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Katharine E. Morgan
President
May 29, 2019
AI- Standards
National Institute of Standards and Technology
100 Bureau Drive, Stop 2000
Gaithersburg, MD 20899
Re: Docket No. NIST -2019-08818 – RFI: Developing a Federal AI Standards Engagement Plan
Thank you for the opportunity to provide the following comments in response to the National
Institute of Standards and Technology’s (NIST’s) request for information on artificial
intelligence (AI) standards.
Background
ASTM International is a leading, globally-recognized, non-profit organization in the
development and delivery of voluntary consensus standards. For more than 120 years, ASTM
has served society by providing a global forum for the development and publication of voluntary
consensus standards for materials, products, systems, and services. Today, over 12,000 ASTM
standards are used by ninety industrial sectors in the United States and around the world to
improve product quality, protect the environment, enhance health and safety, and strengthen
market access and trade. Over 30,000 individuals from 135 countries, including manufacturers,
retailers, consumers, regulators, academics and researchers, serve on ASTM’s 148 technical
committees.
ASTM has a long history of working in conjunction with federal agencies to develop standards
that meet evolving regulatory needs. According to the National Institute of Standards and
Technology (NIST) Standards Incorporated by Reference Database, there are over 2,500
standards from ASTM International incorporated by reference in the US Code of Federal
Regulations. A strong and effective reliance on the non-governmental sector for development
and maintenance of the standards in use across all sectors of our economy is supported by OMB
Circular A119 and codified by Congress through P.L. 104-113 – The National Technology
Transfer and Advancement Act (NTTAA).
Several ASTM technical committees are developing standards to support the reliable, robust, and
trustworthy systems that use AI.
ASTM Technical Committees
ASTM Committee F15 on Consumer Products was formed in 1973 and maintains over 100
standards. Subcommittee F15.75 on Connected Products is working on a standard to provide
guidance for consumer Internet of Things (IoT) as it relates to connected product hazards. It will
apply to consumer products connected to the internet that need testing and evaluation of software
to prevent cybersecurity vulnerabilities and software weaknesses that could compromise safety-
related performance of the product and create a safety hazard.
