General Services Administration (GSA) Fiscal Year 2020 Agency Report

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

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

and in Conformity Assessment Activities” and the National Technology Transfer and Advance Act 

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

information about your agency’s standards and conformity assessment related activities are available

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

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

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

and contributes to greater reliability on product quality. 

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

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

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

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

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

GSA maintains a Standards website: http://www.gsa.gov > Buying & Selling > Purchasing Programs > 

GSA Global Supply > Supply Standards > Index of Federal Specifications, Standards, and Commercial 

Item Descriptions

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

consensus standards during FY 2020. Please note that GUS which are still in effect from previous years 

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

in use (previous years and new as of this FY): 5

(1) Government Unique Standard

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

Voluntary Standard

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

Services Ambulances

Rationale

The ASTM Standard Practice for Design, Construction, and Procurement of Emergency Medical Services 

(EMSS) Ambulances (ASTM F2020) is not practical for use, and therefore GSA uses the Federal 

Specification for Ambulances (KKK-A-1822E). GSA has determined the ASTM document is not practical 

for use for the following reasons:
1) GSA has determined that ASTM F2020 contains specific practices that are technically and 

economically impractical to use for the acquisition of commercial based vehicles because the document 

is financially burdensome and technically ineffective. Specifically at issue is the ASTM Standard 

Specification for Medical Oxygen Delivery Systems for EMS Ground Vehicles, F1949-99 which is inclusive 

to ASTM F2020.

2) GSA has determined that ASTM F2020 is impractical because it is defined as a standard practice which 

is ambiguous and an ineffective substitution for specifications or requirements for use in GSA contract 

documents. ASTM F1949-99, a Standard Specification for Medical Oxygen Delivery Systems for EMS 

Ground Vehicles is included in ASTM F2020. ASTM F1949-99 is defined as a “standard specification”.

3) GSA has determined that ASTM F2020 is impractical because ASTM International does not provide 

interpretations and written guidance to their publications which is inadequate and less useful. ASTM 

members may only offer personal opinions. ASTM offers no mechanism to support timely resolution of 

conflicts between contractor and procurement organizations on technical subject matter. GSA provides 

interpretations, clarifications and engineering determinations when required. This is one of the most 

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

4) The AMD has determined through consensus that it is impractical to replace the Federal Specification 

for Ambulances, KKK-A-1822E with the ASTM Standard Practice, F2020. GSA initiated a survey to collect 

public responses from a wide range of constituent users of the Federal Ambulance Specification. The 

National Association of Emergency Medical Technicians (NAEMT), the International Association of Fire 

Chiefs (IAFC), the National Association of State EMS Directors (NASEMSD) and the National Association 

of EMS Physicians universally accept and support the continued use of the Federal Specification. The 

AMD and constituent users have determined that it is impractical to replace the Federal Specification for 

Ambulances, KKK-A-1822E with the ASTM Standard Practice, F2020 because rule promulgation is 

complex and costly. Staff and administration resources would need to be diverted in each state EMS 

office to implement the change in statutes, public health codes, rules and regulations.

5) GSA has determined that ASTM F2020 is impractical because it is complex to GSA procurement 

efforts. While the current ASTM document recites many of the requirements from the Federal 

Specification, a future ASTM document would likely have diverging requirements unacceptable to the 

Government. This was verified by a member of the ASTM F2020 subcommittee at the September 4, 

2003 meeting of the Federal Interagency Committee on Emergency Medical Services.

(2) Government Unique Standard

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

UL 768

Rationale

Federal Specification FF-L-2937 – Combination Lock, Mechanical used in lieu of UL 768 Combination 

Locks. The lock covered by the GUS is used for the protection of classified information and weapons. The 

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

(3) Government Unique Standard

MIL-DTL-22520G, Crimping Tools, Wire Termination, General Specification for [Incorporated: 2019]

Voluntary Standard

SAE AS22520, Crimping Tools, Wire Termination, General Specification for

Rationale

Temporary use of GUS continued in FY2019 to allow transition to VCS.

(4) Government Unique Standard

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

Voluntary Standard

SAE/AMS 2431 - Peening Media, General Requirements

Rationale

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

applications that are not present in the voluntary standards.

(5) Government Unique Standard

MIL-I-81969B, Installing and Removal Tools, Connector Electrical Contact, General Specification for 

[Incorporated: 2019]

Voluntary Standard

SAE AS81969, Installing and Removal Tools, Connector Electrical Contact, General Specification for

Rationale

Temporary use of GUS continued in FY2019 to allow transition to VCS.