process ing of Health 

Care Products, Part 1, General Requirements

FDA is not using the ISO standard because the 

applicability of these requirements is limited to 

only portions of aseptically manufactured 

biologics and does not include filtration, freezedrying, sterilization in place, cleaning in place, 

or barrier-isolator technology. There are also 

significant issues related to aseptically produced 

bulk drug substance that are not included in the 

document

Agency: Department of Housing and Urban Development (HUD)

Government Standard: 24 CFR 200.935 - Administrator qualifications and procedures for 

HUD building products and certififcation programs [Incorporated: 2000]

Voluntary Standard Rationale

ANSI A119.1 N - Recreation Vehicles HUD Building-Product Standards & 

Certification Programs. HUD was required by 

legislation to “establish Federal construction 

and safety standards for manufactured homes 

and to authorize manufactured home safety 

research and development”. Recently, HUD 

retained a private consensus body (NFPA) to 

update and modernize the Manufactured Home 

Standards. At the conclusion of the development 

process, NFPA will submit the revised standard 

to HUD for regulatory adoption.

Government Standard: 24 CFR 3280 - Manufactured Home Construction and Safety 

Standards [Incorporated: 2000]

Voluntary Standard Rationale

ANSI A119.1 - Recreation Vehicles and NFPA HUD-Unique Manufactured Home Construction 
501C - Standard on Recreational Vehicles & Safety Standards. HUD was required by 

legislation to “establish Federal construction 

and safety standards for manufactured homes 

and to authorize manufactured home safety 

research and development”. Recently, HUD 

retained a private consensus body (NFPA) to 

update and modernize the Manufactured Home 

Standards. At the conclusion of the development 

process, NFPA will submit the revised standard 

to HUD for regulatory adoption.

Agency: National Archives and Records Administration (NARA)

Government Standard: NARA data standard [Incorporated: 2000]

Voluntary Standard Rationale

Archives, Personal Papers, and Manuscripts 

(APPM); 

General International Standard Archival 

Description (ISAD(G)); 

International Standard Archival Authority 

Record for Corporate Bodies, Persons, and 

Families (ISAAR(CPF)); 

Encoded Archival Description (EAD); 

Machine Readable Cataloging (MARC)

These voluntary standards do not meet the 

precise needs of the agency.

Agency: Nuclear Regulatory Commission (NRC)

Government Standard: NRC NUREG-1556, “Consolidated Guidance about Materials 

Licenses” [Incorporated: 2011]

Voluntary Standard Rationale

(ANSI) N 13.2-1969, “Guide for 

Administrative Practices in Radiation 

Monitoring”

(ANSI) N 13.2-1969, “Guide for Administrative 

Practices in Radiation Monitoring,” had been 

endorsed in Regulatory Guide 8.2, with the 

same title, issued in February, 1973. The 

standard has not been revised since its inception, 

and it now refers to obsolete technical practices 

and outdated requirements. Therefore, Revision 

1 of RG 8.2, published in May, 2011, removed 

endorsement of ANSI N 13.2-1969. Guidance is 

now provided through two referenced NRC 

reports, which could be considered 

Government-unique standards: NUREG-1556, 

“Consolidated Guidance about Materials 

Licenses,” and NUREG-1736, “Consolidated 

Guidance: 10 CFR Part 20—Standards for 

Protection against Radiation.”
Government Standard: NRC NUREG-1736, “Consolidated Guidance: 10 CFR Part 20—

Standards for Protection against Radiation” [Incorporated: 2011]

Voluntary Standard Rationale

(ANSI) N 13.2-1969, “Guide for 

Administrative Practices in Radiation 

Monitoring”

(ANSI) N 13.2-1969, “Guide for Administrative 

Practices in Radiation Monitoring,” had been 

endorsed in Regulatory Guide 8.2, with the 

same title, issued in February, 1973. The 

standard has not been revised since its inception, 

and it now refers to obsolete technical practices 

and outdated requirements. Therefore, Revision 

1 of RG 8.2, published in May, 2011, removed 

endorsement of ANSI N 13.2-1969. Guidance is 

now provided through two referenced NRC 

reports, which could be considered 

Government-unique standards: NUREG-1556, 

“Consolidated Guidance about Materials 

Licenses,” and NUREG-1736, “Consolidated 

Guidance: 10 CFR Part 20—Standards for 

Protection against Radiation.”

Agency: Department of Agriculture (USDA)

Government Standard: WILDLAND FIRE FOAM: GUS Number: 5100-307a; June 2007. 

Title: Specification for Fire Suppressant Foam for Wildland Firefighting (Class A 

Foam). [Incorporated: 2010]

Voluntary Standard Rationale

NFPA 1150 - Standard on Fire-Fighting Foam 

Chemicals for Class A Fuels in Rural, 

Suburban, and Vegetated Areas.

Foam fire suppressants contain foaming and 

wetting agents. The foaming agents affect the 

accuracy of an aerial drop, how fast the water 

drains from the foam and how well the product 

clings to the fuel surfaces. The wetting agents 

increase the ability of the drained water to 

penetrate fuels. Foam fire suppressants are 

supplied as wet concentrates. This standard was 

developed with international cooperation for 

Class A Foam used in wildland fire suppression 

situations and equipment. Standard was created 

by the USDA Forest Service in cooperation with 

the Department of Interior (DOI), the State of 

California, Department of Forestry and Fire 

Protection and the Canadian Interagency Forest 

Fire Center. The Forest Service has not chosen 

to utilize NFPA 1150 as it is designed 

specifically for application by municipal fire 

agencies in the wildland-urban interface, 
utilizing apparatus and situations that they are 

likely to encounter. The Forest Service’s GUS 

for foam products is specific to use by wildland 

fire equipment and situations that are unique, 

e.g. helicopter use of foams, remote storage 

situations, and varied quality of water sources in 

the wildland settings. The agency feels this 

standard more accurately reflects the needs and 

mission of the federal wildland fire suppression 

agencies.