One of the technologies commercialized since the advent of the NTTAA of interest to industrial hygienists is the use of optical fluorescence to determine beryllium in dust by wipe, in air sampling media, and in bulk samples, developed by the Department of Energy. This technology is the focus of analytical methods from NIOSH that describe the use of field-portable fluorometry to analyze beryllium in air (method 7704) and in surface wipes (method 9110). ASTM methods also use optical fluorescence technology for the determination of beryllium in the workplace (method D7202) and in soil, rock, sediment, and fly ash (method D7458). Other IH-related technologies facilitated by the NTTAA include soaps, wipes, and cleaning liquids for removing lead and other metals, oxides, and radioisotopes from skin developed by NIOSH; a colorimetric screening method for lead on skin and wipes also developed by NIOSH (see NIOSH method 9105); and the Polymerase Chain Reaction (PCR) mold identification methods based on an EPA patent used by environmental microbiology laboratories accredited by AIHA Laboratory Accreditation Programs, LLC. The NTTAA also requires that government agencies use consensus standards developed by nonprofit standards development organizations whenever possible. Section 12 of the law states that, except after evaluation to the contrary by the U.S. Office of Management and Budget, “all Federal agencies and departments shall use technical standards that are developed or adopted by voluntary consensus standards bodies, using such technical standards as a means to carry out policy objectives or activities determined by the agencies and departments.” Further, the Act states that “Federal agencies and departments shall consult with voluntary, private sector, consensus standards bodies and shall, when such participation is in the public interest and is compatible with agency and departmental missions, authorities, priorities, and budget resources, participate with such bodies in the development of technical standards.” In an amplification of the NTTAA in 2017, the executive branch of the federal government expressed its preference for consensus standards. A revised instruction published by the Office of Management and Budget as Circular A-119 “establishes a preference for the use of voluntary consensus standards in lieu of government-unique standards” and directs federal agencies to adopt voluntary consensus standards wherever possible to avoid development of unique government standards. The OMB instruction states that “all Federal agencies must use voluntary consensus standards in lieu of government-unique standards in their procurement and regulatory activities, except where inconsistent with law or otherwise impractical.” OMB also requires federal agencies to show a “strong preference for using voluntary consensus standards” and states that these policies are intended to encourage federal agencies to benefit from the expertise of the private sector, promote federal agency participation in standards bodies to support the creation of standards that are useable by federal agencies, and minimize reliance on government-unique standards where an existing standard would meet the objectives of the federal government.

As a result, federal agencies and their representatives, and federal employees and contractors, have become more involved in the creation and revision of consensus standards, both internationally and domestically. Consensus standards have begun to appear with more regularity in federal directives, guidelines, regulations, and requirements by citation or by reference. Outside of government, the courts have heard more arguments for compliance to consensus standards in tort cases; and, of direct interest to the IH communities, an unofficial hierarchy for the use of standards for analytical methods has developed. That hierarchy, in descending order of preference of application, is:

The consensus standards process provides the following benefits:

WHO DEVELOPS CONSENSUS STANDARDS? For IH professionals, the most active and most recognized sources of IH-applicable consensus standards are the International Organization for Standardization, the American National Standards Institute, and ASTM International. ISO is an independent, non-governmental international organization with a membership of 162 national standards bodies and a Central Secretariat in Geneva, Switzerland. ISO members represent individual countries, and each country has one vote for final approval of an ISO standard. To date, ISO has published more than 22,000 international standards. Examples of ISO standards of interest to IH professionals include:

One of the more visible ISO examples, at least for sampling and laboratory analysis, is ISO/IEC 17025:2017, General Requirements for the Competence of Testing and Calibration Laboratories, which is the basis for accreditation of sampling and laboratory activities worldwide. (For more information, see the article “New Requirements for Labs” in the August 2018 Synergist.) ISO recognizes one organization within each of its member countries to oversee development and approval of consensus standards. As the ISO representative for the U.S., ANSI oversees the development of voluntary consensus standards for products, services, processes, systems, and personnel. The organization also coordinates U.S. standards with international standards so that American products and services can be used worldwide. More than 230 standards developers are accredited by ANSI including the Acoustical Society of America; the American Society of Heating, Refrigerating and Air-Conditioning Engineers; the American Society of Mechanical Engineers; the American Society of Safety Professionals; ASTM International; the U.S. Department of Defense; ISO; the International Safety Equipment Association; the National Fire Protection Association; and SAE International. ANSI itself does not develop standards but recognizes standards created by its member organizations. These consensus standards are sometimes referred to as “ANSI standards.” All ANSI-recognized standards from accredited standards developers, including ISO standards, are available from ANSI. Examples of ANSI American national standards of interest in industrial hygiene include: 

