Certification Requirements: New Guidance Should Encourage Transparency in
Agency Decisionmaking (Letter Report, 09/24/1999, GAO/GGD-99-170).

Pursuant to a congressional request, GAO reviewed federal agencies'
certification requirements for goods and services, focusing on: (1) the
extent and variety of certification activities in the federal
government; (2) the extent to which there are policies, procedures, or
guidance governing those activities, either governmentwide or within
selected agencies; and (3) an agency certification procedure that could
serve as an example or best practice for other agencies.

GAO noted that: (1) federal agencies engage in a large number and wide
variety of certification-related activities; (2) the National Institute
of Standards and Technology (NIST) publishes directories listing more
than 200 federal government procurement and regulatory programs in which
agencies provide or require certification, accreditation, listing, or
registration; (3) these directories provide only a partial inventory of
agencies' activities because they focus primarily on certifications of
products and services and they do not cover individual procurement
actions in which agencies require particular certifications; (4)
certification activities also vary across multiple dimensions, including
the origin of the requirements, their targets, which entities do the
certifying, whether the certifications are mandatory or voluntary, and
the extent to which there is reciprocity with or recognition of other
certifications or requirements; (5) specific guidance regarding the
selection of specific requirements or certifying organizations is
limited; (6) federal procurement law imposes some limits on agencies'
use of certification requirements, restricting the use of certification
requirements to instances in which the requirements are specifically
imposed by law or the agencies show a particular need and, if possible,
allow for alternatives; (7) some agencies have established certification
procedures and criteria for individual programs, and agency officials
identified some related policies, procedures and guidance that can
affect their certification activities; (8) there is no governmentwide
guidance, or agencywide guidance in the five agencies that GAO reviewed,
regarding all types of certification requirements; (9) NIST has prepared
draft guidance on conformity assessment activities, including
certification, which it plans to issue for public comment; (10) one best
practice that GAO has supported in the regulatory arena, transparency of
decisionmaking, also appears applicable to certification requirements,
particularly given the complexity and diversity of certification
activities and organizations; (11) in the certification actions that GAO
examined, the criteria that the agencies used to establish a particular
requirement or select a particular certifying organization were very
clear in some instances but not clear in others; (12) other agencies'
certification actions were not as transparent and certification bodies
that were not selected raised questions about the criteria that agencies
used; and (13) in each of those cases, agency officials were able to
provide the rationale for their actions.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-99-170
     TITLE:  Certification Requirements: New Guidance Should Encourage
	     Transparency in Agency Decisionmaking
      DATE:  09/24/1999
   SUBJECT:  Procurement
	     Product evaluation
	     Reporting requirements
	     Private sector practices
	     Institution accreditation
	     Standards and standardization
	     Federal procurement
IDENTIFIER:  OSHA Nationally Recognized Testing Laboratory Program
	     NMFS Voluntary Seafood Inspection Program
	     FDA Mammography Certification Program

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    United States General Accounting Office GAO               Report
    to the Chairman, Committee on Small Business House of
    Representatives September 1999    CERTIFICATION REQUIREMENTS New
    Guidance Should Encourage Transparency in Agency Decisionmaking
    GAO/GGD-99-170 United States General Accounting Office
    General Government Division Washington, D.C.  20548 B-281675
    September 24, 1999 The Honorable James M. Talent Chairman,
    Committee on Small Business House of Representatives Dear Mr.
    Chairman: Federal agencies use many certification requirements to
    ensure quality in the goods and services they purchase. For
    example, before purchasing computer or electrical equipment, an
    agency may require that prospective sellers obtain a certification
    from Underwriters Laboratories or another organization that the
    product is safe.1 An agency may also require that individuals in
    certain professions meet specific educational standards or be
    approved as competent by a particular organization before
    providing a service. There is no official definition of
    "certification" that is applicable to the activities of all
    federal agencies. However, the term generally refers to a process
    of providing written assurance that a product, process, service,
    organization, or individual conforms to specified requirements or
    standards for product quality, process reliability, or
    professional competence. Although certification requirements are
    intended to provide a measure of quality assurance, they can also
    engender concern on the part of affected parties. For example,
    businesses or individuals that wish to provide products or
    services to the government might need to obtain more than one
    certification to meet the requirements of different agencies.
    Also, an agency might select a particular certification
    organization while not accepting certifications in the same
    subject area from other organizations with similar qualifications.
    Because of these kinds of concerns regarding the potential effects
    of federal certification requirements on small businesses, you
    asked us to describe (1) the extent and variety of certification
    activities in the federal government; (2) the extent to which
    there are policies, procedures, or guidance governing those
    activities, either governmentwide or within selected agencies; and
    (3) an agency certification procedure that could 1Underwriters
    Laboratories, Inc. (UL) is an independent, not-for-profit product
    safety testing and certification organization. A "UL" mark on a
    product indicates that UL found that samples of the product met
    UL's safety requirements. The marks are commonly found on
    appliances, computer equipment, heaters, fuses, and other
    products. Page 1
    GAO/GGD-99-170 Certification Requirements B-281675 serve as an
    example or "best practice" for other agencies. We defined
    certification broadly in this review to include those activities,
    methods, and programs that agencies use to ensure conformance to
    standards, even if the agencies did not use the term
    certification. Therefore, this report also includes certification-
    related activities, such as accreditation, recognition, and
    conformity assessment. Federal agencies engage in a large number
    and wide variety of Results in Brief    certification-related
    activities, which is at least partially because of the number and
    diversity of the standards upon which they are based. The National
    Institute of Standards and Technology (NIST) publishes directories
    listing more than 200 federal government procurement and
    regulatory programs in which agencies provide or require
    certification, accreditation, listing, or registration.2 However,
    these directories provide only a partial inventory of agencies'
    activities because they focus primarily on certifications of
    products and services; they do not cover individual procurement
    actions in which agencies require vendors or contractors to have
    particular certifications. Certification activities also vary
    across multiple dimensions, including the origin of the
    requirements, their targets, which entity or entities do the
    certifying, whether the certifications are mandatory or voluntary,
    and the extent to which there is reciprocity with or recognition
    of other certifications or other organizations' requirements.
    Specific guidance regarding the selection of specific requirements
    or certifying organizations is limited. Federal procurement law
    imposes some limits on agencies' use of certification
    requirements, restricting the use of certification requirements in
    solicitations for government contracts to instances in which the
    requirements are specifically imposed by law or the agencies show
    a particular need and, if possible, allow for alternatives. Some
    agencies have established certification procedures and criteria
    for individual programs, and agency officials identified some
    related policies, procedures, and guidance that can affect their
    certification activities. However, there is currently no
    governmentwide guidance-or agencywide guidance in the five
    agencies we reviewed-regarding all types of certification
    requirements. NIST has prepared draft guidance for executive
    branch agencies on conformity assessment activities, including
    certification, which it plans to issue for public comment later
    this year. 2Congress established NIST (formerly the National
    Bureau of Standards) in 1901 to support industry, commerce,
    scientific institutions, and all branches of the government. It is
    an agency of the Department of Commerce, and its primary mission
    is to promote economic growth in the United States by working with
    industry to develop and apply technology, measurements, and
    standards. Page 2
    GAO/GGD-99-170 Certification Requirements B-281675 One "best
    practice" that we have supported in the regulatory arena-
    transparency of agency decisionmaking-also appears applicable to
    certification requirements, particularly given the complexity and
    diversity of certification activities and organizations in the
    United States.3 In the certification actions that we examined, the
    criteria that the agencies used to establish a particular
    requirement or select a particular certifying organization were
    very clear in some instances but not clear in others. For example,
    in implementing its mammography program, the Food and Drug
    Administration (FDA) published detailed procedures and criteria
    for certification of personnel and facilities providing
    mammography services, as well as the approval of accreditation
    bodies. Other agencies' certification actions were not as
    transparent, and certification bodies that were not selected
    raised questions about the criteria that the agencies used.
