standards in two respects. First, they are mandatory—by law, by regulation, or by contractual obligation in government purchasing. Second, federal standards are not generally written by committees of volunteer experts through a consensus-seeking procedure. Administrative procedures law requires public notice of proposed rules in the Federal Register and response to received comments, but agencies' statutory obligations require government employees to make any final decisions in setting government standards.

Increasingly, however, government agencies are meeting their statutory obligations not by developing government-unique standards but, rather, by participating in and adopting the end products of voluntary consensus standards development. In 1982, the Office of Management and Budget (OMB) issued Circular A-119, "Federal Participation in the Development and Use of Voluntary Standards."89 Revised in October, 1993, Circular A-119 notes,

Government functions often involve products or services that must meet reliable standards. Many such standards, appropriate or adaptable for the Government's purposes, are available from private voluntary standards bodies. Government participation in the standards-related activities of these voluntary bodies provides incentives and opportunities to establish standards that serve national needs, and the adoption of voluntary standards, whenever practicable and appropriate, eliminates the costs to the Government of developing its standards. Adoption of voluntary standards also furthers the policy of reliance upon the private sector to supply Government needs for goods and services, as enunciated in OMB Circular No. A-76, entitled Performance of Commercial Activities.90

The policy expressed in Circular A-119 has strong potential to produce savings to government in developing standards. Participation of government experts such as NIST research staff in consensus standards committees raises the level of technical competence applied to the standardization effort. Committees serve as a working forum for public-private cooperation in the development of standards to meet public needs, while imposing the lowest possible costs and restrictions on technological innovation in industry. The circular encourages government use of performance standards over design standards for this reason.91

In public procurement, use of consensus standards in place of government-unique specifications has proven effective at both reducing government costs and improving the competitive strength of U.S. industry. Pilot efforts at DoD in replacing military with commercial item specifications have saved procurement funds and reduced burdens on suppliers of maintaining separate commercial and military production capabilities.92 One example is the procurement of thermal insulation for buildings. The Naval Facilities Engineering Command (NAVFAC) reviewed government and consensus standards in this area and found many redundant standards.93 In 1982, at NAVFAC's request, ASTM formed a technical committee to help convert military and civilian federal standards for thermal insulation to ASTM standards. Of an identified 59 candidate government specifications,

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