regulations. Public sector certification programs serve three principal functions.39 The first is to create a level playing field for commerce by assessing and enforcing standards for the quality of products for sale. An example is U.S. Department of Agriculture (USDA) certification of meat and poultry quality. Certification against USDA standards is voluntary, but the marketing advantage it provides is sufficient incentive for many producers to participate.40 This category of activity relates closely to the federal role in maintaining reference standards as a public service, as discussed in Chapter 2.

A second set of federal programs certifies products against health, safety, and environmental regulations. Not all federal regulatory standards are accompanied by third-party certification requirements. In many industries, regulators accept the manufacturer's declaration of conformity to regulations. The automotive industry, in which the National Highway and Traffic Safety Administration (NHTSA) accepts manufacturers' declarations, is one example. Independent testing is generally performed by NHTSA only in the event of an actual or suspected product failure.41 Numerous other federal certification programs exist in connection with the broad mandates of regulatory agencies, such as the Federal Aviation Administration, for aircraft components, and the Food and Drug Administration, for pharmaceutical products.42

The third category of federal certification programs concerns product testing for public procurement. The Department of Defense (DoD) is the main agency conducting this type of activity. For example, DoD requires manufacturers to show conformity to military specifications through independent testing, resulting in DoD certification. Through the Qualified Products List (QPL) program, DoD also conducts its own testing and certification of parts, materials, and products in order to guarantee their quality for military use. The QPL program also has the aim of streamlining the procurement process, by eliminating the need for manufacturers to recertify products for each separate purchase.43

No currently available data indicate the total cost to manufacturers and their customers of federal, state, and local certification mandates associated with regulatory and procurement standards. Apart from several directories of public and private programs compiled by NIST at several-year intervals, no comprehensive source of information about certification exists.44 Determinations to impose regulatory and procurement certification decisions, which add layers of conformity assessment to affected manufacturing processes and commercial transactions, should be weighed against the benefits to the public interest of added assurance. The lack of data on which to base these decisions is, accordingly, cause for concern.

The proliferation of programs in the federal, state, local government, and private sectors suggests strongly, nevertheless, that significant savings could be achieved through consolidating U.S. certification programs. In a $ 10.5 billion independent testing industry, plus an as-yet-unmeasured level of expenditure linked to manufacturer's internal testing against certification criteria, streamlining

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