FY 2016 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 1910.1200 – Hazard Communication Standard 

(Incorporated: May 2012) [Incorporated: 2012]

Voluntary Standard Rationale

ASTM D 56-05, Standard Test Method for Flash 

Point by Tag 

Closed Cup Tester, Approved May 1, 2005, IBR 

approved for Appendix B to 

Sec. 1910.1200. 

• ASTM D 86-07a, Standard Test Method for 

Distillation of 

Petroleum Products at Atmospheric Pressure, 

Approved April 1, 2007, IBR 

approved for Appendix B to Sec. 1910.1200. 

• ASTM D 93-08, Standard Test Methods for 

Flash Point by PenskyMartens

Voluntary consensus standards (VCS) were 

relied upon for the various provisions in the 

final rule. This revision was undertaken to 

align the U.S. with other countries utilizing 

the United Nations Globally Harmonized 

System of Classification and Labeling. It was 

based on various standards and guidance 

materials used in international negotiations 

under the United Nations. No single VCS is 

available to cover all the hazard 

communication issues 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 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 

Four consensus standards were relied upon 

for various provisions in the emergency 

temporary standard, but no one consensus 
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

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 Lay-Up 

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. 

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 -

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 nine individual consensus 

standards used in this rule.

Government Standard: OSHA’s Respirable Crystalline Silica Standard for 

Construction [Incorporated: 2016]

Voluntary Standard Rationale

ASTM’s E 2625 – 09, Standard Practice for 

Health Requirements Relating to Occupational 

Exposure to Respirable Crystalline Silica for 

Construction and Demolition Activities

Rationale for not using: OSHA’s standard 

includes a number of requirements that differ 

from the specifications in the ASTM standard 

because the requirements in the OSHA 

standard better effectuate the purposes of the 

OSH Act and protect employees from the 

significant risks posed by exposures to 

respirable crystalline silica (silica). The 

major differences include: 
Both standards contain tables that specify 

control measures and respiratory protection 

for several common construction tools and 

tasks. OSHA’s table (Table 1) differs from 

the ASTM tables in several respects; the 

OSHA standard divides respirator 

requirements according to duration of tasks 

and includes short duration tasks. Gives 

employers required to do exposure 

assessment a choice between complying with 

a scheduled monitoring approach or a 

performance-oriented approach. Requires a 

written plan to be reviewed annually; made 

available to employees, their representatives, 

OSHA and NIOSH upon request; address 

restricting access and requires a competent 

person to implement the plan. 

Differences between the medical surveillance 

programs include, the ASTM standard 

triggers medical surveillance for employees 

exposed above the PEL or other occupational 

exposure limit for 120 or more days a year, 

while the OSHA standard triggers medical 

surveillance for employees who are required 

to use a respirator under the silica standard 

for 30 or more days a year. Medical 

examinations to be conducted within 30 days, 

spirometry testing is mandatory, an X-ray 

classification of 1/0 triggers referral to a 

specialist, tuberculosis testing for the initial 

examination of all employees who qualify for 

medical surveillance, allows employees to 

make their own placement decisions and the 

OSHA standard withholds medical 

information from the employer because of 

privacy concerns. 

Hazard communication and training 

specifications differ from requirements in the 

OSHA standard in the following ways, 

requires training of all employees covered by 

the standard. The OSHA standard is more 

performance-based in order to allow 

flexibility for employers to provide training. 
Some training topics differ. 

Recordkeeping specifications in the standard 

differ in that the ASTM standard specifies 

that medical and exposure records be retained 

for 40 years or for duration of employment 

plus 20 years.

Government Standard: OSHA’s Respirable Crystalline Silica Standard for General 

Industry and Maritime [Incorporated: 2016]

Voluntary Standard Rationale

ASTM’s E 1132 – 06, Standard Practice for 

Health Requirements Relating to Occupational 

Exposure to Respirable Crystalline Silica

Rationale for not using: OSHA’s standard 

includes a number of requirements that differ 

from the specifications in the ASTM standard 

because the requirements in the OSHA 

standard better effectuate the purposes of the 

OSH Act and protect employees from the 

significant risks posed by exposures to 

respirable crystalline silica (silica). The 

major differences include: 

The OSHA standard gives employers 

required to do exposure assessment a choice 

between complying with a scheduled 

monitoring approach or a performanceoriented approach, requires employers to 

establish regulated areas, requires a written 

plan to be reviewed annually and made 

available to employees, their representatives, 

and OSHA and NIOSH upon request. 