    However, in each of those cases, agency officials were able to
    provide us with the rationale for their actions. A fundamental
    difficulty in discussing federal agencies' certification
    Background    requirements is that there is no official definition
    of the term in the federal government. In fact, a NIST official
    told us that there are almost as many definitions of a federal
    certification program as there are federal agencies. Different
    organizations may also use other terms to refer to the concept of
    certification, such as accreditation, registration, approval, or
    listing. These terms have specific and different meanings in some
    contexts but are used interchangeably in others. In any case, the
    nomenclature can be confusing. For example, in 1989 we reviewed
    laboratory accreditation requirements for 20 different programs
    and found that these programs used 10 different terms for
    accreditation, with at least 18 different meanings. 4
    Certification, accreditation, recognition, conformity assessment,
    and related terms all refer to types of standards-related
    activities, so a definition of "standards" can serve as a useful
    starting place. The International Organization for Standardization
    (ISO) defines standards as documented agreements containing
    technical specifications or other precise criteria to be used
    consistently as rules, guidelines, or definitions of
    characteristics to ensure that materials, products, processes, and
    3See, for example, Regulatory Reform: Changes Made to Agencies'
    Rules Are Not Always Clearly Documented (GAO/GGD-98-31, Jan. 8,
    1998); and Dietary Supplements: Uncertainties in Analyses
    Underlying FDA's Proposed Rule on Ephedrine Alkaloids
    (GAO/HEHS/GGD-99-90, July 2, 1999). 4Laboratory Accreditation:
    Requirements Vary Throughout the Federal Government (GAO/RCED-89-
    102, Mar. 28, 1989). Page 3
    GAO/GGD-99-170 Certification Requirements B-281675 services are
    fit for their purpose.5 ISO defines certification as the procedure
    by which a third party gives written assurance that a product,
    process, or service conforms to specified requirements or
    standards. Accreditation, according to ISO, refers to the
    procedure by which an authoritative body gives formal recognition
    that a body or person is competent to carry out specific tasks. In
    the context of certification, an accreditation body might accredit
    a certification body, such as a testing laboratory, as competent
    to carry out certification activities-in a sense, certifying the
    certifiers. Recognition is a term that is relatively new to
    conformity assessment activities in the United States, and it
    refers to designation by a government entity that an accreditation
    program is competent. Conformity assessment is the broadest term
    for these types of activities. According to the National Academy
    of Sciences, conformity assessment is the determination of whether
    a product or process conforms to particular standards or
    specifications. It may include such activities as sampling,
    testing, inspection, certification, registration, accreditation,
    and recognition. There are a great many standards or criteria for
    product quality, process Numerous Standards         reliability,
    or professional competence. NIST estimated that in the United
    Underlie Certifications    States alone, approximately 49,000
    voluntary standards have been developed by more than 620
    organizations. The agency said this estimate does not include "a
    much greater number of procurement specifications. . . as well as
    mandatory codes, rules, and regulations containing standards
    developed and adopted at federal, state, and local levels." NIST
    also pointed out that numerous foreign, regional, and
    international organizations produce standards of interest and
    importance to American businesses. For example, ISO has issued
    more than 10,000 international standards. Agency officials told us
    that use of these and other international standards has become
    increasingly common in the United States. The standards underlying
    certifications cover a wide range of products, processes, and
    professions. Some are product quality or safety standards, such as
    the American National Standards Institute (ANSI) standard for
    manually operated gas valves or the UL standard for communications
    cables. There are also standards for the performance and
    reliability of particular processes, as in ISO standards for
    quality management systems. Professional standards, such as the
    American Medical Association's standards in medical practice,
    research, and education, are used to assure 5 ISO is an
    international organization that writes standards. Established in
    1947, ISO is a nongovernmental federation of national standards
    bodies from about 130 countries. Its work results in international
    agreements that are published as International Standards. Page 4
    GAO/GGD-99-170 Certification Requirements B-281675 the
    qualifications and competence of individuals in specific
    disciplines or fields. The preceding examples also illustrate that
    standards can come from many sources. They can be established by
    industry or professional consensus standard-setting bodies, by
    governments through statutes or regulations, or by international
    standard-setting bodies. Certifications of products, processes,
    and services provide information on Certifications Reflect
    whether they can meet certain levels of quality, safety, or
    performance. Diversity of Standards    However, certifications of
    people or organizations focus on an evaluation and designation of
    competence and qualifications. In professional and technical
    fields, certifications confirm the skills and knowledge of
    individuals who meet specific requirements (e.g., a certified
    public accountant). The professional certification process
    typically involves passing examinations and meeting other
    educational and/or experiential requirements. The choice of
    standards, the type of certification program, and the
    certification methodology used to assess conformity all have a
    significant impact on the validity and value of the information
    provided by a given certification. The total number of
    certification programs in the United States is unknown, but NIST
    has identified at least 178 private sector organizations that have
    product certification programs. In addition, the National
    Organization for Competency Assurance (NOCA) has identified at
    least 1,700 organizations based in the United States with programs
    for the certification or accreditation of individuals.6 The
    National Academy of Sciences and NIST have each noted that there
    is no central coordination of conformity assessment and related
    activities in the United States. Perhaps as a result,
    certification requirements can be duplicative and costly for those
    who must be certified or accredited. The fees for each
    certification exam can range from a few hundred dollars to over a
    thousand dollars, and the associated costs for annual fees and
    recertification in future years may be substantial. NIST officials
    told us that some laboratories must obtain multiple different
    accreditations-which often evaluate many of the same common
    elements in their evaluation processes-in order to provide testing
    services. NIST had found that laboratories desiring to be
    accredited or designated nationwide to conduct electrical safety-
    related testing of construction materials had to gain the
    acceptance of at least 43 states, over 100 local jurisdictions,
    the International Conference of Building Officials, the Building
    Officials and Code Administrators, the Southern Building Code
    Congress International, a number of federal agencies, and several
    large corporations. 6NOCA is a private sector national umbrella
    organization in the area of certification. Page 5
    GAO/GGD-99-170 Certification Requirements B-281675 Congress has
    attempted to address some of the concerns about redundant
    certification requirements. For example, the Technology Transfer
    and Advancement Act of 1995 requires greater coordination of
    conformity assessment activities and attempts to facilitate mutual
    recognition among conformity assessment programs. Also, in June
    1999 Congress amended the Fastener Quality Act in part to address
    concerns about potentially burdensome, costly, and duplicative
    testing and certification procedures that would have been imposed
    on industry. The amended law no longer requires NIST to approve
    organizations that accredit fastener testing laboratories. The
    amendments also exempt those fasteners already subject to the
    Federal Aviation Administration's (FAA) regulation. However,
    despite such concerns, it also should be recognized that some
    certification programs and requirements foster opportunities for
    small businesses.  For example, the Nationally Recognized Testing
    Laboratory (NRTL) Program implemented by the Occupational Safety
    and Health Administration (OSHA) recognizes private sector
    laboratories that meet the necessary qualifications specified in
    program regulations.  OSHA officials pointed out that this program
    has given a number of small testing laboratories in the United
    States the opportunity to provide types of services that only a
    few organizations provided before the program went into effect.
    Our objectives in this review were to describe (1) the extent and
    variety of Objectives, Scope, and certification activities in the
    federal government; (2) the extent to which Methodology
    there are policies, procedures, or guidance governing those
    activities, either governmentwide or within selected agencies; and
    (3) an agency certification procedure that could serve as an
    example or "best practice" for other agencies. To address these
    objectives, we interviewed officials and obtained documentation
    from five federal agencies in which the Committee had expressed an
    interest: the Departments of Transportation (DOT) and Veterans
    Affairs (VA); and, within the Department of Health and Human
    Services, the Centers for Disease Control and Prevention (CDC),
    FDA, and the National Institutes of Health (NIH). We also
    contacted officials in the Office of Management and Budget's (OMB)
    Office of Information and Regulatory Affairs, NIST, and the Office
    of Government Ethics (OGE) because of their responsibilities
    related to the issue of certification. We also interviewed and
    obtained documents from officials of NOCA and its related
    accreditation body, the National Commission for Certifying
    Agencies (NCCA). There are some important scope limitations to our
    review. Although we defined the term certification broadly to
    include such issues as Page 6
    GAO/GGD-99-170 Certification Requirements B-281675 accreditation,
    recognition, and conformity assessment, the report does not cover
    those Federal Acquisition Regulation certifications (e.g., the
    Certification of Final Indirect Costs and the Certification of
    Nonsegregated Facilities) that might be included as standard
    solicitation provisions and contract clauses but are not related
    to conformity with technical or professional standards.7 The scope
    of our first objective was governmentwide. However, as agreed with
    the Committee, it was not our intention to develop a comprehensive
    listing of every possible certification-related activity and
    requirement of federal agencies. Our intent was to illustrate the
    extent and variety of such activities in the federal government.
    As agreed with the Committee, our review of agency- specific
    policies, procedures, or guidance under the second objective was
    limited to selected agencies, including CDC, DOT, FDA, NIH, and
    VA. To address our third objective, we again focused primarily on
    specific certification examples from the five selected agencies.
    The examples cited in agencies other than the five selected for
    more in-depth review were limited to ones cited in published
    reports or suggested by persons we interviewed. We obtained only
    limited information on the certification requirements in agency
    procurement actions. Our choices of examples to highlight as best
    practices represent subjective decisions based on our observations
    and work in the regulatory arena. We conducted this review between
    November 1998 and August 1999 at the headquarters offices of the
    above-mentioned agencies in the Washington, D.C., area in
    accordance with generally accepted government auditing standards.
    We provided a draft of this report to the Secretaries of Commerce,
    Health and Human Services, Transportation, and Veterans Affairs
    and the Director of OMB for their review and comment. Their
    responses are presented at the end of this letter, along with our
    evaluation. Federal agencies engage in both a large number and a
    wide variety of Agencies Engage in a     certification-related
    activities. The certifications differ across several Wide Variety
    of          dimensions, including the origins of the requirements,
    their targets, which entity or entities do the certifying, whether
    the certifications are Certification-Related    mandatory or
    voluntary, and the extent to which there is reciprocity with
    Activities               or recognition of other certifications or
    other organizations' requirements. The extent of agency
    involvement in the process can also vary, ranging from instances
    in which an agency might simply apply a certification requirement
    established by other entities to cases in which the agency is
    actively involved in developing and enforcing a specific
    requirement. 7See 41 U.S.C. 425(c) for limitations on the use of
    requirements for certification by offerors or contractors in the
    Federal Acquisition Regulation. Page 7
    GAO/GGD-99-170 Certification Requirements B-281675 We did not
    attempt to develop a compendium of every federal agency Federal
    Certification        certification or certification-related
    activity and requirement, and it would Activities Are Numerous
    be difficult to do so given the absence of a common understanding
    and and Diverse                  definition of the term
    "certification requirement" in the federal government. However, it
    is clear that federal agencies engage in a large number of
    certification-related activities. For example, NIST publishes
    directories that list more than 200 federal procurement and
    regulatory programs in which agencies provide or require some form
    of certification. The NIST directories provide only a partial
    inventory of agencies' activities, though, because they primarily
    focus on certification of products and services. Also, the
    directories do not cover individual procurement opportunities in
    which agencies require a vendor or contractor to have a particular
    certification, accreditation, or registration in order to
    participate. Agencies' certification requirements also vary in a
    number of ways, reflecting the variety of the underlying
    standards. One such dimension is the scope of the certification
    programs and requirements. For example, FAA's comprehensive system
    of certifications for the civil aviation system is quite broad,
    covering numerous categories of equipment, personnel, and
    facilities. On the other hand, one of the Environmental Protection
    Agency's (EPA) requirements (pursuant to section 609 of the Clean
    Air Act) is very specific, focused solely on operators who service
    motor vehicle air conditioners and requiring them to be certified
    under an EPA-approved program before offering their services.
