An MOU would affirm ANSI's responsibility and improve its ability to represent U.S. interests in international, nontreaty standards-setting bodies. Although the Trade Agreements Act of 1979 recognizes that U.S. representation in international standardization should be by the private U.S. member of the relevant organization, it does not specify mechanisms for government cooperation with ANSI and U.S. industry in preparing U.S. positions for international standards activities.105
An MOU would also be an appropriate vehicle for addressing a frequent source of tension in public–private standards cooperation. This source is the low level of government financial support for voluntary standards organizations, including ANSI. Government agencies make significant contributions to voluntary standardization, as shown by the previously discussed data on NIST staff participation in outside standards committees. ANSI incurs significant expenses, however, in providing the administrative overhead for coordinating the U.S. voluntary standards system. ANSI dues to ISO and IEC are a particularly large expense.
Government participation and use of the system implies a responsibility to pay a share of the overhead expenses associated with the system. Among federal agencies, however, only the Departments of Agriculture, Defense, Energy, and Veterans Affairs, along with NIST, the U.S. Geological Survey, FCC, FDA, GSA, the NASA, and the National Archives are dues-paying members of ANSI. EPA, CPSC, the Nuclear Regulatory Commission, and the Departments of Housing and Urban Development, Labor, and Transportation are among prominent government standards developers that are not ANSI members.106 Although membership dues represent 23 percent of ANSI gross revenues (including publications sales), U.S. government dues are less than half of 1 percent of ANSI revenues.107
Cooperation and understanding between the private standards system and the federal government appear to be improving. A formal MOU clearly would not create understanding where none exists. It would, however, create a formal framework for continuation of cooperation in the future. This framework would prove valuable as circumstances change, new issues emerge, and informal working relationships among individuals in each sector are replaced through changeover of key personnel.
The U.S. system for developing formal product and process standards is complex and diverse. It incorporates, for example, cooperative efforts by technical experts to write voluntary standards on a consensus basis. These activities generally take place in the context of consensus-based standards-developing organizations, according to guidelines for due process and open participation of interested parties. Many standards developers are accredited by the American National Standards Institute, a private, nonprofit federation of business, government,