General Services Administration (GSA) Fiscal Year 2022 Agency Report

1. Please provide a summary of your agency’s activities undertaken to carry out the provisions of 

OMB Circular A-119, “Federal Participation in the Development and Use of Voluntary Consensus 

Standards and in Conformity Assessment Activities” and the National Technology Transfer and 

Advance Act (NTTAA). The summary should contain a link to the agency’s standards-specific 

website(s) where information about your agency’s standards and conformity assessment related 

activities are available.

OMB Circular A-119 assists our Agency to review our standards use on a recurring basis, and 

continuously assess the potential to expand use of non-government standards/ voluntary consensus 

standards when practical for the Government. This leads to increased efficiency in our work processes 

and contributes to greater reliability on product quality. 

Standards play a significant role in the Federal Supply program. They are used to establish baselines for 

product quality, performance and features; allow competitive procurement of functionally equivalent 

products and; when necessary ensure interchangeability of products produced under different contracts 

and across different contract periods. The most significant aspect of our use of standards is to ensure 

the safety and durability of the products purchased for government use. 

GSA maintains a Standards website: http://www.gsa.gov > Buy Through Us > Purchasing Programs > 

Requisition Programs > GSA Global Supply > Supply Standards > Index of Federal Specifications, 

Standards, and Commercial Item Descriptions

2. Please list the government-unique standards (GUS) your agency began using in lieu of voluntary 

consensus standards during FY 2022. Please note that GUS which are still in effect from previous years 

should continue to be listed, thus the total number in your agency's report will include all GUS 

currently in use (previous years and new as of this FY):

Current total GUS: 3

(1) Government Unique Standard

Federal Specification KKK-A-1822E - Federal Specification for Ambulances [Incorporated: 2003]

Voluntary Standard

ASTM F2020 - Standard Practice for Design, Construction, and Procurement of Emergency Medical 

Services Ambulances

Rationale

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, KKKA-1822E with the ASTM Standard Practice, F2020 because rule promulgation is complex 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 complex 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.

(2) Government Unique Standard

FF-L-2937 [Incorporated: 2006]

Voluntary Standard

UL 768

Rationale

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.
(3) Government Unique Standard

MIL-G-9954 - Glass Beads for Cleaning and Peening [Incorporated: 2000]

Voluntary Standard

SAE/AMS 2431 - Peening Media, General Requirements

Rationale

This government-unique standard contains specific size & performance required for Air Force critical 

applications that are not present in the voluntary standards.