    Another narrowly focused certification requirement is in FDA
    regulations that are designed to prevent botulism. The regulations
    require that a "processing authority" must certify the competency
    of "low-acid canned food retort operators" (i.e., the operators of
    heating and pressure cookers). Federal agencies' certification-
    related activities also vary with regard to the extent of agency
    involvement in the certification process. For example, an agency
    might be deeply involved in developing and/or enforcing a specific
    certification requirement. On the other hand, the agency might
    simply apply a requirement established by other entities, such as
    when an agency incorporates technical or professional
    certification requirements by reference in solicitations for
    specific products or services. Other ways that certification
    requirements vary include the following. *  The target of
    certification. *  Product *  Profession Page 8
    GAO/GGD-99-170 Certification Requirements B-281675 *  Process *
    Facility or organization *  Who does the certification. *  Federal
    government *  State or local governments *  Joint commissions *
    Private sector, professional, or trade organizations *  Self-
    certification *  The origin or basis of the certification
    requirement. *   Statutory requirements *  Agency regulatory
    actions *  International agreements *  Industry consensus or
    nonconsensus requirements *  Procurement actions *  The degree of
    compulsion on those being certified. *  Voluntary *  Mandatory *
    Required for program participation *  Whether other certifications
    are accepted or recognized. *  Only the specified certification is
    accepted *  Other certifications accepted or recognized According
    to NIST officials, the risk associated with a particular
    regulatory action or procurement can be an important factor
    influencing choices within these various dimensions. If the
    perceived risk is low, for instance, an agency might determine
    that certification is voluntary and accept a manufacturer's self-
    certification. However, if the risk associated with failure to
    meet standards is serious, the agency might choose to make
    certification mandatory and accept certification from only a
    federally recognized laboratory. Appendix I describes a number of
    specific agency certification programs and requirements that
    illustrate these kinds of differences. Some of the requirements
    differ on multiple dimensions. For example, the National Marine
    Fisheries Service within the Department of Commerce has a program
    for the inspection and certification of seafood products and
    processing operations. The Seafood Inspection Program is a
    voluntary program carried out pursuant to the Agricultural
    Marketing Act of 1946, as Page 9
    GAO/GGD-99-170 Certification Requirements B-281675 amended;
    involves inspection by licensed federal and state agents; and
    provides certification recognized by other federal, state, and
    foreign government agencies as well as some private and
    international organizations. In contrast, a provision in an NIH
    procurement solicitation stated that a prospective contractor's
    supervisors responsible for inspection of the agency's biohazard
    cabinets "must be NSF accredited biohazard cabinet field
    certifiers."8 This provision is based on an industry consensus
    standard, targets professional competence, involves accreditation
    by a private sector third party, represents a mandatory
    requirement for prospective contractors, and recognizes only one
    source for the certification. Federal procurement law establishes
    some legal boundaries on the Little Guidance Exists certification
    requirements used in federal procurement. In addition, agency on
    Agency                        officials pointed out that their
    general procedures and practices for rulemaking and procurement
    can serve a useful role in notifying the public Certification
    and soliciting feedback on proposed certification requirements.
    However, Requirements                     there is little in the
    way of general policies, procedures, or guidance governing how
    agencies should establish certification requirements or select
    certification bodies, except at the level of some individual
    agency programs. Agency officials told us that they primarily
    viewed certification as an industry or professional concern rather
    than as a federal issue, and therefore they tended to rely on the
    "industry standard" or "nationally recognized" requirements. NIST
    has prepared draft guidance for federal agencies on conformity
    assessment activities, including certification. This guidance is
    currently under review at OMB, and NIST expects to publish it for
    public comment later this year. The Competition in Contracting Act
    of 1984 provides that a solicitation for Procurement Law Sets
    a government contract may include a restrictive provision only to
    the Some Boundaries on               extent that the provision is
    authorized by law or is necessary to satisfy the Certification
    Requirements       agency's needs. Some agency-specific
    acquisition regulations mirror the Competition in Contracting
    Act's limitations on the use of unnecessarily restrictive
    certification requirements. For example, VA's regulations allow
    requirements that offerors conform to technical standards that are
    generally recognized and accepted in the industry involved.
    However, if there is a choice of laboratories available to certify
    the quality of the 8NSF refers to NSF International, founded in
    1944 as the National Sanitation Foundation. NSF is an independent,
    not-for-profit organization active in standards development and
    certification programs related to public health safety and
    protection of the environment. Page 10
    GAO/GGD-99-170 Certification Requirements B-281675 product
    involved, the regulations also say that the requirements must not
    indicate that only one laboratory's certificate will be
    acceptable.9 In our bid protest decisions, we have generally not
    objected to a requirement that an item conform to a set of
    standards adopted by a nationally recognized organization in the
    field or a requirement for independent laboratory certification
    that such standards are met. However, we have found requirements
    unduly restrictive if they require approval by specific
    organizations without recognition of equivalent approvals.10 The
    absence of an endorsement by a particular private organization
    should not automatically exclude offers that would otherwise meet
    a procuring agency's needs. These procurement provisions
    notwithstanding, there is little in the way of Certification
    Guidance Is    general policies, procedures, or criteria governing
    how agencies should Currently Limited to         proceed in
    establishing certification requirements or selecting certifying
    Specific Programs            bodies. Neither the agency officials
    we interviewed nor agency documents we reviewed identified any
    governmentwide guidance or, for the selected agencies we reviewed,
    agencywide guidance focused specifically on certification
    activities. The only specific certification guidance that we could
    identify was limited to particular programs. In some of these
    programs-such as FDA's Mammography Program; the Coast Guard's
    requirements for vessel design, inspection, and certification; and
    OSHA's NRTL Program-the agencies have established detailed
    procedures and criteria governing their certification requirements
    and/or the selection of certifying bodies. In general, however,
    officials in the five agencies that we contacted tended to view
    certification as an industry or professional issue rather than a
    federal one. Consequently, the agencies' selection of specific
    certification requirements or certifying organizations were driven
    more by the particular profession, industry, or market sector
    involved than by federal considerations. For example, officials
    from VA and NIH said that their agencies commonly rely on national
    consensus bodies and their "nationally recognized" or "industry
    standard" certifications for a given sector. NIST officials said
    that a common finding from their meetings and workshops is that
    people tend to use the certification or accreditation program with
    which they are most familiar. 9 48 C.F.R. 852.211-75. 10 See, for
    example, Aegis Analytical Laboratories, Inc., B-252511, July 2,
    1993. Page 11
    GAO/GGD-99-170 Certification Requirements B-281675 NIST Has
    Developed Draft        NIST has taken a first step toward
    developing governmentwide Certification Guidance
    certification guidance. In response to requirements in the
    National Technology Transfer and Advancement Act of 1995 and OMB
    Circular A- 119, and with input from the Interagency Committee on
    Standards Policy (ICSP), NIST has prepared draft guidance for
    issuance by the Secretary of Commerce on conformity assessment
    activities, including certification.11 This draft guidance is
    currently under review at OMB, and NIST expects to publish it in
    the Federal Register for public comment later this year. NIST
    officials explained that the guidance would apply to all agencies
    that set policy for, manage, operate, or use conformity assessment
    activities and results, both domestic and international, except
    for activities carried out pursuant to international treaties. In
    addition to suggesting common terminology and definitions for
    agencies to use, NIST expects the guidance to define agency
    responsibilities in a number of areas, including the following: *
    identifying private sector conformity assessment practices and
    programs and considering use of the results of such practices or
    programs in new or existing regulatory and procurement actions, *
    using relevant guides or recommendations for conformity assessment
    practices published by domestic and international standardizing
    bodies, and *  working with other agencies to avoid unnecessary
    duplication and complexity in federal conformity assessment
    activities. However, NIST officials also pointed out that the
    guidance would not preempt the agencies' authority and
    responsibility to make regulatory or procurement decisions
    authorized by statute or required to meet programmatic objectives
    and requirements. They also said the guidance would not suggest
    that agencies explain why they selected one certification
    requirement or organization over other possible candidates.
    Although there is currently no governmentwide guidance
    specifically on Related Policies and            certification
    requirements, agency officials noted several related policies
    Procedures Also Affect          and procedures that can affect
    those requirements. Those policies and Certification Requirements
    procedures include OMB Circular A-119, federal ethics and
    conflict-of- 11ICSP consists of representatives from each federal
    executive agency and advises the Secretary of Commerce and other
    executive branch agencies on standards policy matters. The
    committee reports to the Secretary through the Director of NIST.