ASTM International, as an ANSI-accredited developer of consensus standards that are used worldwide, is a significant contributor of standards of interest to IHs. ASTM standards include the following types:

Of direct interest to IH professionals are the standards under the jurisdiction of ASTM Committee D22 on Air Quality. The committee has subcommittees on Quality Control; Workplace Air Quality; Indoor Air; Sampling and Analysis of Asbestos; Assessment, Sampling, and Analysis of Microorganisms; and Sampling and Analysis of Lead for Exposure and Risk Assessment. These subcommittees have more than 130 current standards that may be of interest to IHs. Also, ASTM Committee E34 on Occupational Safety and Health has over 20 standards, primarily for metalworking fluids. The NTTAA requires that the National Institute of Standards and Technology report to OMB on federal agencies’ use of consensus standards. Within the report, federal agencies briefly describe their activities undertaken to carry out provisions described in the NTTAA and OMB Circular A-119. All laboratories accredited by AIHA-LAP are accredited to a consensus standard, ISO/IEC 17025. AIHA-LAP itself conforms to ISO 17011, Conformity Assessment—Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies, and is recognized as such within the framework of the International Laboratory Accreditation Cooperation. One of the requirements for laboratories is to participate in proficiency testing programs such as the AIHA Proficiency Analytical Testing Programs, LLC. AIHA PAT Programs is a proficiency sample provider accredited to ISO 17043, Conformity Assessment—General Requirements for Proficiency Testing. WHAT'S IN IT FOR YOU? The IH professional can benefit from consensus standards in many ways:

Initial decision making. Guides such as ASTM E1370 for air sampling and ASTM D7659 for surface sampling describe options to evaluate when developing a sampling plan. Similarly, ANSI/ISEA Z87.1 provides selection criteria for eye- and face-protection devices. Consistency and reproducibility. Using applicable and appropriate consensus standards to propose, plan, conduct, document, analyze, report, and archive processes for IH projects and the resulting data creates a consistent and reproducible record of the work. This makes the process for reaching a conclusion and developing recommendations much easier. Data quality objectives. Consensus standards can be used to establish appropriate and consistent data quality objectives, or DQOs, for the results of sampling and analysis. Guidance for DQOs was developed by EPA and has been incorporated into consensus standards such as ASTM D7659 and in the widely-used Visual Sample Plan from the Pacific Northwest National Laboratory. Data comparability. When consensus standards are used for sampling and laboratory analysis, comparison of the data is much easier. Trending and control banding can also be more consistent across multiple locations or organizations. Data defensibility. Perhaps most important, the records of the work and processes used, the analysis of the collected data, and the conclusions reached are more easily defended to superiors and clients—and in court—when consensus standards are applied and followed. Imagine providing testimony that says the work was done according to a consensus standard; the data were analyzed and reported according to a consensus standard; and the conclusions reached, recommendations made, and actions taken were according to a consensus standard. Consistent application and use of consensus standards make the requirements for admissibility much easier to achieve. Participation in their development. IH professionals can participate in the consensus standards process by joining a standards development organization such as ASTM International or ASSP. Being involved in the creation and maintenance of national standards presents a valuable insight into the current state of the profession; the current thinking on possible changes in the application of standards; current conduct of government and commercial research, and other professional work; possible future professional developments and future changes to the profession; and the standard-making and standard-amending process. Participation in the standards process results in knowledge of what is currently happening and a unique view of what is coming. All could be important for career development and career enhancement.    KENNETH T. (KENN) WHITE, MS, MM, CIH, CSP, FAIHA, is the principal of Consultive Services in Virginia Beach, Va. He is a three-time recipient of the AIHA Edward J. Baier Technical Achievement Award, chair of the ASTM International Subcommittee D22.12 on Sampling and Analysis of Lead for Exposure and Risk Assessment, and a member of the AIHA Sampling and Laboratory Analysis Committee, serving as chair of the Environmental Lead Subcommittee. MICHAEL J. (MIKE) BRISSON, MS, PMP, FASTM, is a fellow technical advisor at Savannah River National Laboratory, Aiken, S.C. He is past chair of the AIHA Sampling and Laboratory Analysis Committee, chair of ASTM International Committee D22 on Air Quality, chair of ISO Technical Committee 146, Subcommittee 4, on Air Quality General Aspects, and convener of three ISO working groups.  Send feedback to The Synergist.