Letter to ANSI Re CRI 10-6-10

8/8/2019 Letter to ANSI Re CRI 10-6-10

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Racine Industries, Inc. 1405 Sixteenth Street Racine, Wisconsin 53403

October 6, 2010

Mr. Lane Hallenbeck

American National Standards Institute

1819 L Street, Northwest

Washington, DC 20036

Dear Mr. Hallenbeck,

We at Racine Industries understand that Carpet and Rug Institute (CRI) has applied for

ANSI Accreditation of their Seal of Approval Vacuum Cleaner Program. As a product

manufacturer, client of CRI and as a directly and materially affected industry

stakeholder in CRI activities, Racine Industries objects and urges ANSI to deny the CRI

application.

The ANSI name lends credence to standards activities. The ANSI name indicates to the

public that a standards developer has followed the stringent steps necessary to create

and maintain trustworthy, scientific standards that the public may have confidence in.

Alternatively, the ANSI name may be used to make it appearthat these things have

been done. For example, CRI publicly and with no retraction claims to already have

ANSI accreditation for its vacuum cleaner testing program:

-accredited product certifying body and has placed the SOA/Green

(Appendix F)

alluding to and trying to disparage is

actually certified under the American National Standards Institute so you know if you

think that this program is so bad, then you may want to consult with the American

National Standards Institute to see what their oAppendix O)

opinion of this program is.


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Considfor the ANSI brand name, as indicated by using

erroneous claims to gain credibility, and considering CRevidence supporting

their standards , we

not fulfilled the requisites in ISO/IEC Guide 65, General requirements for bodies

operating product certification systems, First Edition 1996.

Specific examples of CRI failures to fulfill the criteria in Guide 65 and other relevant

guides and standards, include but are not limited to:

I. ISO/IEC Guide 65, 4.1.3, states that the criteria against which the productsare evaluated shall be those outlined in specified standards, suitable per

ISO/IEC Guide 7, which has been revised into ISO/IEC 17007-2009. CRI fails

to meet Guide 7 and 17007 criteria in numerous ways.

A. Guide 7, 4.4 and ISO/IEC 17007, 5.2.2 state that a standard should resultin accurate and uniform interpretations, and that parties using a standard

should be able to derive a common understanding of its meaning and

intent.

1. CRI has supplied no document that is labeledThand there is a list of

2. There are various web site pages marketing the program, eachwith different language that implies different meanings. If the

accurate and uniform interpretations are impossible. Some

examples of lack of clarity:


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a. Otwo categories

another page lists products that have passed

tests.

The categories are inconsistent and definitions unknown.

b. Meanwhile, in one place it is stated that carpet samples

Yet another page listsfourcarpet samples in the testing,but choicebetween them

for participating manufacturers. And still yet another

page lists three potential samples with a choice. Anyone

looking at this program as presented would not be able to

discern what was actually tested. Further, approved

products are not differentiated by what carpet they were

tested with and for what purpose. This makes any

performance rankings incomparable. ISO/IEC 17007 4.5

Principle 4 requires comparability.

3. The vacuum cleaner testing program incorporates the nameGreen Label. The carpet testing program also uses the name

Green Labelcarpettesting programs are within

the scope of current ANSI accreditation. The use of the

same name for both scopes is misleading and obscures the

meaning and intent.

4. (in the new testingprogram) requires a 10 percent improvement of soil removal

over the Green Label program and the standards are even higher


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This is fallacious and misleading.

The passing score for the new testing was simply raised four

percentage points; it does not mean that performance has

improved. Removing 40% of a tiny amount of soil of one soil

blend does not indicate or reflect a performance improvement

over removing 36% of a much larger amount of a different soil

blend. An analogy to indicate the statistical fallacy: spending

40% of a hundred dollars gets you less than spending 36% of a

thousanddollars. However, this analogy presumes, as CRI

implies, that the tests are correlated and comparable, which they

are not. Increasing the percentage required to pass one test

does not increase vacuum cleaner performance; there can be no Such CRI claims are

misleading and inaccurate, and this represents another example

of how Guide 7, 4.4, still needs to be followed.

B. Guide 7, 5.1, states that standards should be written in such a way as to notretard technological developments. The conformity assessment in

question here retards technological developments.

1. The texture-retention part of the testing (Appendix A) that wasdeemed necessary by CRI in order to make sure vacuums do not

damage loop pile carpet is performed on cutpile carpet. Not

only does this not make scientific sense, but it penalizes and

locks out technologies that make use of more powerful agitation

(i.e. brushing). For instance, a vacuum built for use on loop pile

carpet should not be tested on a cut pile, where it would fail this

deliberately limiting conformity assessment and be

marginalized in the marketplace unfairly and inappropriately.

a. The given CRI reasoning for this dichotomy is that the cutpile carpet


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texture from cleaning processes, as the loop pile would be

In other words,

items submitted for testing in one category would all pass

unless the test was specifically changed to fail a number

of them. This is unreasonable. If an efficacy test is

performed on loop pile carpet, the texture retention test

should also be performed on loop pile carpet.

b. This testing is especially unreasonable given the basequality of the carpet samples used. Despite a relatively

high market share due to its low price point, the former

CEO of Shaw Industries admits that this quality of carpetAppendix N)

To deliberately create a test for the purpose of showing

texture damage to a carpet sample by a cleaning process,

when that carpet sample would be damaged by walking

on it for a month anyway, amounts to shifting warranty

blame inappropriately. It also amounts to a commercial

interest in the certification process by voting

CRI members who have included the CRI SOA into their

warranties, which violates Guide 7, 4.2.m.

2. The CRI Seal of Approval has become a market requirement inseveral arenas, as it has been incorporated into warranties,

various pieces of legislation and national standards.

a. There is pressure on manufacturers of products toenretards technological

developments (especially in the commercial arena).