    The publication of the guidance is in response to requirements in
    the National Technology Transfer and Advancement Act of 1995 as
    well as OMB Circular A-119. Page 12
    GAO/GGD-99-170 Certification Requirements B-281675 interest laws,
    and agencies' rulemaking and procurement procedures and
    regulations. OMB Circular A-119 says 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. 12 If
    an agency uses government-unique standards, it must explain why it
    did so in a report to OMB through NIST. The circular also says
    that agencies must consult with voluntary consensus standards
    bodies, both domestic and international, and must participate with
    such bodies in the development of voluntary consensus standards
    "when consultation and participation is in the public interest and
    is compatible with their missions, authorities, priorities, and
    budget resources." Agency officials from each of the selected
    agencies we reviewed noted that employees of their agencies
    commonly participate in such consensus bodies, including ones that
    help to establish certification requirements. Agency employees
    who, at government expense, participate in such activities on
    behalf of the agency must do so as specifically authorized agency
    representatives and are subject to ethics laws regarding
    participation by federal employees in activities of outside
    organizations. However, according to the Office of Government
    Ethics, there is no conflict of interest if an authorized agency
    representative participated in developing a voluntary consensus
    standard and the agency subsequently selected that standard as a
    requirement.13 Circular A-119 does caution, however, that agency
    participation in voluntary consensus bodies does not necessarily
    connote agency agreement with, or endorsement of, decisions
    reached by such organizations. The circular does not apply to
    conformity assessment activities carried out pursuant to treaties,
    which may impose their own obligations on federal agencies. NIST
    officials pointed out that the World Trade Organization (WTO)
    Agreement on Technical Barriers to Trade, in particular, includes
    conformity assessment obligations that apply to federal agencies.
    According to WTO, the intent of this agreement is to ensure that
    regulations, standards, testing, and certification procedures do
    not create 12OMB revised the circular on February 10, 1998, in
    part to make the terminology consistent with the National
    Technology Transfer and Advancement Act of 1995. That act codified
    existing policies in A- 119, established reporting requirements,
    and authorized NIST to coordinate conformity assessment activities
    of agencies. 13 The Office of Government Ethics is a small
    independent agency that has as its mission exercising leadership
    in the executive branch to prevent conflicts of interest on the
    part of government employees and to resolve those conflicts of
    interest that do occur. Page 13
    GAO/GGD-99-170 Certification Requirements B-281675 unnecessary
    obstacles to trade. The agreement includes articles regarding
    procedures for assessment of conformity and recognition of
    conformity assessment by central government bodies. For example,
    the agreement encourages countries to recognize each other's
    testing procedures. Members of WTO are also encouraged to permit
    conformity assessment bodies located in the territories of other
    members to participate in their conformity assessment procedures
    under conditions no less favorable than those accorded to bodies
    within their own territories or the territories of any other
    countries. Agency officials also said that their general
    procedures and regulations governing rulemaking and procurement
    play an important role in certification activities. In particular,
    they noted that such procedures and regulations provide valuable
    opportunities for an agency to inform the public and solicit
    feedback on proposed certification requirements. FDA officials
    said their agency's procedural rules and regulations require them
    to use rulemaking in order to establish an enforceable
    certification requirement. DOT and FDA used the rulemaking process
    in developing or implementing several of the agencies'
    certification requirements. Although DOT and FDA officials
    acknowledged that rulemaking procedures take considerable time and
    effort, they noted that those procedures could also help the
    agencies obtain informed comments and document certification
    decisions. DOT officials said the use of the rulemaking process
    was particularly valuable in the establishment of certification
    requirements for subjects that are new to the department or in
    which DOT has little expertise. For example, proposed departmental
    regulations intended to reduce alcohol misuse by employees in DOT-
    regulated transportation industries included important roles for
    substance abuse professionals (SAPs). In response to public
    comments on the proposed rule, DOT refined and expanded its
    definition of SAPs in the final regulations and said alcohol and
    drug abuse counselors certified by the National Association of
    Alcoholism and Drug Abuse Counselors (NAADAC) Certification
    Commission could serve as SAPs.14 However, agency officials also
    emphasized that rulemaking may not always be a necessary or
    appropriate procedure for making certification decisions. In
    particular, NIH and CDC officials distinguished their research-
    oriented agencies from regulatory agencies, noting that they tend
    14Subsequently, DOT recognized another certifying organization
    that petitioned to be recognized and asked for comment on a
    proposed requirement that certification organizations obtain NCCA
    accreditation for inclusion in the SAP definition. See 64 FR
    29831. Page 14
    GAO/GGD-99-170 Certification Requirements B-281675 to act through
    nonmandatory guidance or recommendations, not through rulemaking.
    DOT officials said that they generally do not use rulemaking
    procedures if certification requirements are part of a one-time
    procurement or contract.  However, they said rulemaking might be
    the appropriate approach if the requirements are part of a
    recurring procurement. Agency officials also noted that
    procurement procedures can play a role in their agencies' choice
    of certification requirements and certifying organizations.
    Contracting officials emphasized the opportunities provided
    throughout the procurement process for prospective bidders to
    question proposed certification requirements and to suggest
    changes or other equivalent certifications that might meet the
    agency's needs. NIH officials noted that in addition to responding
    to the solicitation itself, bidders can comment on the draft
    request for proposal (published to see if there are enough
    sources) and the announcement of forthcoming solicitations to the
    market that appears in the Commerce Business Daily. Officials from
    CDC, FDA, and NIH pointed out that any solicitation could be the
    subject of bid protests if their agencies used procurement
    provisions that some entities believed were too restrictive. As
    noted previously, agency certification actions are numerous and
    vary Transparency of        substantially. Therefore,
    specification of a particular certification "best Certification
    practice" would likely depend on the context of the
    certifications. Rather than attempting to develop criteria for
    selecting among these procedures, Decisionmaking Is a    we
    focused on one practice that we have supported in the regulatory
    "Best Practice"        arena-transparency, or clearly describing
    the basis for agency decisionmaking. Transparency in certification
    decisionmaking is important because those decisions can have
    significant implications for affected parties, but they are
    sometimes made with little public explanation. An agency's
    certification decisions can be transparent either retrospectively
    (explaining why a decision has been made) or prospectively
    (explaining the criteria it will use in making future decisions).
    As noted previously, OMB Circular A-119 requires agencies that
    develop government-unique standards to explain why they did not
    use voluntary consensus standards. However, we are not aware of
    any statutory or regulatory provisions requiring agencies to
    disclose why they selected one voluntary standard, certification,
    or certifying organization over another, or to describe the
    criteria they will to use to make those decisions in the future.
    Page 15                                 GAO/GGD-99-170
    Certification Requirements B-281675 The transparency of the agency
    certification actions that we reviewed Transparency of Agency
    varied dramatically. In some instances, the agencies clearly
    documented Certification Requirements    the criteria that they
    used or planned to use to select particular Varies
    requirements or certifying organizations. Other certification
    decisions were not as transparent, with the criteria less clear or
    well documented. However, agency officials were able to provide us
    with justifications for their actions in these instances during
    our review. FDA's certification requirements in its previously
    mentioned Mammography Program are very transparent. The program's
    regulations published in the Federal Register provide detailed
    procedures and criteria for certification of personnel and
    facilities providing mammography services, as well as the
    procedures and criteria that FDA uses to approve accreditation
    bodies. FDA has developed and publicized the regulations through a
    series of public rulemaking notices, building on procedures and
    criteria promulgated in earlier regulations issued by the
    Department of Education and the Health Care Financing
    Administration within the Department of Health and Human Services.
    The agency also provides ongoing guidance on the implementation of
    this program and its requirements, notifying the public of any
    updates in the guidance through quarterly Federal Register notices
    that announce the availability of and changes in FDA guidance
    documents. DOT has also clearly explained in several of its
    rulemaking documents how it made or planned to make decisions on
    the selection of particular certifying organizations. For example,
    in a 1997 final rule, the Coast Guard allowed an alternative
    inspection compliance method to fulfill requirements for vessel
    inspection and certification.15 Previously, these inspections and
    certifications had to be performed by the Coast Guard. Under the
    alternative, the Coast Guard can issue a certificate of inspection
    based upon reports by a "recognized, authorized classification
    society" that a vessel complies with United States and
    international safety rules, conventions, or other specified
    requirements. In order to receive recognition from the Coast
    Guard, the regulation requires a classification society to meet 23
    specific criteria.16 15See 62 FR 67525 (Dec. 24, 1997). This
    change was made in response to concerns raised by the U.S.
    maritime industry in comments on an earlier notice of proposed
    rulemaking regarding the cost burden-and perceived competitive
    disadvantage to U.S. merchant vessels-of redundant inspection
    requirements. 16For example, one of the standards was that the
    classification society must maintain an internal quality system
    based on ANSI standard ANSI/ASQC Q9001 or an equivalent quality
    standard. Page 16
    GAO/GGD-99-170 Certification Requirements B-281675 In DOT's
    previously mentioned substance abuse-prevention program, the
    department's rulemaking notices clearly documented the
    department's reasons for selecting or rejecting particular
    certifying bodies. Although DOT did not describe the specific
    criteria it would use to accept or reject professional
    certifications at the time it issued the proposed rule, the
    department's response to public comments in the final rule clearly
    described why it accepted certification by NAADAC and rejected
    state certifications. DOT noted that NAADAC was a national
    organization and that commenters provided information showing that
    the training and experience needed to meet NAADAC standards and
    certification requirements were sufficient for participation as a
    SAP in DOT's alcohol misuse prevention programs. DOT said it
    rejected suggestions that the SAP definition include state-
    certified counselors because qualification standards varied
    dramatically by state and did not always result in state-
    certified counselors having the experience or training DOT deemed
    necessary to implement the objectives of its rules. However, the
    reasoning behind some other agency certification requirements that
    we examined was not as clearly documented or otherwise explained.
