FY 2012 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 

The CPSC rules go beyond the provisions of the ASTM voluntary standard 

to provide increased protection to children from the risk of death and 
Specification for Bunk Beds 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 Pensky- Martens

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 

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 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: 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 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 Performance-Based 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.

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 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 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 L-shaped 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 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 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, 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 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 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: 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 FireFighting 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.