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b. One consequence of the continued use of this conformityassessment is the filtering out of equipment built for

specific carpet constructions.

C. Guide 7, 5.2, states that requirements should be clearly specified. They arenot; please seeIA, above andIIIA2, below.

D. Guide 7, 5.2 and 17007, 5.2.9 also state that conformance assessmentrequirements be free from subjective elements. They are not.

1. The evaluation of results from theStandard Laboratory TestPractice for Measurement of Surface Appearance Change ofTextile Floor Covering as a Result of the Vacuuming Process

(ibid.) is subjective.

a. Lab technicians judge the results by comparing testedcarpet samples to reference pictures.

b. This is subjective in itself, but in addition, the referencepictures used to judge the carpet samples against were

created via subjective opinion in the first place. It was

decided essentially howfuzzy a carpet could be before it

voided the warranty, and pictures were taken of that

point. These pictures were created from carpet

-off, a cost-control

Based upon current appearance retention

warranties a maximum level of appearance change

ibid.,

page 5)

2. After vacuuming, the yarns in a carpet sample used in the soilremoval test (Appendix B) must be returned to the positions


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they were in before they were vacuumed. This is because

measured amount, in (conjunction) with variation in carpet

fiber to detector distance is believed to be the largest source of

Appendix C)

a. Returning yarns back to their original positions istechnically impossible without exacting study.

b. Nevertheless, a technician brushes the yarns with a rakein order to attempt to return the yarns back to a

Appendix B, 6.8) Thereis no definition of what

there is no proscribed number of brush

strokes; there is no monitored pressure or speed. The

technician goes through inconsistent and subjective but

token motions in an attempt to do the impossible.

XRF peak intensity drops as the inverse square of the

distance from the fiber to the detector; hence, it is

important that the samples be brushed or combed before

they are scanned to maintain a constant position.I)t is

essential that pile orientation and its distance relative to

ibid., 12.2.8) Being so

essential, a non-subjective method should be employed

for correction.

3. In calibrating the equipment for the soil removal testing, one isdirected to raise the carpet sample up with shims until it

(ibid., A1.1.4)

. One is directed to accept the

detected in the sample, but if there are, one must incrementally


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lower the sample until the amount of backing elements is

thus creates

another point of subjectivity in the method.

Because this testing attempts to measure trace quantities,

amount of strontium found in the backing as is allowed in the

calibration would add to the strontium used in the test soil, thus

adding error to calculations and causing false positives.

E. Guide 7, 5.3 states that standards should be written in such a way thatvariants are clearly defined and indentified. CRI has failed to do this.

1. ronze, Silver, and Gold categories are described as basedon quantitative analysis. However, with all the issues involved

with the soil removal efficacy testing using XRF, these categories

are qualitative, misleading and unclear--until proper validation

and other method requirements have been proven. (Appendix

D)

2. Passing variants are listed one way on the CRI web site, but areconfusingly stated as tested in different ways elsewhere on their

site. Please refer toI.A.2.a and I.A.2.babove.

F. Guide 7, 6.1 states that test methods should be consistent with the purposeof the standard. At least one of the specified test methods for conformity

assessment,Standard Test Method for Evaluation of Solid Particulate

Removal Effectiveness Using X-Ray Fluorescence Techniques for

Evaluating Cleaning Effectiveness of Residential/Commercial and

Central Vacuum Cleaners (Appendix B), has not been shown to be

relevant to the purpose of the standard. It has not been shown to be


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correlated to real-world dirt removal, or to another laboratory test method

that has.

1. cleaning tests. There is no established correlation between field

and laboratory results. However it is reasonable to assume that

in most cases, a vacuum that performs well in the laboratory will

ibid., 5.4.)

a. It is not reasonable to assume a correlation.

b. Again, this test method is replete with issues that makevalidating and correlating paramount before any

assumptions should be allowed. Please refer toAppendix

D.

2. CRI has not provided any proper correlation or validationmaterials to show that their tests function as stated and that

they are relevant to real-world experience. This test method has

not been shown to be consistent with the purpose of the

standard, as required in 6.1.

3. Further, ISO/IEC 17007, 5.4.8, specifies that test methodsfollow metrological principles concerning validation,

measurement traceability, and estimation of measurement

uncertainty

test methods (AppendicesA, B, andE) do not. None of this

information exists or is available, despite private and public

requests, and despite a public CRI response to the contrary

(Appendix F). When validation is discussed, inappropriate,

incomplete and misleading studies are referred to. Robust


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validation, traceability, and uncertainty principles should be

followed as is required by 17025.

G. Guide 7, 6.1 also states that unambiguous, repeatable and reproducible results, so that the results of

1. Tests have not been shown to be accurate. Further, outsideexperts question that the test method (Appendix B) can be

accurate. (Please refer to the bibliography included inAppendix

D; additionally, currently anonymous peer reviewers of

Appendix D may be consulted, upon request and upon approvalby them.)

2. Test results are ambiguous. Treating an unproven qualitativemethod as a definitive and quantitative method creates

unwarranted trust in ambiguous product rankings and

certifications. (Please refer toAppendix Dfor the qualitative

versus quantitative nature of this test.)

3. Repeatable and reproducible results are not available. The fewother laboratories solicited have refused to get involved.

(Unanswered technical questions and cost have been given as

reasons for non-

Appendix B) Further, since no calculation methods are

provided in the test method protocol, a second laboratory would

be unable to follow the protocol even if they so chose.

4. If three samples are tested and averaged, with two of the threetests scoring high removal percentages and one scoring low,

there is no consideration that the one low score may be an

outlier. All results are averaged without thought to the data or a


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protocol in place to consider such errors. The low, outlying

score would bring down the average and thus create a false

ranking that makes the results incomparable.

H.ne

equipment as to ensure that comparable testing can be conducted by all

ISO/IEC 17007, 5.2.4 states that test methods should be

ted party may carry out the

Any interested party may not carry out the testing.