    These specific cases involved the selection of particular
    certification bodies, and organizations that were not selected
    raised questions about the criteria that the agencies used. One
    such example was VA's implementation of new procedures, effective
    July 1, 1997, generally requiring that newly hired physicians be
    board-certified in the clinical specialty in which they will
    practice. The VA Undersecretary for Health later specified that
    the only certifying bodies recognized by VA for this purpose would
    be the American Board of Medical Specialties (ABMS) for allopathic
    physicians and the Bureau of Osteopathic Specialists (BOS) for
    osteopathic specialists. Although the subsequent announcement
    indicated that the two organizations were "umbrella organizations
    for approving medical specialty boards in the United States" and
    described the importance of board certification, the announcement
    did not indicate why these organizations were selected.17 Another
    certifying organization (the American Association of Physician
    Specialists, Incorporated) and the House Committee on Veterans'
    Affairs then questioned why VA recognized only ABMS and BOS
    certifications. The Committee requested that VA provide the
    criteria used to evaluate and select those two organizations. In
    its response to the Committee, VA stated that certifying groups
    vary widely in their requirements and that ABMS and 17VA noted
    that certification of physicians ensures that medical specialists
    have successfully completed an approved educational program and an
    evaluation designed to assess their possession of knowledge,
    experience, and skills needed to provide high quality patient care
    within the specialty. VA also said that board certification is a
    widely accepted measure of physician qualifications. Page 17
    GAO/GGD-99-170 Certification Requirements B-281675 BOS are "the
    standard certifying organizations recognized throughout American
    medicine." However, VA did not further describe why it selected
    these two certifying organizations. VA officials told us during
    this review that they rely on consensus practices and standards of
    the health care profession in establishing certification
    requirements. They said VA's use of ABMS and BOS certifications
    can be traced back to a 1980 decision by the Chief Medical
    Director to accept ABMS and BOS physician board certifications for
    Incentive Special Pay purposes. In 1997, VA extended those same
    certifications that were required for special pay purposes to
    employment, "grandfathering" currently employed physicians. VA
    officials also noted that they had canvassed other federal
    agencies involved in health care issues-including the Department
    of Defense, the Public Health Service, NIH, CDC, and the Bureau of
    Prisons-and found that essentially all recognized ABMS and BOS as
    the two accepted organizations for board certification purposes.
    The officials also described to us some of their expectations of a
    health professional certification program-in essence, informal
    selection criteria. These included (1) accreditation for
    educational requirements (undergraduate, medical school, and
    residency program); (2) accreditation for post-residency
    experience; and (3) certifying exams in the area of specialty.
    Finally, they pointed out that by law, the Secretary for Veterans
    Affairs has special authority to make personnel decisions.
    Although the description that VA officials provided explains how
    ABMS and BOS were selected, it was not contained in any published
    document and did not explain what criteria other organizations
    would need to meet to be accepted by VA. Another agency
    certification decision that was not transparent to affected
    entities involved a 1996 NIH solicitation for the maintenance,
    certification, and decontamination of certain types of facilities
    and equipment, including biological safety cabinets. NIH
    implicitly designated NSF International as the sole certifying
    organization by including a requirement in the solicitation that
    the full-time on-site supervisor for specific locations be an NSF-
    accredited biohazard cabinet field certifier. NIH did not explain
    why only NSF accreditation was acceptable. As in the VA example,
    other certifying organizations that were not designated raised
    questions about the restriction to NSF's program. NIH officials
    told us during our review that NSF had the only accreditation
    program that was nationally recognized. The officials also pointed
    out that they applied the restrictive provision as narrowly as
    possible-requiring accreditation only for supervisors-while still
    addressing the agency's primary need to protect the safety of NIH
    personnel. Page 18                                 GAO/GGD-99-170
    Certification Requirements B-281675 Agencies can make clear the
    criteria they used or plan to use to select a Common Criteria Used
    to           particular certification requirement or certifying
    organization in any Select Certifying                 number of
    ways. However, those cases that we reviewed in which agencies
    Organizations                     clearly documented the criteria
    they used to select certifying organizations appeared to have
    certain common elements. For example, in most of these cases the
    agencies included discussions of elements such as the following: *
    the structure, purpose, and other characteristics of the
    organization (e.g., its legal status and composition of the
    governing board); *  the resources and qualifications of the
    organization (e.g., technical competence of the staff, adequacy of
    management and quality control systems, and appropriate
    experience); *  the certification procedures or mechanisms used by
    the organization (e.g., public documentation, use of valid test or
    evaluation methods, enforcement of certification requirements, and
    appeals or due process procedures regarding certification
    decisions); and *  other factors (e.g., compatibility with or
    recognition of related certifications and the costs and fees
    associated with certification). However, transparency is not free.
    The Director of CDC's Procurement Transparency Is Not Free or and
    Grants Office told us that a governmentwide requirement for
    complete a Panacea                         documentation of each
    agency certification action would carry with it certain costs,
    including possible delays in procurement and the issuance of
    agency rules. The Director pointed out that the relative
    infrequency of concerns expressed about agency certification
    requirements could mean that those costs could exceed the benefits
    derived from documentation requirements. He also noted that
    mechanisms are already in place to address concerns about
    restrictive solicitation provisions and said that agencies will
    probably hear from affected entities if the requirements are
    considered unreasonable and/or restrictive of competition.
    Finally, both he and DOT officials emphasized that no one uniform
    approach is appropriate in the varied conditions in which
    certifications are used. Also, transparency in an agency's
    certification requirements does not guarantee that the process
    will result in the best (or even a good) decision. Conversely,
    lack of transparency does not necessarily mean that an agency's
    certification decision will not be good or appropriate. At a
    minimum, however, the opportunities for alternative certification
    organizations or requirements to be put forward are improved if
    agencies are transparent in establishing their requirements and
    vetting their decisions with the public. Page 19
    GAO/GGD-99-170 Certification Requirements B-281675 Federal
    agencies' certification requirements are an invaluable tool in
    Conclusions    helping to ensure product quality, process
    reliability, and professional competence in a variety of venues.
    Without those requirements, federal agencies would have to
    independently evaluate the safety of products, whether certain
    procedures will yield the desired results, and whether individual
    workers possess the skills required to perform a given task.
    Federal agencies have broad latitude in the selection of
    certification requirements and certifying organizations, which can
    result in what appear to be inconsistencies of application. For
    example, five agencies might each require a different
    certification for the same type of product or service. Businesses
    that want to provide that product or service to each of the
    agencies would therefore have to incur the expense associated with
    obtaining five certifications. Also, an agency can accept
    certifications from one certifying organization while not
    accepting certifications in the same subject area from other
    organizations with what appear to be similar qualifications.
    Organizations that are not selected would then have to forgo any
    income associated with providing certifications for that agency.
    These apparent inconsistencies are exacerbated when the reasons
    behind the agencies' certification decisions are unclear.
    Transparency of these decisions could improve their perceived
    legitimacy, particularly when more than one certification option
    is available to an agency. The means by which agencies'
    certification decisions can be made transparent will depend on the
    context in which the requirements are imposed. For example, if an
    agency's certification requirement is part of a procurement
    action, the agency can make clear the basis of that requirement in
    the request for proposals. Some agencies have also used the
    rulemaking process to delineate the rationale behind their
    certification requirement decisions. However, although contracting
    and rulemaking processes are convenient mechanisms for
    certification transparency, they are not always available because
    some certification requirements do not arise in either
    environment. The extent to which agencies' certification
    requirements need to be explained will also depend on the
    circumstances surrounding the certification requirement. For
    example, only a brief explanation should be necessary when an
    agency picks a certifying organization that is generally
    acknowledged to be the only such organization available. On the
    other hand, a more elaborate explanation may be necessary when an
    agency selects one organization over others with what appear to be
    similar qualifications. In that case, transparency can also help
    organizations not Page 20                                GAO/GGD-
    99-170 Certification Requirements B-281675 selected to understand
    what they must do to meet the agency's requirements. The
    forthcoming guidance being developed by NIST for the Secretary of
    Commerce may help bring more uniformity to the certification
    process, thereby making that process more intelligible to
    contractors, regulated parties, and other entities affected by the
    requirements. However, NIST officials said that the draft guidance
    does not directly address the issue of certification transparency.