Differences between the medical surveillance 

program include, that the ASTM standard 

triggers medical surveillance for employees 

exposed above the PEL or other occupational 

exposure limit (OEL) for 120 or more days a 

year, while the OSHA standard triggers 

medical surveillance for employees exposed 

at or above the action level (half the PEL) for 

30 or more days a year. That the medical 

examinations to be conducted within 30 days, 

spirometry testing is not optional, X-ray 

classification of 1/0 triggers referral to a 

specialist, requires tuberculosis testing for the 

initial examination of all employees who 

qualify for medical surveillance, allows 
employees to make their own placement 

decisions and the OSHA standard withholds 

medical information from the employer 

because of privacy concerns.

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 run-off 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 State (DOS)

Government Standard: The 2017 OBO Design Standards [Incorporated: 2016]

Voluntary Standard Rationale

2015 International Building Code The 2017 OBO Building Code adopts the 

2015 International Building Code (IBC) as 

amended by the 2017 OBO International 

Codes Supplements (OBO-ICS). The 2017 

ICS adds material that is not covered in the 

2015 IBC but introduces the material in an 

industry-standard format so that the users are 

easily able to locate OBO-specific 

requirements. 

Similarly, OBO provides master specification 

sections in an industry-standard format where 

no industry master exists, such as for Forced 
Entry / Ballistic Resistant (FE/BR) windows 

and doors.

Agency: Department of Transportation (DOT)

Government Standard: 49 CFR 571.102, Transmission shift position sequence, starter 

interlock, and transmission braking effect (2005) [Incorporated: 2016]

Voluntary Standard Rationale

SAE J915 This regulation was issued on July 1, 2005. 

SAE J915, “Automatic TransmissionsManual Control Sequence,” published on 

July 1, 1965, and updated on March 9, 2017. 

NHTSA has not incorporated this standard 

because its content currently relies on 49 

CFR 571.102 and 571.114, and the SAE J915 

abstract also states that some portions of the 

standard are unique and may not represent 

current common practices within the user 

community. NHTSA is evaluating industry 

standards to inform the next steps of any 

revisions to its regulations.

Government Standard: 49 CFR 571.114, Theft protection and rollaway prevention 

(2006) [Incorporated: 2016]

Voluntary Standard Rationale

SAE J2948 NHTSA published this regulation on April 7, 

2006. SAE Recommended Practice, SAE 

J2948 "Keyless Ignition Control Design" was 

published on January 13, 2011. NHTSA 

reviewed and referenced SAE J2948 in an 

NPRM it issued on December 12, 2011, and 

is considering whether to finalize this 

regulatory action.

Government Standard: 49 CFR 571.123, Motorcycle controls and 

displays [Incorporated: 2016]

Voluntary Standard Rationale

ISO 2575 NHTSA first published this regulation on 

April 12, 1977. ISO 2575, “Road vehicles --

Symbols for controls, indicators and telltales,” was published in 2004, and specifies 

symbols for use on vehicle controls and 

indicators. On November 26, 2014, NHTSA 

issued an NPRM proposing to allow the use 

of an ISO 2575 warning label for ABS failure 
indication. NHTSA is considering whether to 

finalize this regulatory action.

Government Standard: 49 CFR 571.129 New non-pneumatic tires for passenger cars 

(1990) [Incorporated: 2016]

Voluntary Standard Rationale

SAE J918c This regulation was published on July 20, 

1990. Although not incorporated by 

reference, the performance and test 

requirements are based upon SAE 

recommended practice, “Passenger Car Tire 

Performance,” J918c, last updated on May 1, 

1970. NHTSA is evaluating industry 

standards to inform the next steps of any 

revisions to its regulations.

Government Standard: 49 CFR 571.138, Tire pressure monitoring systems 

(2005) [Incorporated: 2016]

Voluntary Standard Rationale

SAE J2657 NHTSA published this regulation on April 8, 

2005. SAE J2657, Tire Pressure Monitoring 

Systems for Light Duty Highway Vehicles, 

was published on December 16, 2004. While 

SAE J2657 was not incorporated in the final 

rule, the regulation has many commonalities. 