1. The CRI standard, which in the absence of any such nameddocument is taken to mean the various criteria and testing

protocols/methods, does not provide enough information to

for

example, are:

a. what calculations are performed by software

b. how results are derived from raw data

2. CRI publicly states that no one besides their contractor,Professional Testing Laboratory, has shown interest in doing the

testing. (Appendix F) This statement is untrue.

a. On one hand, CRI states that others are using thetechnology for testing. (Appendix I)

b. Yet others, such as Racine Industries, have expressedinterest but have been denied the ability to perform the

testing. (Appendix Q) CRI disallows certain parties from

performing the testing, with the justification that this


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discrimination is to ensure the credibility of the program

(Appendix I). This justification ensures and indicates the

failure of CRI to comply with Guide 7, 6.5 and ISO/IEC

17007, 5.2.4 to

conducted by all involved parties.

II. ISO/IEC Guide 65, 4.2.j requires CRI to employ personnel to have the

Guide 65, 5.5.1 similarly requires

competence in making required technical judgments and framing and

implementing policies. CRI has shown on several occasions that there is not

a sufficient level of expertise and they are unable to properly communicatetechnical details; highly important technical aspects of the testing are not

understood by CRI. CRI often shares incorrect technical information, with

both the public and CRI committee members, who vote on certification issues.

Some examples:

A. the design of the instrument that decreases the signal as the source is

moved farther from the instrument. Hence it is critical to present the

carpet fibers in the same position each time it is scanned. The carpet must

Appendix C) In other words, sample distance and

brushing are critical. However, when asked why a carpet sample needs to

be brushed during the testing, or when asked about concerns of sample

distance, is that carpet samples are groomed just like the

IICRC S100 standard. It is part of the cleaning process, and that

(Appendix J)

B. Press releases refer to the accuracy and precision of the efficacy test,alternately saying that the CRI testing can identify or quantify soil to a

precision or accuracy of four decimal places.


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1. CRI confuses the terms accuracy and precision and seeminglyuses them interchangeably. (Appendix K, 1 and 2)

2. CRI confuses the definitions of identification and quantification.(Appendix K, 3)

3. CRI uses aaccuracy numbers in theirmarketing and given technical information as their own.

(Appendix K, 4) They seem to assume that because a piece of

test equipment had a certain level of accuracy in identifying

elements in one kind of test method, that their related piece ofequipment will work how they wish an SOA test, and to the

same level of accuracy and precision.

4. Section 5.4.1 of ISO/IEC 17007 asks for what is acceptable interms of uncertainty of measurement, accuracy, reproducibility,

and repeatability. CRI has not been able to produce this

information. Despite the above precision and accuracy

references in 1, 2, and 3 above, no statements about precision

and accuracy may scientifically be made (Appendix B, page 8),

due to lack of information.

III. ISO/IEC Guide 65, Section 6, requires a certification body to give due notice

take account of views expressed by interested parties before deciding on the

met these requirements.

A. CRI does not procedurally give an opportunity for interested parties orconcerned stakeholders outside the CRI to comment on or to be informed

on certification requirement changes.


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1. CRI does not publish consideration of changes, and numerousstakeholders are ignorant of potentially business-changing

decisions happening behind closed doors. Stakeholders submit

no views on changes because they are unaware the topic is being

discussed; the opportunity to comment is not given. Please see

the blog atAppendix G, created by an industry professional and

stakeholder discussing being excluded from participation.

2. Seal of Approval test procedures are changed without notice tocustomers. Based on criteria posted on the CRI web site, Racine

Industries participated in an SOA conformance test; the

equipment submitted was expected to pass easily. However,

when we received our report (excerpt, Appendix S), we noted

that the original sample specification had beencrossed out and

replacedwith a handwritten new specification. The specified

carpet sample for testing was replaced with another, without

consulting us. The result being that the equipment was failed.

If we had been consulted, we would have refused the test and

would have avoided being invoiced for a test we did not order.

Following Guide 65, Sections 4 and 6 may have prevented this.

[It is unknown if equipment tested before this specification

change occurred has been retested so that it would be more

comparable to more current conformance assessments; if not,

there are further ISO/IEC 17007 4.5 issues.]

B. CRI also neglects to give due notice to committee members who vote onrelated matters. For example, meeting agendas are sometimes sent just

before a meeting and contain little if any detail to review(Appendix H).

Certification-related topics are frequently voted on quickly with no

a

sentence heard at many meetings.


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IV. ISO/IEC 17007, 5.2.11, requires the use of SI units for measurements. CRI isinconsistent in this regard. See test methods at AppendicesA, B, andE.

V. ISO/IEC Guide 65, 4.2.p requires a certifying body to have policies andprocedures in place for handling certification-related issues received from any

uality

and Procedure Manual in their Carpet and Rug Institute Quality Manual and

cites it as part of their Quality System (and likely has submitted this document

to ANSI for approval), CRI also states that there is no Policy and Procedure

Manual available. (Appendix L) Denying the existence of and thereforeaccess to a Policy and Procedures Manual prevents due process and violates

the purpose and intent of numerous requisites in Guide 65.

VI. ISO/IEC Guide 65, 7.2 requires that a certification body keep a record of allappeals, complaints and disputes and remedial actions relative to

certification, to take appropriate subsequent action, and to document the

action taken and its effectiveness. CRI denies, ignores or is otherwise unable

to provide evidence of serious questions regarding the testing program.

