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GBlist: Consensus standards - ASTM, ASHRAE, etc.
>Date: Tue, 22 Apr 1997 08:21:46 -0700
>To: Marc.J.Rosenbaum@valley.net (Marc J. Rosenbaum),
>From: Hal Levin <hlevin@cruzio.com>
>Subject: Consensus standards - ASTM, ASHRAE, etc.
>Bcc: Art McIvor, GPC10 Committee Members, George Luciw, Harriet Burge,
Steve Taylor, Saul Krimsly, John Talbott, John Girman
>
>At 07:41 AM 4/22/97 EDT, Marc Rosenbaum wrote:
>
>[snip]
>
>>Which brings me to a short rant - I have become increasingly suspicious of
>>"consensus standards" coming out of organizations like ASTM and ASHRAE. It
>>seems as though any party with enough bucks loads up the committee to make
>>certain their interests are represented. So what is held forth as a "best of
>>our knowledge" document is really just a lowest common denominator political
>>football. Some of these committees sound as though they work more like the US
>>Congress than a group of researchers/practitioners seeking the truth. Bion's
>>post about ASTM's green building std confirm my uneasy suspicions. And
you all
>>may be exhorted to "get involved" - sure, on our own time, sitting next to the
>>on-the-clock rep from Philip Morris or Dupont.
>>
> * Since I sit on ASHRAE's standard 62 committee, also chair the
committee writing "Guideline for Achieving Acceptable Indoor Environments,"
and chair ASTM's subcommittee D22.05 on Indoor Air, I will offer some
observations in response to Marc's observations.
> Generalizations are dangerous. Consider what "consensus" means. The
real issue is the composition of the committee and the rules under which it
operates. Things were much worse until the late 1970s when the FTC
considered adopting rules governing the standards development process by
private organizations. The FTC proposed rules were to require a "sunshine"
process in which the public would have access to the agendas and and minutes
of such organizations and would be able to submit information that would
have to be considered. Prior to that time, processes of bodies like the
model building code organizations were very closed. Most of the FTC's
proposal covered standards that are in the building industry. The FTC held
hearings (I testified as a friendly witness on behalf of the FTC's
proposal). The FTC gathered over 90,000 pages of testimony and evidence, and
it was on its way toward adoption when Congress, under pressure from the
building industry, castrated the FTC, removing its authority to promulgate
the proposed rule (as well as one that would have limited the amount of
sugar-containing products that could be advertised on children's television
programs, the so called "kids-vid" rule). Following that, reforms were
instituted at ASHRAE, ASTM, ANSI, and elsewhere. NIBS was established by
Congress to try to provide a forum for some of the debate, but even NIBS is
often too dependent on industry to be "independent" of its influence. In
spite of the reforms, tthe potential for abuse never disappeared completely.
A case-by-case analysis is necessary.
> There are large differences between the two organizations'
processes for establishing membership. ASTM membership is open to anyone,
although there are some built-in limits to the number of representatives
from a given organization or even industry. But these are not uniform across
committees, and the rules of any specific committee must be consulted to
determine the composition and potential for abuse. There are committees in
ASTM that suffer from a lack of "public interest" representation although in
theory, this should not happen. But it costs time and effort to participate
effectively, and when one casts a negative ballot, it is important to be at
the committee meeting to argue the position in order to be over-ridden as
"non-persuasive." Obviously it costs not only time but also money to attend
committee metings. If you don't show up, it is easy to dismiss your
arguments if no one who is there really cares. In committee D22, only about
10% of the membership actually comes to the meetings, and the quorum
requirements are low enough to allow those who can afford to attend to
prevail. This is unfortunate. Some committees are dominated by industry and
the arguments are among members of the industry. Other committees have more
scientists and consultants on them. Generalizations are dangerous.
> My own opinion is that ASTM committee E50 - Environmental
Assessment - (where Green buildings work resides) may present potential
abuses more than some others (such E6 on Building Performance or D22 on
Sampling and Analysis of Atmospheres). ASTM is currently addressing some
recent abuses or attempts at abuse in E50 by changing the rules for adopting
"provisional standards."
> ASHRAE's committees vary. Standard 62 1989, "Ventilation for
Acceptable Indoor Air Quality," is being revised by a committee that is
comprised of people who range from design engineers to IAQ technical experts
to industry advocates. My own feeling is that industry concerns play too big
a role. Clearly the tobacco industry is focused on this standard, but only
one committee member is an openly acknowledged industry representative.
There is also a member who is a known anti-tobacco advocate, a lawyer. Many
tobacco industry consultants and representatives attend committee meetings
and they submitted lengthy, detailed comments on the public review draft of
the revised standard. They oppose the draft revision since it does not
provide for compliance if smoking occurs. If the standard is adopted into
code, it becomes law, and the industry obviously does not want to see that
happen. The current standard permits a "moderate" amount of smoking.
> The ASHRAE committee I chair is not so contentious because we will
produce a non-regulatory document, a guideline. The composition of the
committee is in no way industry-dominated or susceptible to excessive
influence. The membership is basically academics, researchers, scientists,
and engineers. Other ASHRAE committees vary as well.
> There is a real world basis for Marc's concerns. Perhaps one could
say that the more important a committtee's output, the more it affects
industry, the more likely industry will play or attempt to play an
influential role. Neither ASHRAE nor ASTM are perfectly insulated from such
efforts. They, like Congress, are part of the "American way" - one that has
made economic interests extremely powerful at the cost of other
considerations - human and environmental.
>
> Hal
>
>
Hal Levin <hlevin@cruzio.com>
2548 Empire Grade, Santa Cruz, CA 95060
408 425 3946 fax 408 426 6522
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