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ANSI Responds to CRE "Good Government" Recommendations
CRE, in response to an invitation from ANSI, recommended changes in the process by which Standards Development Organizations (SDOs) produce consensus standards intended for regulatory application. CRE recommended to ANSI's Executive Standards Council (ExSC) that SDOs developing standards intended for regulatory use incorporate the policies and procedures found in the federal "good government" laws. After consideration, the ExSc declined to adopt CRE's recommendations.
Read the ANSI letter to CRE
Read the ANSI ExSC Response
Comment on Item
Ms. Anne Caldas
Director
Procedures and Standards Administration
American National Standards Institute
11 West 42nd Street
New York, NY 10036
Dear Ms. Caldas:
Thank you very much for the
opportunity to submit, for consideration by ANSI's Executive Standards
Council, proposed revisions to the ANSI Guide for the Preparation
of Standards for Use in Regulations (ExSC 4643).
As the ANSI Guide notes,
"Government is now one of the principal users of consensus standards."
Furthermore, government agencies are increasingly reliant on voluntary
consensus standards for regulatory and procurement programs.
ANSI’s recently revised MOUs with NIST and OSHA are indicative
of the importance of private standards to government agencies.
However, as ANSI’s National Standards Strategy recognizes,
"Government agencies demand evidence that voluntary consensus
standards meet high principles so that they can rely on them for both
regulation and procurement."
The following addition
to the ANSI Guide is designed to provide closer conformity
between ANSI requirements for standards development procedures and the
federal "good government" laws which regulate the regulatory process.
The changes are necessary to ensure that American National Standards
are able to demonstrate the "high principles" required by
government.
Recommended Revision: ANSI
Guide for the Preparation of Standards for Use in
Regulations
BACKGROUND (Third Paragraph)
The key to achieving greater
recognition of consensus standards by government agencies is the
preparation of documents in a manner and form that fulfills the
public's needs. To ensure that documents intended for
regulatory application fulfill these needs and can be readily
adopted by government, SDOs should incorporate into their own
operating procedures the policies and processes found in the laws
which Congress enacted to regulate the regulatory process. The key
"good government" laws which SDOs should adhere to when developing
standards intended for regulatory application are: the
Administrative Procedure Act; the Paperwork Reduction Act; the
Regulatory Flexibility Act; the Data Access law (contained in the
FY 1999 Omnibus Appropriations Act, P.L. 105-277); and the Data
Quality law (contained in the FY 2001 Consolidated Appropriations
Act, P.L. 106-554). This ANSI Guide has been prepared to
address these needs. provide additional
guidance to assist SDOs in meeting public needs.
Rationale
The laws referenced above
mandate a series of requirements that federal agencies must adhere to
when developing regulations. Incorporation of these requirements into
the process of developing voluntary consensus standards intended for
regulatory application will make it substantially easier for
government agencies to rely on the standards. Failure of SDOs to adopt
these Congressional requirements would mean that agencies would have
to comply with the procedural and analytic requirements themselves,
thus duplicating much of the standard development process and
substantially reducing the efficiencies associated with utilizing
consensus standards.
If you or the ExSC have any questions regarding CRE's
recommendations, please feel free to contact me for additional
information.
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Sincerely,
Jim J. Tozzi, Ph.D.
Chairman, Board of Advisors
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cc:
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A. Marasco
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J. McCabe
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J. Thompson
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