A. response to a question asking if a letter existed thatcontained serious technical questions regarding some of the SOA test

Appendix O)

B. A draft version ofA Discussion Regarding a Novel Method: the Use of X-Ray Fluorescence for Quantitative Analysis of Elements in Carpet

(Appendix D) was sent to CRI March 25, 2010. (Appendix P) There was

no response from CRI; that is, there was no response until the paper was

finalized and made public several months later. The response finally

elicited from CRI consisted of a dismissive press release, which included


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no offer of remedial action or other attempt to work with the testing

problems (see their non-substantive public response atAppendix F). As is

required in Guide 65, 7.2, has CRI documented the ignoring of the

Discussion paper until it was published, and does the record reflect how

they voted tonot respond furtherafter their press release and how

effective their response has been? These actions and inactions cannot be

VII. ISO/IEC Guide 65, 4.2m and 4.2n require that those involved be free fromcommercial, financial, and other influential pressures. Guide 65, 4.4 refers to

conflict of interest in subcontracting.

A. CRI owns a major piece of prohibitively expensive testing equipment thata CRI contractor uses to perform testing for CRI. CRI has a vested interest

in the use of this equipment, and thus cannot be considered independent

from its testing contractor.

B. This contractor is also a voting CRI committee member; this contractorcontrols the access and translation of (self-generated) technical data and

therefore has strong influence regarding committee voting on certification

program issues.

Conclusion

Participation in CRI programs or attending CRI meetings does not equal confidence in

the testingnumerous manufacturers feel forced to participate because of market and

legal pressures such as warranty requirements, legislation, and other standards and

procurement specifications that have agreed to incorporate a CRI approval as a

prerequisite. According to the National Institute of Standards and Technology,

voluntary consensus standards may be rendered mandatory when referenced in

regulations or procurement specifications, and may be rendered quasi-mandatory due

to conditions in the marketplace. (Appendix R) These qualifications apply here, and in

effect render the CRI SOA programs non-voluntary for manufacturers who desire to


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continue selling their products. These pressures keep stakeholders paying for testing

when they otherwise might not be, and keep stakeholders interested in seeing rigor in

the standards process: livelihoods are at stake. Interest, presence at meetings, and

program participation do not indicate that a stakeholder condones or endorses the

process or outcome, or is otherwise in consensus with CRI.

The outlined examples of issues above indicate that much work still needs to be

attempted and accomplished. However, CRI is not interested in pausing and doing the

scientific work required first; they have instead chosen to garner popular support rather

than factual data to further their program acceptance.

product ranking scheme into the

marketplace, with no successful method validation studies behind it, no passing peer

review by independent experts in the specialized lab technology utilized, and no public

due process used.

Instead they This question cannot be allowed to

sweep aside the ISO/IEC compliance requirements for technical rigor, openness,

consensus and other process safeguards that ANSI stands for.

Sincerely,

Deborah Lema

Research and Education

Racine Industries, Inc.

Cc:

Reinaldo Figueiredo, Senior Program Director, Product Certification Accreditation at ANSI

Nikki Jackson, Program Manager, Product Certification Accreditation at ANSI

Shahin Moinian, Chair, ANSI Accreditation Committee for Product Certifiers

Ken McIntosh, Senior Technical Director at CRI

Pat Jennings, Technical Manager and Seal of Approval Coordinator at CRI


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APPENDICES

Note: ISO/IEC Guide 65, General requirements for bodies operating product

certification systems, as well as related and incorporated guides and standards referred

to above and more, are available at www.ansi.org.

Appendix A

CRI TM 114:Standard Laboratory Test Practice (f)or Measurement (o)f Surface

Appearance Change (o)f Textile Floor Covering (a)s (a) Result (o)f (t)he Vacuuming

Process.

http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_114.pdf

Also perhaps of interest,Assessment of Carpet Appearance Change using the CRI

Reference Scales: http://www.carpet-

rug.org/technical_bulletins/0307_CRI_TM_101.pdf

Appendix B

CRI TM 112: Standard Test Method for Evaluation of Solid Particulate Removal

Effectiveness Using X-Ray Fluorescence Techniques for Evaluating Cleaning

Effectiveness of Residential/Commercial and Central Vacuum Cleaners.

http://www.carpet-rug.org/technical_bulletins/1003_Test_Method_114.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_114.pdfhttp://www.carpet-rug.org/technical_bulletins/0307_CRI_TM_101.pdfhttp://www.carpet-rug.org/technical_bulletins/0307_CRI_TM_101.pdfhttp://www.carpet-rug.org/technical_bulletins/0307_CRI_TM_101.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_112.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_112.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_112.pdfhttp://www.carpet-rug.org/technical_bulletins/0307_CRI_TM_101.pdfhttp://www.carpet-rug.org/technical_bulletins/0307_CRI_TM_101.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_114.pdf


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Appendix C

Asbury, G, and Shannon, RF, Quantification of (f)oreign (c)ontaminant from flooring

surface through XRF (t)echnology. Attached separately.

Relevant excerpt:

decre(a)ses the signal as the source is moved farther from the instrument. Hence it is

critical to present the carpet fibers in the same pos(i)tion each time it is scanned. The

Page 6,

Discussion of Errors)

Appendix D

Lema, D,A Discussion Regarding a Novel Method: The Use of X-Ray Fluorescence for

Quantitative Analysis of Elements in Carpet.

Attached separately; also available here: http://www.hostdry.com/whitepaper.pdf.

Appendix E

CRI TM 115:Standard Laboratory Test Practice (f)or Determining the Power Use

Effectiveness of Residential and Commercial Vacuum Cleaners.