However, SAE J2657 does not contain 

requirements or test procedures for a 

malfunction indicator, and requires different 

levels of rigorousness. NHTSA is evaluating 

industry standards to inform the next steps of 

any revisions to its regulations.

Government Standard: 49 CFR 571.207, Seating Systems [Incorporated: 2016]

Voluntary Standard Rationale

SAE J879; SAE J879B This regulation was published on April 8, 

2005. Although not incorporated by 

reference, the test procedures and 

performance requirements are based on SAE 

J879, “Passenger Car Front Seat and Seat 

Adjuster,” published on November 1, 1963, 

and SAE J879B, “Motor Vehicle Seating 

Systems,” published on July 1, 1968. 

NHTSA is evaluating industry standards to 

inform the next steps of any revisions to its 

regulations.
Government Standard: 49 CFR 571.226, Ejection Mitigation [Incorporated: 2016]

Voluntary Standard Rationale

SAE J2568; BSI AU 209 This regulation was published on January 19, 

2011. SAE J2568 - Intrusion Resistance of 

Safety Glazing Systems for Road Vehicles 

was published on April 24, 2001 and BSI AU 

209 - Vehicle Security was published in 

August 1995. NHTSA studied the test 

procedures and performance requirements in 

these standards, but did not adopt them 

because they did not meet NHTSA’s safety 

objectives and in some cases, were costlier. 

NHTSA is evaluating industry standards to 

inform the next steps of any revisions to this 

regulation.

Government Standard: 49 CFR 571.302 Flammability of Interior Materials 

(1971) [Incorporated: 2016]

Voluntary Standard Rationale

ASTM D5132; SAE J369 This regulation was published on December 

2, 1971. Although not incorporated by 

reference, these standards are technically 

equivalent to the regulation: ASTM D5132, 

“Standard Test Method for Horizontal 

Burning Rate of Polymeric Materials Used in 

Occupant Compartments of Motor Vehicles,” 

published in 1994 and SAE J 369, 

“Flammability of Polymeric Interior 

Materials - Horizontal Test Method,” 

published on March 1, 1969. NHTSA 

initiated a research program in 2016 to 

evaluate the test procedures of the industry 

standards to inform the next steps of any 

revision to this regulation.

Government Standard: 49 CFR 571.304, Compressed natural gas fuel container integrity 

(1974) [Incorporated: 2016]

Voluntary Standard Rationale

ANSI/CSA NGV2 The standard was published on September 

26, 1994 and was based on ANSI/CSA 

NGV2, “Basic requirements for compressed 

natural gas vehicle fuel containers.” NHTSA 

started a research program in 2015 to 

evaluate the performance tests in the revised 

version of NGV2 and also in the Global 

Technical Regulation No. 13, “Hydrogen and 
fuel cell vehicles.” NHTSA will use the 

research to inform the next steps of any 

revision to this regulation.

Government Standard: 49 CFR 571.305, Electric-powered vehicles: electrolyte spillage 

and electrical shock protection (2000) [Incorporated: 2016]

Voluntary Standard Rationale

SAE J1766 The standard was issued on September 27, 

2000, and was based on SAE J1766, 

“Recommended practice for electric and 

hybrid electric vehicle battery systems crash 

integrity testing,” published on February 1, 

1996. NHTSA reviewed the 2016 revision of 

SAE J1766 and other industry standards for 

electric vehicles in an NPRM it issued on 

March 10, 2016, and is considering whether 

to finalize this regulatory action.

Government Standard: 49 CFR Part 563, Event Data Recorders (2006) [Incorporated: 

2016]

Voluntary Standard Rationale

SAE J1698–1; IEEE P1616 This regulation was issued on August 28, 

2006. NHTSA did not incorporate either the 

SAE Vehicle Event Data Interface (J1698–1) 

Committee or the IEEE Motor Vehicle Event 

Data Recorder (MVDER) working group 

(P1616) because both standards were 

developed and issued during the rulemaking 

process. NHTSA is evaluating industry 

standards to inform the next steps of any 

revisions to its regulations.

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 on-road 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.