    Although it would probably be unwise to recommend a single
    transparency approach, the guidance could generally advocate the
    concept of transparency in agencies' certification decisions and
    suggest alternative mechanisms by which those decisions could be
    explained to the public. We recommend that the Secretary of
    Commerce include a section in the Recommendation
    conformity assessment guidance being developed that specifically
    addresses the transparency of agencies' certification
    decisionmaking. Specifically, we believe that the guidance should
    encourage agencies to publicly explain why particular
    certification decisions were made or how certification decisions
    in the future will be made. The guidance should present
    alternative approaches for the agencies to consider in making
    their certification decisions more transparent, but it should not
    advocate that a single approach be used in all circumstances. We
    provided a draft of this report to the Secretaries of Commerce,
    Health Agency Comments and and Human Services, Transportation, and
    Veterans Affairs and the Director Our Evaluation
    of OMB for their review and comment. Officials from HHS, DOT, and
    OMB informed us that their agencies did not have comments on our
    draft report. VA did not provide comments.  On September 13, 1999,
    the Secretary of Commerce provided written comments on the draft
    report.  The Secretary said that the Department would address our
    recommendation on the issue of transparency in agencies'
    certification decisionmaking during the public comment period for
    the conformity assessment guidance being prepared by NIST. The
    Secretary noted that NIST would work with ICSP on the most
    effective way to address the issues of transparency for both
    regulatory and procurement agencies. The Department of Commerce
    also provided some technical comments and suggestions, which we
    incorporated as appropriate. To ensure that we had accurately
    characterized the examples of agency certification programs and
    requirements presented in an appendix to this report, we also
    provided the relevant portions of our draft report to officials in
    the Departments of Agriculture, Housing and Urban Page 21
    GAO/GGD-99-170 Certification Requirements B-281675 Development,
    and Labor and the Environmental Protection Agency.  They provided
    technical comments and suggestions, which we included in this
    report as appropriate. We are sending copies of this report to
    Representative Nydia M. Velazquez, Ranking Minority Member of the
    House Committee on Small Business. We are also sending copies to
    the Honorable William M. Daley, Secretary of Commerce; the
    Honorable Donna E. Shalala, Secretary of Health and Human
    Services; the Honorable Rodney E. Slater, Secretary of
    Transportation; the Honorable Togo D. West, Jr., Secretary of
    Veterans Affairs; and the Honorable Jacob Lew, Director of OMB.
    Copies will also be made available to others on request. Major
    contributors to this report are acknowledged in appendix II. If
    you have any questions about this report or would like to discuss
    it further, please contact me on (202) 512- 8676. Sincerely yours,
    L. Nye Stevens Director, Federal Management and Workforce Issues
    Page 22                                GAO/GGD-99-170
    Certification Requirements Page 23    GAO/GGD-99-170 Certification
    Requirements Contents 1 Letter 28 Appendix I
    Department of Agriculture
    28 Examples of Federal          Department of Commerce
    29 Department of Health and Human Services
    30 Agencies' Certification Department of Housing and Urban
    Development                                   32 Requirements
    Department of Labor
    32 Department of Transportation
    33 Department of Veterans Affairs
    36 Environmental Protection Agency
    36 38 Appendix II GAO Contacts and Staff Acknowledgments Page 24
    GAO/GGD-99-170 Certification Requirements Contents Abbreviations
    AAR         Association of American Railroads ABMS        American
    Board of Medical Specialties AHA         American Heart
    Association AMS         Agricultural Marketing Service ANSI
    American National Standards Institute APHIS       Animal and Plant
    Health Inspection Service ASME        American Society of
    Mechanical Engineers BOS         Bureau of Osteopathic Specialists
    CAP         College of American Pathologists CDC         Centers
    for Disease Control and Prevention CLIA        Clinical Laboratory
    Improvement Amendments CPR         Cardiopulmonary resuscitation
    DOT         Department of Transportation EPA         Environmental
    Protection Agency FAA         Federal Aviation Administration FDA
    Food and Drug Administration HCFA        Health Care Financing
    Administration HUD         Department of Housing and Urban
    Development ICSP        Interagency Committee on Standards Policy
    ILO         International Labor Organization ISO
    International Organization for Standardization NAADAC
    National Association of Alcoholism and Drug Abuse Counselors NCCA
    National Commission for Certifying Agencies NIH         National
    Institutes of Health NIST        National Institute of Standards
    and Technology NMFS        National Marine Fisheries Service NOAA
    National Oceanic and Atmospheric Administration NOCA
    National Organization for Competency Assurance NRTL
    Nationally Recognized Testing Laboratory NSF         NSF
    International (formerly the National Sanitation Foundation) NSSP
    National Shellfish Sanitation Program NVCASE      National
    Voluntary Conformity Assessment System Evaluation Program NVLAP
    National Voluntary Laboratory Accreditation Program NWS
    National Weather Service OGE         Office of Government Ethics
    OMB         Office of Management and Budget OSHA
    Occupational Safety and Health Administration RSPA        Research
    and Special Programs Administration (Transportation) SAP
    Substance abuse professional SSCA        Shellfish Sanitation
    Control Authority UL          Underwriters Laboratories, Inc. Page
    25                                      GAO/GGD-99-170
    Certification Requirements Contents USDA        United States
    Department of Agriculture VA          Department of Veterans
    Affairs WTO         World Trade Organization Page 26
    GAO/GGD-99-170 Certification Requirements Page 27    GAO/GGD-99-
    170 Certification Requirements Appendix I Examples of Federal
    Agencies' Certification Requirements This appendix briefly
    describes selected certification or certification- related
    programs and requirements.  Although not intended to provide a
    compendium of all such federal agency programs or requirements,
    the appendix illustrates both the number of federal certification
    requirements and the dimensions by which they vary.  To compile
    this appendix, we relied primarily on examples identified by
    officials within the agencies that we contacted during this review
    and information provided in the National Institute of Standards
    and Technology (NIST) Directory of Federal Government
    Certification and Related Programs.1 *  The U.S. Department of
    Agriculture's (USDA) Agricultural Marketing Department of
    Service (AMS) provides voluntary on-site grading and certification
    of Agriculture        meats and meat products through physical
    examination of product characteristics during the production
    process.  The required tests are performed in government labs by
    AMS personnel, and approved USDA stamps and roller brands are
    applied to products that are considered in compliance with
    applicable standards or specifications.  The grading system
    provides a common language to facilitate trading, and the
    certification assists large-scale buyers by providing impartial
    evaluation and certification that meat purchases meet their
    contract specifications. An AMS official also pointed out two
    related services provided under the agency's regulations.  The
    Contract Verification Service provides wholesale buyers of
    noncertified commodity products a method of determining whether
    procurements meet contractually specified requirements.  The
    Quality Systems Certification Program provides meat packers,
    processors, producers, or other businesses in the livestock and
    meat trade the ability to have special processes or documented
    quality management systems verified. *  USDA's AMS also issues
    certificates regarding the quality of other agricultural products,
    including fresh fruits, vegetables, nuts, and related products.
    All of these certifications are voluntary, except for commodities
    that are regulated for quality by a marketing order or marketing
    agreement, or that are subject to import or export requirements.
    AMS also issues grade certificates for raw cotton, which are
    mandatory for cotton delivered on futures contracts. *  To assist
    in the export of plants and unprocessed plant products, USDA's
    Animal and Plant Health Inspection Service (APHIS) issues
    phytosanitary (plant health) certificates to exporters certifying
    conformity with the receiving country's plant quarantine import
    regulations.  The inspections 1 NIST SP739, 4th Edition (Office of
    Standards Services, July 1999).  NIST also publishes a separate
    directory on laboratory accreditation programs, Directory of
    Federal Government Laboratory Accreditation/Designation Programs
    (NIST SP808). Page 28
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements are conducted by
    federal and state cooperators, and testing is done in federal and
    recognized state and university labs. APHIS also provides export
    certificates, stamp endorsements, or letterhead certification to
    indicate the class, quality, and condition of animal by-products
    to assist exporters in the United States to comply with import
    requirements in foreign countries. *  The National Marine
    Fisheries Service (NMFS) within the Department of Department of
    Commerce's National Oceanic and Atmospheric Administration (NOAA)
    Commerce           inspects seafood products and processing
    operations on a voluntary, fee- for-service basis.  The
    inspections are performed by licensed federal and state agents and
    involve vessel and plant sanitation, product inspection, grading,
    certification, label review, and laboratory analysis.  Federal,
    state, and federally recognized private laboratories perform
    testing and analysis, and NMFS lists approved suppliers and
    graded/certified products.  Other federal and state agencies,
    private organizations, foreign government agencies, and
    international organizations recognize the NMFS seafood
    certifications. *  The National Weather Service (NWS) within NOAA
    administers a mandatory program to certify weather observers and
    approve weather stations.  NWS certifies weather observers by
    examination and experience for acceptable vision, adequate
    training, and demonstrated ability to take and record accurate and
    timely weather observations.  The stations are approved on the
    basis of appropriate instrumentation use, installation of
    automated sensors, maintenance programs, and certification of the
    observers.  The program ensures consistent, minimum performance
    expectations for manual weather observations used for the
    preparation of forecasts and warnings and the support of aviation
    operations. *  The National Institute of Standards and Technology
    (NIST) administers the National Voluntary Laboratory Accreditation
    Program (NVLAP).  NVLAP accredits laboratories on the basis of an
    evaluation of their technical qualifications and competence to
    carry out specific calibrations or tests. NVLAP accreditation is
    available to commercial; manufacturers' in-house; university; and
    federal, state, and local government laboratories and is
    formalized through issuance of a Certificate of Accreditation and
    Scope of Accreditation. *  NIST also administers the National
    Voluntary Conformity Assessment System Evaluation (NVCASE)
    program.  The program's primary objectives are to provide a basis
    for the United States government to assure foreign governments
    that qualifying conformity assessment bodies in the United States
    (e.g., accreditors of laboratories) are competent to satisfy their