CRI TM 113:Standard Laboratory Practice (f)or Quantifying Respirable Particulate

Emissions Generated by Residential/Commercial Vacuums and Central Vacuum

Systems.

http://www.hostdry.com/whitepaper.pdfhttp://www.hostdry.com/whitepaper.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_115.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_115.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_113.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_113.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_113.pdfhttp://www.carpet-rug.org/technical_bulletins/1003_Test_Method_115.pdfhttp://www.hostdry.com/whitepaper.pdf


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Appendix F

"There is nothing [in the document] that has not been addressed either before or since

the SOA program was introduced at NASA's John F. Kennedy Space Center in the Fall of

2004(*)," Braun said. "It is disappointing to see questions listed as unanswered when

we have, in fact, answered Racine Industries on multiple occasions in writing."

http://www.scrt.org/news/73-cri-defends-validity-of-seal-of-approval-testing

in the above press release

include:

1. Having been asked for method validation studies, CRI replies that one has beendone but is in the peer review process (and is therefore unavailable). That is the

same response we have heard for years:

-----Original Message-----

From:[email protected]

Sent: Friday, November 07, 2008 12:17 PM

To: Debbie Lema

Subject: Re: Encapsulation Study

The copyright is held by CIRI; don't know the status of publication

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Shaw Industries does not provide or endorse any opinions, conclusions or other

information in this message that do not relate to the official business of the company or

its subsidiaries.

**********************************************************

-----Original Message-----

From: [email protected] [mailto:[email protected]]

Sent: Friday, November 07, 2008 8:21 PM

To: Debbie Lema

Cc: [email protected]

Subject: Re: Shaw and CIRI Encapsulation Study- Paper.

Debbie Lema, Host/Racine Industries:

D:- are you referring to the separate paper Carey M presented at UNLV in 2007? If so,

pls. provide the full title from PowPt as the actual reference, clarity.

Note however that the detailed, full text CIRI 2007 papers have not [yet] been published

or made available. We have been looking for an approp. peer reviewed research journal

capable of reviewing and publishing the lengthy 2007 papers, as such.

I have finally made progress this year toward that goal...

In any event I do not have them; assume that Jim Harris Sr, CIRI HQ and/or the CIRI

conf. proceedings reviewers do so. It's Jim Harris' to reply and determine their public

sale; [we can discuss access and their distribution].

Did receive "Fritz@CRI" PowPt and DVDs for post-election read.

Steve Spivak.

[No further response from Jim Harris.]


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2. CRI provides pictures of some of the designer soils used in the testing andcollected dirt as evidence of validation. However, these pictures contain little

useful information (e.g. numerical data comparing micron size) and have no

relevance to a measurement method validation.

3. CRI has recently provided some pages of undefined and untraceable numbers asevidence of correlations between tests. These numbers are useless in this offered

form, but moreover appear to indicate a lack of correlation.

*Correction: the program introduction at the Kennedy Space Center happened in 2005.

Appendix G

http://realdirtoncri.wordpress.com/

A sample quote, illustrating the exclusion of a main stakeholder type by CRI:

and residential professional cleaners. Cleaners complaints and criticisms were being

brushed aside,articlesby authorities in our industry completely ignored, and even

officially filed complaints

Appendix H

1. An example of a one-day notice of meeting agenda, amounting to aboutfour or five

business hours for preparation, accompanied by review material for only two of ten

65:
http://realdirtoncri.wordpress.com/http://realdirtoncri.wordpress.com/http://realdirtoncri.wordpress.com/2010/07/11/scientists-vs-cleaners/http://realdirtoncri.wordpress.com/2010/07/11/scientists-vs-cleaners/http://realdirtoncri.wordpress.com/2010/07/11/scientists-vs-cleaners/http://realdirtoncri.wordpress.com/2010/07/08/nasa-logo-no-questions-allowed/http://realdirtoncri.wordpress.com/2010/07/08/nasa-logo-no-questions-allowed/http://realdirtoncri.wordpress.com/2010/07/11/scientists-vs-cleaners/http://realdirtoncri.wordpress.com/


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From: Ken McIntosh [mailto:[email protected]]

Sent: Tuesday,August 24, 2010 4:12 PM

To: (Relevant Committee, addresses deleted)

Cc: (Addresses deleted)

Subject: C&M IMT Meeting 8-25-10

Agenda and review material for the subject meeting.

If you have additional agenda items, please let me know ASAP.

Ken McIntosh

To sign up for CRI's newsletter, subscribe on our website at: www.carpet-

rug.org/newsroom.cfm#subscribe

To sign up for CRI's blog, subscribe at:www.criblog.org

****************************

This e-mail and any files transmitted with it are confidential and intended solely for the

use of the individual or entity to whom they are addressed. If you have received this e-

mail in error please notify the originator of the message. Any views expressed in this

message are those of the individual sender, except where the sender specifies and withauthority, states them to be the views of The Carpet and Rug Institute.

****************************

2. Below is an email example of how certification requirement changes may be

completed at CRI. The email gives committee members less than one business day to

committee chairman.

----- Original Message -----

From: "Ken McIntosh"

To: (Relevant Committee, addresses deleted)

Sent: Friday, October 12, 2007 1:32 PM
http://www.carpet-rug.org/newsroom.cfm#subscribehttp://www.carpet-rug.org/newsroom.cfm#subscribehttp://www.carpet-rug.org/newsroom.cfm#subscribehttp://www.criblog.org/http://www.criblog.org/http://www.criblog.org/http://www.criblog.org/http://www.carpet-rug.org/newsroom.cfm#subscribehttp://www.carpet-rug.org/newsroom.cfm#subscribe


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Subject: SOA-GL Vacuum Cleaner Testing and Certification Program

To: C&M IMT Members

The following issue was presented to Carey Mitchell, Chair of the C&M IMT, regarding

how to address the issue and move forward with testing vacuum cleaner machines under

the SOA-GL Vacuum Cleaner Testing and Certification

Program:

"The XRF soil composition contains Zinc Oxide which is an extremely

sticky material that vacuum cleaners are not designed to remove from

carpet. The rationale for using Zinc Oxide in the XRF composition atthe start of the SOA cleaning program was based on chemical and

extractor cleaning and not vacuum cleaner testing which are designed

to remove dry particulates."