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 10 [Incorporated: 2015]

Voluntary Standard Rationale
ANSI/ASME PTC 19-10-1981—Part 10, ISO 

10396:1993 (2007), ISO 12039:2001, ASTM 

D5835-95 (2007), ASTM D6522-00 (2005), 

CAN/CSA Z223.2-M86 (1999), CAN/CSA 

Z223.21-M1978, ASTM D3162-94 (2005)

The use of these voluntary consensus 

standards would not be practical with 

applicable law due to a lack of equivalency, 

documentation, validation data and other 

important technical and policy 

considerations.

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 

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.

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 18 [Incorporated: 2016]

Voluntary Standard Rationale

ASTM D6420-99 (2010) “Test method for 

Determination of Gaseous Organic Compounds by 

Direct Interface Gas Chromatography/Mass 

Spectrometry”

The use of this voluntary consensus standard 

would not be practical due to a lack of 

equivalency, documentation, validation data 

and other important technical and policy 

considerations. The EPA did not receive 

comments during the notice and comment 

period that caused us to alter the standards 

and methods in the final permits.
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 Surface-Mounted 

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 29 for the determination of the concentration of 

Hg [Incorporated: 2015]

Voluntary Standard Rationale

ASTM D6784-02 (2008), “Standard Test Method 

for Elemental, Oxidized, Particle-Bound and Total 

Mercury in Flue Gas Generated from Coal-Fired 

Stationary Sources (Ontario Hydro Method)”

The use of this voluntary consensus standard 

would be more expensive and is inconsistent 

with the final Hg standard that was 

determined using EPA Method 29 data.

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 311 "Analysis of Hazardous Air Pollutant 

Compounds in Paints and Coatings by Direct Injection Into a Gas 

Chromatograph" [Incorporated: 2015]

Voluntary Standard Rationale

ASTM D6438 (1999)—Standard Test Method for 

Acetone, Methyl Acetate, and 

Parachlorobenzotrifluoride Content of Paints and 

Coatings by Solid Phase Microextraction-Gas 

Chromotography

This methods is impractical as an alternative 

to EPA Method 311 because it targets 

chemicals that are VOC and are not HAP

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 5 [Incorporated: 2015]

Voluntary Standard Rationale

ASME B133.9-1994 (2001), ISO 9096:1992 

(2003), ANSI/ASME PTC-38-1980 (1985), 

ASTM D3685/D3685M-98 (2005), CAN/CSA 

Z223.1-M1977

The use of these voluntary consensus 

standards would not be practical with 

applicable law due to a lack of equivalency, 

documentation, validation data and other 

important technical and policy 

considerations.

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 

With an Electron Capture Detector

ASTM D5317-98 specifies acceptance 

windows for the initial demonstration of 

proficiency for laboratory fortified blank 

samples that are as 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 7E [Incorporated: 2015]

Voluntary Standard Rationale

ANSI/ASME PTC 19-10-1981—Part 10, ISO 

10396:1993 (2007), ASTM D5835-95 (2007), 

CAN/CSA Z223.2-M86 (1999)

The use of these voluntary consensus 

standards would not be practical with 

applicable law due to a lack of equivalency, 
documentation, validation data and other 

important technical and policy 

considerations.

Government Standard: EPA Method 9 [Incorporated: 2016]

Voluntary Standard Rationale

ASTM D7520-09 “Standard Test Method for 

Determining Opacity of a Plume in the Outdoor 

Ambient Atmosphere”

The use of this voluntary consensus standard 

would not be practical due to a lack of 

equivalency, documentation, validation data 

and other important technical and policy 

considerations. The EPA did not receive 

comments during the notice and comment 

period that caused us to alter the standards 

and methods in the final permits.

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 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, 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 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, 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, KKKA-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-A1822E 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, freeze-drying, 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 3280 - Manufactured Home Construction and Safety 

Standards [Incorporated: 2000]

Voluntary Standard Rationale

ANSI A119.1 - Recreation Vehicles and NFPA 

501C - Standard on Recreational Vehicles

HUD-Unique Manufactured Home 

Construction & 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: Lifecycle Data Requirements Guide, Second Edition (January 18, 

2002) (NARA standard) [Incorporated: 2016]

Voluntary Standard Rationale

RDA Steering Committee: Resource Description 

and Access--2015 Revision

The voluntary standards of the Resource 

Description and Access (RDA) 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 NUREG1736, “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 NUREG1736, “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.