    regulatory requirements and to facilitate the acceptance of
    American products in foreign markets.  The NVCASE program can also
    be applied in Page 29
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements support of domestic
    regulatory programs at the request of another federal agency.  The
    NVCASE program includes activities related to laboratory testing,
    product certification, and quality system registration.  After
    NVCASE evaluation, NIST provides recognition to qualified
    organizations in the United States that effectively demonstrate
    conformance with established criteria.  NIST maintains listings of
    all recognized bodies, as well as listings of qualified bodies
    that are currently accredited by bodies recognized by NIST. *  In
    various procurement documents prepared by the Centers for Disease
    Department of Health      Control and Prevention (CDC), the agency
    included certification and Human Services        requirements for
    persons providing specific services.  For example, a medical
    officer had to be board-certified in one relevant primary care
    area (such as internal medicine or surgery) and licensed to
    practice in the United States or be board-eligible in both
    occupational medicine and internal medicine.  A physician's
    assistant had to be certified or licensed as a physician assistant
    by the appropriate national or state recognized organization.  A
    chief nurse, in addition to being registered as a registered nurse
    in the state of Georgia, had to have annual certification in basic
    cardiac life support.  CDC also required that cardiopulmonary
    resuscitation (CPR) instructors have American Heart Association
    (AHA) certification as providers of basic and advanced cardiac
    life support or American Red Cross Association certification plus
    AHA certification as (1) Instructor in Basic Cardiac Life Support,
    (2) Instructor-Trainer in Basic Cardiac Life Support, and (3)
    Instructor in Advanced Cardiac Life Support. *  The National
    Shellfish Sanitation Program (NSSP) is a federal-state cooperative
    program recognized by the Food and Drug Administration (FDA) and
    the Interstate Shellfish Sanitation Conference for the sanitary
    control of shellfish (oysters, clams, mussels, and scallops)
    produced and sold for human consumption.  Most of the regulation,
    inspection, investigations, and control measures are done at the
    state level.  However, FDA conducts an annual review of each state
    shellfish control program to determine its degree of conformity
    with the NSSP.  Annually, the state Shellfish Sanitation Control
    Authority (SSCA) issues number certificates to shellfish dealers
    who comply with sanitary standards and forwards copies of the
    interstate certificates to FDA.  FDA publishes a monthly list of
    all shellfish shippers that have been certified by states that
    maintained satisfactory control programs.  Shellfish plants
    certified by SSCA are required to place their certificate numbers
    on each container or package of shellfish shipped.  Separate from
    NSSP, FDA also issues certificates for other fish and fishery
    products, including Certificates of Free Sale, Certificates of
    Export, Certificates to Foreign Governments, and European Union
    Health Certificates for Fishery Products. Page 30
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements *  FDA also has a
    mandatory certification program that lists approved color
    additives and the conditions under which they may be safely used
    in foods, drugs, cosmetics, and medical devices.  Each batch of
    color must be tested and certified in an FDA laboratory before it
    can be used, unless the color additive is specifically exempted by
    regulation. Other federal agencies, state agencies, and private
    sector organizations recognize FDA's certifications. However,
    under the provisions of the Federal Food, Drug, and Cosmetic Act,
    FDA cannot accept certification of a color by a foreign country as
    a substitute for its own certification. *  FDA's Center for
    Devices and Radiological Health is responsible for the setting and
    enforcement of performance standards to control radiation
    emissions from electronic products, such as television receivers,
    microwave ovens, X-ray equipment, and lasers.  A manufacturer of
    an electronic product for which there is an applicable federal
    performance standard is required to affix a certification label
    stating that the product conforms to the standard.  Certification
    is based on a test prescribed by the standard or a testing program
    that is in accord with good manufacturing practices as determined
    by the Center.  Manufacturers' or third-party laboratories perform
    the testing. *  Under the Mammography Quality Standards Act of
    1992, FDA was authorized to implement the act's requirements for
    the certification and inspection of all mammography facilities.2
    Only certified facilities that are in compliance with uniform
    federal standards for safe, high quality mammography services may
    lawfully operate.  These requirements apply to all facilities
    producing, processing, or initially interpreting mammograms,
    whether for screening or diagnostic purposes, except for
    facilities of the Department of Veterans Affairs, which developed
    its own quality assurance program.  To become certified,
    facilities must first be accredited by an FDA-approved
    accreditation body.  FDA published regulations to establish the
    requirements and standards for accrediting bodies and application
    procedures for such bodies.  The FDA regulations also established
    the quality standards for mammography facilities and procedures
    for facility certification.  Accreditation and certification must
    be renewed every 3 years. *  The Health Care Financing
    Administration (HCFA) regulates all laboratory testing (except
    research) performed on humans in the United States through the
    Clinical Laboratory Improvement Amendments (CLIA) program.  CLIA
    certification is mandatory for all facilities that perform
    laboratory testing on specimens derived from the human body for
    the purpose of providing information for the diagnosis,
    prevention, or 2 The Mammography Quality Standards Reauthorization
    Act of 1998 extended this program until October 2002. Page 31
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements treatment of disease,
    or impairment of or assessment of health.  CLIA regulations are
    based on the complexity of the test method-the more complicated
    the test, the more stringent the requirements.  Upon determining
    compliance with regulatory requirements, HCFA issues the
    appropriate certificate(s) for the type(s) of testing the
    laboratory performs.  Those certificates are effective for a 2-
    year period.  Those laboratories that must be surveyed routinely
    (those performing moderate- or high-complexity testing) can choose
    whether to be surveyed by HCFA or by a private accrediting
    organization.  Approved accrediting organizations under CLIA
    include the American Association for Blood Banks, the American
    Osteopathic Association, the American Society for
    Histocompatibility and Immunogenetics, the College of American
    Pathologists, the Commission of Laboratory Accreditation, and the
    Joint Commission on Accreditation of Healthcare Organizations.  In
    addition, certain laboratories are licensed under CLIA-exempt
    state programs in New York, Oregon, and Washington. *  HCFA also
    has a survey and certification program covering providers and
    suppliers of health care services to Medicare and Medicaid
    beneficiaries. The aim of HCFA's program is to ensure that these
    providers (such as participating hospitals, home health agencies,
    and nursing home providers) meet federal health, safety, and
    program standards.  Hospitals accredited by the Joint Commission
    on Accreditation of Healthcare Organizations or the American
    Osteopathic Association are deemed to participate in the program
    and meet federal requirements. *  The Department of Housing and
    Urban Development (HUD) has a Department of Housing voluntary
    program for validation of private sector certifications of
    building and Urban                        products for
    construction (i.e., that building products comply with Development
    designated standards).  After testing by government accredited,
    third-party validating, state/local, or manufacturers'
    laboratories and inspection by third parties, products that meet
    standards must have an authorized mark or label affixed by the
    manufacturer or a third-party administrator. Currently, 33 third-
    party administrators participate in the HUD Building Products
    Certification program for such products as solid fuel-type
    heaters, fireplace stoves, plastic bathtub units, aluminum
    windows, storm doors, wood window units, carpet, and lumber, among
    others. *  HUD also has a mandatory program requiring third-party
    certification of manufactured housing designs and quality
    assurance manuals, as well as in-plant inspection to ensure
    compliance with standards.  HUD issues lists of approved third-
    party agencies. *  The Occupational Safety and Health
    Administration (OSHA) implements Department of Labor
    the Nationally Recognized Testing Laboratory (NRTL) Program.  This
    Page 32                                      GAO/GGD-99-170
    Certification Requirements Appendix I Examples of Federal
    Agencies' Certification Requirements program recognizes private
    sector organizations (third-party laboratories) that meet the
    necessary qualifications specified in program regulations as
    NRTLs.  An NRTL determines that specific equipment and materials
    meet consensus-based standards of safety to provide the assurance,
    required by OSHA, that these products are safe for use in United
    States workplaces. To obtain initial NRTL recognition, an
    applicant must complete an application and resolve any
    deficiencies found during an on-site assessment.  A preliminary
    notice is then published in the Federal Register announcing the
    application for recognition, a 60-day comment period ensues, and
    (absent compelling reasons to the contrary), a final notice is
    published formally recognizing the applicant as an NRTL. *  In
    another program, OSHA also accredits independent third-party
    certification agencies for the purpose of certifying maritime
    vessels' cargo gear lifting and handling gear and shore-based
    cargo handling equipment. OSHA maintains a list of accredited
    certification agencies and surveyors. The certifications are
    intended to ensure that all covered equipment is in a safe
    material condition, properly tested, and in compliance with
    regulatory requirements.  Through this program, the United States
    fulfills its responsibilities under International Labor
    Organization (ILO) Convention No. 152. *  Regulations on substance
    abuse prevention that cover employees in Department of
    Department of Transportation (DOT)-regulated transportation
    industries Transportation      (including aviation, highway, rail,
    and other transit industries, such as pipelines) include
    provisions requiring face-to-face evaluation by substance abuse
    professionals.  DOT defines these professionals as including,
    among others, a licensed or certified psychologist or an addiction
    counselor certified by the National Association of Alcoholism and
    Drug Abuse Counselors Certification Commission or by the
    International Certification Reciprocity Consortium/Alcohol & Other
    Drug Abuse. *  Testing and/or inspection by a Coast Guard
    accredited laboratory is mandatory for some equipment required for
    use on recreational boats and commercial vessels (e.g., equipment
    used for lifesaving, fire protection, and pollution prevention, as
    well as other electrical and engineering equipment).  Manufacturer
    self-certification is allowed for selected items. *  The Coast
    Guard issues certificates of approval to certain providers of
    merchant marine courses.  Obtaining a certificate is mandatory
    where required by regulations (in areas such as radar observation,
    fire fighting, and first aid), but it is otherwise voluntary.