Carey Mitchell suggested and approved using the XRF soil composition in testing

vacuum cleaners but to determine the soil removal percentage without inclusion of the

ZnO component. Real world soil does contain some sticky component which affects dry

soil removal; so this is a reasonable approach.

We need a decision quickly to allow time to get together data for the ISSA show in

Orlando in less than 2 weeks. We can tweak the amount of the ZnO component at a later

date if it appears that it adversely skews the pass/fail criteria.

As per Carey Mitchell's request, please call me at 706-428-2105 by noon Monday, Oct 15

if you desire to discuss the recommendation. As indicted, time is critical to have vacuum

cleaner test data to discuses at the ISSA show.

Thanks,

Kmc


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To sign up for CRI's newsletter, subscribe on our website at:

www.carpet-rug.org/newsroom.cfm#subscribe

****************************

This e-mail and any files transmitted with it are confidential and intended solely for the

use of the individual or entity to whom they are addressed.

If you have received this e-mail in error please notify the originator of the message. Any

views expressed in this message are those of the individual sender, except where the

sender specifies and with authority, states them to be the views of The Carpet and Rug

Institute.

****************************

Appendix I

The following excerpts are from one CRI lobbying effort to have their programs written

in as legislative requirements:

be and arecurrently being performed by other private labs, including several vacuum cleaners

Page 4)

certification purposes; however, the program-party testing

https://greencleaning.ny.gov/Docs/NewCleaningTechnology.rtf
http://www.carpet-rug.org/newsroom.cfm#subscribehttp://www.carpet-rug.org/newsroom.cfm#subscribehttps://greencleaning.ny.gov/Docs/NewCleaningTechnology.rtfhttps://greencleaning.ny.gov/Docs/NewCleaningTechnology.rtfhttps://greencleaning.ny.gov/Docs/NewCleaningTechnology.rtfhttp://www.carpet-rug.org/newsroom.cfm#subscribe


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Appendix J

Below are examples of CRI statements and answers that show the lack of necessary

technical expertise or desire to communicate the information that members, other

stakeholders, and the public need to make business decisions and/or provide input,

perform, or vote on certification matters.

1. Question : Why does the carpet sample being tested need to be brushed so that the

readings are more accurate if the readings detect all the soil through the fibers?

CRI Answer: The carpet is groomed just like the IICRC S100 standard. It is part of the

cleaning process.

president Werner Braun, available atwww.mikeysboard.com)

[The correct answer would have been that

the design of the instrument that decreases the signal as the source is moved farther

from the instrument. Hence it is critical to present the carpet fibers in the same position

(Appendix C)]

2. Question: Because questions of fairness to differing equipment and methods havearisen, why does not CRI publish at least the basics of their test protocol(s)?

CRI Answer: Primarily because it is based on years of research and data that is not

easily digested.

available atwww.mikeysboard.com)

[CRI also stated in the same interview

However, those contacting the lab for detailed protocols have been told there is no

written protocol available from them. (Reference below atAppendix K.)]
http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/


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3. Question: Why are there no water-soluble soils included in the test, when water is

used to suspend soils?

CRI Answer: Initially, research was done on a variety of soiling compounds and a

water soluble one was included. What we found during the early research was that it

was removed essentially by everything and did not offer us any manner to

differentiate in the testing, so it was replaced.

CRI president Werner Braun, available atwww.mikeysboard.com)

[The correct answer would not have been that it was removed essentially by everything,

but thatWe beli-soluble

components washed out, however it could be argued that table salt (NaCl) would be acommon particle found in carpets. Chemically Potassium Bromide, (KBr) is similar to

At most, only 62% of KBr was removed in trials. The KBr percent removedafter chemical extraction is two percent less than after it was vacuumed. This of course

cannot be, and is likely due to a wicking of the KBr to the fiber tips. This wicking

problem is why in future testing KBr is not used.(Appendix C)]

4.

to a carpet sample, clean the sample with a vacuum or extractor and quantify the precise

(CRI Press

Release)

[Quantification and precision are in question in this test. Marketing the test as accurate

As stated previously, no statement

about precision may be made (Appendix B), and XRF experts question that the test is

quantitative rather than qualitative (Appendix D)

comes from a different test methodnot used in the SOA program (CRI Press Release).
http://www.mikeysboard.com/http://www.mikeysboard.com/http://www.mikeysboard.com/http://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://www.carpet-rug.org/news-room/press-releases/050912_SOA_XRF_launch.cfmhttp://www.carpet-rug.org/news-room/press-releases/050912_SOA_XRF_launch.cfmhttp://www.carpet-rug.org/news-room/press-releases/050912_SOA_XRF_launch.cfmhttp://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://floorcoveringweekly.com/ME2/dirmod.asp?sid=E8BB079C64B042958E6764D7B3CE8058&nm=Archives&type=Publishing&mod=Publications%3A%3AArticle&mid=8F3A7027421841978F18BE895F87F791&tier=4&id=EA9CBC428D544BC9B76CD17CF9A3E0F4http://www.mikeysboard.com/


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Appendix K

From: lisa smith [mailto:[email protected]]

Sent: Monday, February 26, 2007 1:58 PM

To: Debbie Lema

Subject: Re: CRI

Hi Debbie,

I called and talked to Lloyd Cooper at the lab. He said there is no WRITTEN protocol

available, that you would have to get that from CRI. He also said quite a bit more that

was interesting. Too much to type for me, so give me a call @ (number deleted) and I'llfill you in. You can call in the evening too, it's a home office.

Take care,

Lisa

Appendix L

From: Deborah Lema [mailto:[email protected]]

Sent: Wednesday, August 25, 2010 10:05 AM

To: Ken McIntosh

Subject: Polcies/procedures

Hi Ken,

Will you please send me the CRI policies/procedures?

