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Comments sent to SOS_RFI@nist.gov "Standardization feedback for Sub-Committee on Standards.''

Ajit Jillavenkatesa, 100 Bureau Drive, 

Stop 1060, Gaithersburg, MD 20899-1060, 301-975-8519, 

ajit.jilla@nist.gov.

Response for: National Institute of Standards and Technology, Department of Commerce, request for information:

"Effectiveness of Federal Agency Participation in Standardization in Select Technology Sectors for National Science and 

Technology Council's Sub-Committee on Standardization"

Response:

The Occupational Safety and Health Administration needs to be encouraged to incorporate by reference existing 

and future ANSI and ISEA voluntary consensus standards. The ANSI and ISEA standards must remain current to 

within a five-year period. These voluntary consensus standards are developed by persons with expertise and with 

public comment. Neither the public nor the voluntary standards committee members are paid for their 

contributions. 

The Occupational Safety and Health Act has no provisions for their government unique standards to be current. To 

utilize these and other voluntary consensus standards would enable OSHA to redirect their resources from 

standards writing to education and enforcement, or to as direct cost savings (estimated from OPM 2010 pay tables,

5 GS/GM 15's + 15 GS 14's + 15 GS 13's + 5 (contractors and administrative staff average GS 9) equivalent ≈ $

3,790,600 per year. An estimated cost of $75 per voluntary consensus standard or a site purchase for public use

could be less than the expense to produce an OSHA standard, on average of every six to 17 years.).

Several voluntary consensus standards related to safety and health procedures for construction workers exist or 

are soon to be published for performing electrical transmission work, nuclear facility
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rehabilitation/reconditioning/new construction at existing facilities, occupational and emergency health protections

for those not in the medical professions, emergency planning and incident command interaction, etc., such as:

A10.3 Powder-Actuated Fastening Systems

A10.17 Safe Operating Practices for Hot Mix Asphalt (HMA) Construction

A10.19 Pile Installation and Extraction Operations

A10.20 Ceramic Tile, Terrazzo, and Marble Work

A10.21 Safe Construction Demolition of Wind Generation/Turbine Facilities (under development)

A10.23 Safety Requirements for the Installation of Drilled Shafts (under development)

A10.25 Sanitation in Construction

A10.26 Emergency Procedures for Construction Sites (under development)

A10.27 Hot Mix Asphalt Facilities

A10.29 Aerial Platforms in Construction (under development)

A10.32 Personal Fall Protection Used in Construction and Demolition Operations

A10.33 Safety and Health Program Requirements for Multi-Employer Projects

A10.34 Public Protection

A10.39 Construction Safety and Health Audit Program

A10.40 Reduction of Musculoskeletal Problems in Construction

A10.41 Equipment Operator and Supervisor Qualifications and Responsibilities (under development)

A10.42 Rigging Qualifications and Responsibilities in the Construction Industry

A10.43 Confined Spaces in Construction (under development)

A10.44 Lockout/Tagout in Construction

A10.46 Hearing Loss Prevention

A10.47 Highway Construction Safety

A10.48 Communication Tower Erection (under development)

A10.49 Control of Health Hazards (under development)

Direct utilization of voluntary consensus standards by OSHA would benefit many industries in addition to the 

construction industry. The DOL reports for the Executive Order A119 (OMB Circular A-119) and the "National 

Technology Transfer and Advancement Act of 1995" (Pub. L. 104-113), beginning after the issuance of these 

documents in 1997, show few incorporated or fully utilized referenced voluntary consensus standards. In these

DOL reports, one ANSI, A10 standard (A10.13) has been cited by DOL for the past eight years (not including 2010)
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as being incorporated by reference, however, this voluntary consensus standard neither is incorporated by 

reference nor appears in the OSHA standards (see 29 CFR 1926, Subpart R.)

Selected Sections From, "Department of Labor (DOL) Fiscal Year 2009 Agency Report." Columns with different numbers reflect number changes 

in the numbering of the Agency Reporting forms; NA indicates the question changed content or no longer appeared.

Government Unique 

Standard: ...

2009, #2-9 

2008, #2-8

2007, #2-8 

2006, #2-6

2005, #2-5

2004,#1-4 

2003, #1-2 

2002, #1-2 

2001, #2

2000, #1

1999,#1

1989,#1

1997, #1 

Comment by 

commenter

#3 ... (VCS) your 

agency substituted 

for Government 

Unique Standards 

(GUS) ... 

#9 Please provide 

any conformity 

assessment activities 

...

# 10 ... uses 

... guidance 

...update ... 

2009 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...

2008 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...

2007 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...

2006 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...

2005 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...

2004 (Incorporated: 

2002) ... ANSI 

Not "Incorporated 

by Reference"

0 NA No comment ... ...no...no...
4

A10.13

2003 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 #6-1 reports 

its use ... ... 

Response: 

Only first time 

use ...

#9 ... examples or 

case studies of 

standards successes

... attempts to update 

over 200 national 

consensus standards 

that were 

incorporated by 

reference ... over 30 

years old.

#10 Note, 

different 

question than 

#10 above.

2002 (Incorporated: 

2002) ... ANSI 

A10.13

Not "Incorporated 

by Reference"

0 #6-1 reports 

its use ... ... 

Response: 

Only first time 

use ...

No comment. #10 Note, 

different 

question than 

#10 above.

2001 0 NA Now #2

Response, 0

NA #8 ...examples ...

Response, None.

#10 Note, 

different 

question than 

#10 above.

2000 0 NA Now #2

Response, 0

NA #8 ...examples ...

Response, None.

#10 Note, 

different 

question than 

#10 above.

1999 0 NA Now #2

Response, 0

NA NA NA

1998 0 NA Now #2

Response, 0

NA NA NA

1997 0 NA Now #2

Response, 0

NA NA NA

There is an industry need for updated occupational safety and health standards. The use of voluntary consensus 

standards addresses this need for guidance that addresses new hazards, equipment, processes, and procedures. The 

Occupational Safety and Health Administration should be encouraged to utilize this professional resource.

Sincerely,
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Camille Villanova, Occupational Safety and Health Consultant

P. O. Box 9804

Alexandria, VA 22304

202-255-6194