    Training organizations seeking approval must submit course
    packages to the Coast Guard's National Maritime Center, the
    proposed training facility is inspected by a Coast Page 33
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements Guard Regional
    Examination Center, and instructor qualifications are reviewed. *
    The Coast Guard issues certificates of inspection for certain
    vessels following satisfactory completion of an inspection by a
    government body or an organization recognized by the Coast Guard.
    A 1997 final rule provided for the alternative to Coast Guard
    inspection by permitting the Coast Guard to issue a certificate of
    inspection based upon reports by a "recognized, authorized
    classification society."  The Coast Guard generally establishes
    the procedures and standards used in inspections, but some are
    also established by statute or through international conventions
    and treaties for certain vessels.  Other federal agencies, foreign
    government agencies, and international organizations recognize
    these certificates. *  The Coast Guard also enforces requirements
    to ensure the safety of shipping containers used for the
    international transport of cargo.  A third party must certify
    these containers before they enter into international traffic.
    The certifications are mandatory under the International Safe
    Container Act and signify that the containers conform to the
    International Convention for Safe Containers. Foreign governments
    and international organizations recognize this certification.
    Containers must display a Safety Approval Plate from the approval
    authority in the country of registry. *  The Federal Aviation
    Administration (FAA) has a comprehensive system of certifications
    for the civil aviation system, with coverage ranging across
    equipment, personnel, and facilities.  For example, FAA issues
    Type Certificates for makes and models of aircraft, aircraft
    engines, or propellers and grants Airworthiness Certificates for
    specific aircraft that meet approved type designs and are in
    condition for safe operation.  FAA provides certification for
    pilots, flight instructors, crew members, mechanics, control tower
    operators, and other aviation-related personnel. FAA also provides
    for certification of repair stations, parachute lofts, and schools
    for pilots and mechanics.  FAA operates an Airport Safety and
    Certification Program and an Airport Lighting Equipment
    Certification program.  It issues certificates of designation and
    certificates of authority to, among others, aviation medical
    examiners, examiners of pilots and technical personnel, designated
    engineering representatives, and manufacturing inspection
    representatives.  Compliance with the FAA certification system is
    mandatory for civil aviation, and the Department of Defense and
    the Coast Guard also require that some of their aircraft and
    equipment be FAA-certified.  Most of the applicable design,
    performance, and quality requirements are specified in the Code of
    Federal Regulations. The International Civil Aviation Organization
    also sets general guidelines for airworthiness certification
    systems that FAA implements in the United States.  In addition,
    FAA accepts some nongovernment standards, such as ones developed
    by the Society of Automotive Engineers, the Radio Page 34
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements Technical Commission
    for Aeronautics, and the Aerospace Industries Association. *  The
    Federal Railroad Administration has a number of safety-related
    certification programs.  One mandatory program covers safety
    glazing of windows for locomotives, passenger cars, and cabooses.
    Testing of glazing materials to demonstrate compliance with
    regulatory requirements is done by either manufacturers in their
    labs or independent labs that meet specified qualifications.  Each
    individual unit of glazing material is permanently marked to
    indicate certification. *  A voluntary program administered by
    DOT's Research and Special Programs Administration (RSPA) covers
    packaging of hazardous materials for export.  Shippers and
    container manufacturers can demonstrate conformance of their
    packaging designs with United Nations' standards through third-
    party testing agencies designated by RSPA's Office of Hazardous
    Materials Technology.  These third-party approval agencies
    evaluate and issue approval certificates for intermodal portable
    tanks and certificates of conformance for other types of
    packaging. *  RSPA also has a mandatory requirement for third-
    party certification of railway tank cars used for the transport of
    hazardous materials.  The third parties must be acceptable to the
    Association of American Railroads (AAR) and the Bureau of
    Explosives.  AAR provides design approval of couplers, which is
    accepted by DOT.  RSPA issues certificates of construction. *
    Another RSPA mandatory program requires registration of all
    persons or organizations engaged in the manufacture, assembly,
    inspection and testing, certification, or repair of cargo tanks or
    cargo tank motor vehicles. Manufacturers of special cargo tanks
    and cargo tank motor vehicles must also obtain an American Society
    of Mechanical Engineers (ASME) Certificate of Authorization for
    the use of the ASME "U" stamp.  Repairs that are not verified to
    the ASME Code must have a National Board or ASME Certificate of
    Authorization.  ASME or ASME-designated bodies perform the
    required testing or inspection.  Other federal agencies, state
    agencies, private sector organizations, and the Canadian
    government recognize reciprocity with this registration. *  RSPA
    requires third-party certification of welders and plastic pipe
    assemblers to ensure the safety of pipelines for gas and hazardous
    liquids. The agency also requires manufacturers' self-
    certification for valves, pressure-limiting services, and overall
    installation to specified standards. Certification of welders is
    usually conducted by the American Welding Society, but a
    comparable program by the installing contractor may be acceptable
    to RSPA.  The agency adopts the standards of national standards
    organizations. Page 35
    GAO/GGD-99-170 Certification Requirements Appendix I Examples of
    Federal Agencies' Certification Requirements *  The Department of
    Veterans Affairs (VA) requires certification of Department of
    automotive driving aids and automatic wheelchair lifts for
    purchases Veterans Affairs       funded by the Department.  VA
    publishes a compliance list that delineates certified suppliers of
    wheelchair lift systems and hand controls (driving aids).
    Certification is by a VA-sponsored Automobile Adaptive Equipment
    Committee.  Government testing and inspection, third party
    government- approved certification (Society of Automotive
    Engineers), and manufacturers' self-certification are used to
    ensure compliance with VA's standards.  VA also accepts
    certification by other agencies when current standards are
    applied. *  VA has similar mandatory requirements for self-
    propelled and motorized wheelchair purchases funded by the
    department, again listing suppliers of these products.
    Certification is by a VA-sponsored Prosthetic Technology Equipment
    Committee.  Government testing and inspection, third party
    government-approved certification (Rehabilitation Engineering and
    Assistive Technology Society of North America/ANSI), and
    manufacturers' self-certification are used to ensure compliance
    with VA's standards.  VA also accepts certification by other
    agencies when current standards are applied. *  In order to ensure
    standardization and uniformity in laboratory test performance
    throughout the VA system's clinical, nuclear medicine, and special
    purpose ancillary testing laboratories, the department requires
    third-party certification by the College of American Pathologists
    (CAP) and the Joint Commission on Accreditation of Healthcare
    Organizations.  The standards applied are those of the CAP
    Laboratory Accreditation Program, but VA also recognizes
    certification by the Joint Council of American Hospitals. *  VA
    established board certification requirements that, with some
    exceptions, applied to physicians hired on or after July 1, 1997.
    Unless they have written approval of the Chief Patient Care
    Services Officer prior to appointment, these physicians must be
    board-certified in the clinical specialty area in which they will
    practice.  VA's Undersecretary for Health specified that the
    certifying bodies for these purposes are the American Board of
    Medical Specialties (ABMS) for allopathic physicians and the
    Bureau of Osteopathic Specialists (BOS) for osteopathic
    physicians. *  An Environmental Protection Agency (EPA)-
    accredited, third-party Environmental          laboratory must
    conduct emissions testing for certification of new Protection
    Agency      residential wood heaters and submit the results to
    EPA.  EPA certifies a representative wood heater from the model
    line, granting certificates valid for 5 years. *  In another
    mandatory program, laboratories performing drinking water analysis
    to demonstrate compliance with regulations must be certified as
    Page 36                                      GAO/GGD-99-170
    Certification Requirements Appendix I Examples of Federal
    Agencies' Certification Requirements capable of delivering
    acceptable performance.  States seeking to operate a drinking
    water regulatory program must implement a laboratory certification
    program based on federal standards.  EPA's regional offices serve
    as the certifiers in situations where there is no approved state
    program.  Certified laboratories are issued certificates
    identifying areas of competency. *  To ensure that pesticides
    posing relatively high risk, or that are difficult to use, are
    used only by or under the direct supervision of competent persons,
    EPA oversees state programs to certify applicators.  EPA serves as
    the certifier of applicators in Colorado.  An applicator may not
    apply restricted-use pesticides until he or she demonstrates
    competency and receives certification. *  Under section 609 of the
    Clean Air Act Amendments of 1990, operators who service motor
    vehicle air conditioners must be certified under an approved 609
    program prior to offering services.  EPA restricts the sale of
    small containers of Class I and Class II substances appropriate
    for use in motor vehicle air conditioners to certified personnel.
    Personnel testing is done by private industry programs approved by
    EPA.  Also, recovery and recycling equipment must be approved by
    EPA and must meet the requirements of the SAE standards for
    approval.  EPA maintains a list of technician certification
    programs and approved equipment. Page 37
    GAO/GGD-99-170 Certification Requirements Appendix II GAO Contacts
    and Staff Acknowledgments Curtis Copeland, (202) 512-8101 GAO
    Contacts       Tim Bober, (202) 512-4432 In addition to those
    named above, Alan Belkin, John Brosnan, and Victor Acknowledgments
    B. Goddard made key contributions to this report. Page 38
    GAO/GGD-99-170 Certification Requirements Page 39    GAO/GGD-99-
    170 Certification Requirements Page 40    GAO/GGD-99-170
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