Thanks,

Debbie
mailto:[email protected]:[email protected]:[email protected]


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From: Ken McIntosh [mailto:[email protected]]

Sent: Wednesday, August 25, 2010 9:30 AM

To: [email protected]

Cc: Louise Dobbs

Subject: Fw: Polcies/procedures

Debbie:

Please note that your request is being referred to Louise. She is the expert and keeper of

this information.

Km c


Sent: Wednesday, August 25, 2010 3:48 PM

To: Louise Dobbs

Subject: RE: Polcies/procedures

Thanks in advance, Louise!

From: Louise Dobbs [mailto:[email protected]]

Sent: Thursday, August 26, 2010 7:50 AM

To: Deborah Lema

Cc: Ken McIntosh; Werner Braun


The requested document is attached.


Sent: Thursday, August 26, 2010 10:14 AM

To: Louise Dobbs



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Thanks Louise!

It looks like the procedures are separate, in the by-laws? May I have those too please?

Thanks some more,

Debbie


Sent: Thursday, August 26, 2010 1:38 PM

To: Deborah Lema


Requested document attached.


Sent: Thursday, August 26, 2010 4:31 PM

To: Louise Dobbs


May I please have the CRI quality manual as well?

The documents keep referring elsewhere; sorry!

Debbie


Sent: Friday, August 27, 2010 8:16 AM

To: Deborah Lema


Requested document attached.


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To: Louise Dobbs

Subject: RE: Policies/procedures

Louise,

I asked for the CRI policies and procedures,

but got policy. The policy referred to procedures in the bylaws, which in turn referred to

procedures in the quality manual, which in turn refers to a document called the Policy

and Procedures Manual, which sounds like what I wanted before? Will you please send

me that one?

Thanks again,

Debbie



To: Deborah Lema

Cc: Werner Braun

Subject: RE: Policies/procedures

The CRI Bylaws, CRI Policies, and CRI Quality Manual are what we have.

sure what else we can provide.

Appendix M

Rather than properly answering technical issues regarding an SOA conformity

assessment test method, CRI press releaseand

the CRI Cleaning and Maintenance Issues Management Team voted to not respond

further:
http://www.cleanfax.com/newsprint.asp?print=1&mode=4&N_ID=75275http://www.cleanfax.com/newsprint.asp?print=1&mode=4&N_ID=75275http://www.cleanfax.com/newsprint.asp?print=1&mode=4&N_ID=75275http://www.cleanfax.com/newsprint.asp?print=1&mode=4&N_ID=75275


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Item 9, MINUTES, Cleaning and Maintenance Issues Management Team, Meeting of

July 15, 2010:

C & M IMT Response to Host Press Release and Close the Issues of

Responses toHost Press Release Ken McIntosh The C&M IMT draft Response

[immediately below in italics] to the Host Press Release was presented for review and

discussion. Motion made and seconded to accept. Vote taken 12 Ayes, 1 Nay. Ken

McIntosh made a recommendation that based on the number of responses made public

relative to the HOST Press Release that carpet related industry groups cease and desist

from issuing any additional responses. A motion was made and seconded for the carpet

related industry to consider not issuing any additional responses to this particular HostPress Release. Vote taken 13 Ayes, 3 Abstentions.

New 7-7-10 Proposed Draft

Draft response from CRI Cleaning and Maintenance Issues Management Team

The CRI Seal of Approval program was developed over several years in what was then

viewed as a very slow, methodical process. At several significant stages, input was

sought from external scientists to ensure that our direction was valid. Input was

received numerous times from Dr. Michael Berry, retired US EPA scientist and

research professor, Dr. Alan Hedge of Cornell University, and Dr. Barry Ryan of the

Emory University School of Medicine. [Note: None of whom are XRF experts.]

It is interesting to note that during the development of the SOA program, Racine

Industries personnel were members of the committee and were routinely involved in

the discussions, the approval process, and the votes. No concerns, like those raised in

the new white paper by Racine Industries, surfaced during the process. [Note: this

statement is misleading and incorrect. CRI apparently has kept no records of concerns.]

Discussion Regarding a Novel Method: The

Use of X-

previously raised and answered issues and several new twists. At the request of the
http://www.businesswire.com/news/home/20100603005465/en/White-Paper-Racine-Industries-Questions-Validity-Carpethttp://www.businesswire.com/news/home/20100603005465/en/White-Paper-Racine-Industries-Questions-Validity-Carpethttp://www.businesswire.com/news/home/20100603005465/en/White-Paper-Racine-Industries-Questions-Validity-Carpethttp://www.businesswire.com/news/home/20100603005465/en/White-Paper-Racine-Industries-Questions-Validity-Carpet


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Racine CEO, Fritz Rench, in 2009, the C&M IMT listened to a presentation on his

perceived problems with the XRF test method. [Note: presentation was in 2008.] The

issues he raised were found at the time to be due to misinterpretations and a general

lack of understanding. Each of his issues was addressed in the meeting and later in

writing. [Note: some of his issues were indeed addressed, and addressed poorly,

incompletely, or dismissively. This document is available for viewing if desired by

ANSI; it is largely without technical relevance.] For instance, the claim that the test

protocol was not available to Racine is preposterous, because, as the protocol was

developed and adapted over the years, it was routinely distributed to the entire group,

which included Racine personnel.[Note: CRI has been repeatedly confused by the term

Please refer toAppendix J.2andAppendix K, showing the lack of availability of aprotocol to review.] The collective judgment of this committee is that the Racine white

paper appears primarily to be a reflection of dissatisfaction with a concept that does

not favor a particular product.

It is also instructive to note that the update of the Institute of Inspections, Cleaning,

and Restoration Certification (IICRC) S-100 Cleaning Standard is currently stalled due

to an appeal by Racine Industries. Since this is an ANSI standard,[Note: draft

standard] the process is clearly defined and the rules for achieving consensus are quitestringent. Racine Industries personnel served on the IICRC committee throughout the

process, and apparently no issues were raised. [Note: Untrue, but also irrelevant.]

Now, the IICRC has been presented with a 100 page appeal questioning the standard

similar to the situation with CRI's SOA program. This pattern suggests a company

with some personnel that are not working for the betterment of the carpet industry

when given the opportunity to fully participate but to discredit the hard work of other

industry members after the fact while offering no better alternatives. [Note: Rather

than answer with substance, CRI attempts to discredit legitimate requests for

information, transparency and scientific diligence.]

The focus in recent years on the indoor environment has brought attention to the value

of identifying cleaning methods and systems capable of maintaining carpets relative to

high quality indoor environments. While


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always available for improvement, they are fair they reasonably replicate real

world performance. [Note: how?] These programs utilize the best knowledge in the

industry today. The C&M IMT members are confident that the various CRI Seal of

Approval programs have contributed significantly to measurable improvements in

cleaning equipment, cleaning agents, and systems and have advanced the science of

cleaning. [Note: how?]

Appendix N

No less a carpet man than Bob Shaw once stated iMy 28-

ounce Stainmaster carpet is guaranteed to walk out in four weeks.

industry jargon for losing texture appearance via foot traffic or, more simply, getting

frizzy from walking on it.]

http://www.fcnews.net/index.php/2010/06/salesmanship-the-lost-carpet-fiber/

Appendix O

http://www.talkfloor.com/TalkFloorTVSegments.aspx?psGroupID=253

Appendix P

From: Fritz Rench

Subject: Fw:

To: "ken" , "Lee Phillips"

Date: Wednesday, March 24, 2010, 11:38 PM

Ken, Lee...
http://www.fcnews.net/index.php/2010/06/salesmanship-the-lost-carpet-fiber/http://www.fcnews.net/index.php/2010/06/salesmanship-the-lost-carpet-fiber/http://www.talkfloor.com/TalkFloorTVSegments.aspx?psGroupID=253http://www.talkfloor.com/TalkFloorTVSegments.aspx?psGroupID=253mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.talkfloor.com/TalkFloorTVSegments.aspx?psGroupID=253http://www.fcnews.net/index.php/2010/06/salesmanship-the-lost-carpet-fiber/


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ou are first class gentlemen. It's in that spirit I'm sharing

Debbie Lema's Draft Discussion re SOA testing of cleaning systems

ala XRF et al. She started it a couple of years ago. Then I stopped it,

only to ask her to re-start recently. She finished last week.

This material is not what was shared at the IMT session, Oct ' 08.

As noted then, I don't know anything about XRF technology.

My expertise is carpet performance relative to traffic and soil,

and some of the strategies and tactics re what to do about it.

A handful of people have received copies since Monday,

requesting their comments. The PR-strategy-survival worldis going to scream when they find out this draft has been sent

to you. But I just can't operate any other way.

For us this issue is about survival, not about personalities or agendas.

Best regards,

f

Appendix Q

The following series of emails contradicts the repeated CRI position that no one besides

their contractor, Professional Testing Laboratories, has indicated an interest in pursuing

the acquisition of XRF technology.

After KeyMaster copied CRI in on these emails indicating our interest in the XRF

equipment, subsequent repeated calls to KeyMaster (now Bruker) went unreturned.

The XRF equipment specified by CRI is not available to everyone.


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From:Deborah R. Lema

To:[email protected]

Sent: Wednesday, July 27, 2005 4:52 PM

Subject: XRF Research

Hi Lloyd,

Per your request this afternoon, I am emailing to give you my email

address so that you may respond with quotes for us. Thanks in advance

for putting that together.

Regarding the NASA habitat research, I've been pondering a bit and think

our product-- at least our method-- would be a brilliant solution for

surface cleaning in such situations. How can I help you in the research

of this idea, with or without XRF? As I said on the phone, we like to

share information here, so please count us as a resource.

I will serve as your contact at this juncture, and here is my info:

Deborah R. Lema

Research and Education Associate

Racine Industries, Inc.

[email protected]

800-558-9439

262-637-4491

FAX 262-637-0505

1405 16th Street

PO Box 1648

Racine, WI 53401

http://www.hostcarpetcleaning.com
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.hostcarpetcleaning.com/http://www.hostcarpetcleaning.com/http://www.hostcarpetcleaning.com/mailto:[email protected]:[email protected]:[email protected]


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Thanks again, Lloyd.

~Debbie

-------- Original Message --------

Subject:Re: XRF Research

Date:Wed, 27 Jul 2005 17:24:27 -0400

From:Lloyd Starks

To:Deborah R. Lema

References:

Thanks Debbie!

Lloyd


Subject: Fw: XRF research:

Date: Tue, 2 Aug 2005 13:03:36 -0400

From: Lloyd Starks

To: dlema

Debbie,

Let me know if you receive this!

Lloyd


*From:* Lloyd Starks

*To:*[email protected]

*Cc:* kmcintosh ; John Landefeld
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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*Sent:* Tuesday, August 02, 2005 12:24 PM

*Subject:* XRF research:

Debra,

Thanks for your interest in KeyMaster Technologies and our XRF technology and

instrumentation.

I think there are a several options available:

1. Create your own in house methods for evaluating your cleaning technology.

2. Work through the CRI for permission to apply current SOA XRF protocols.

3. Purchase instruments for your own in house use.

If you choose to develop your own protocols it would probably be more productive to

enter into a R&D agreement with KeyMaster Technologies to assist in your efforts. The

R&D agreement would include an XRF instrument for the term of the contract. At the

end of the contract you would have the option to return or purchase the instrument.

The R&D agreement is for 3 months for a fee of $30,000.00 which includes safety,

instrument training and a standard TRACER III instrument renewable on a month to

month basis. If it is determined that you will need a TRACER III V, (the NASA

instrument), the fee would be somewhat higher. Technical assistance is also included

and detailed in the agreement.

If you would like to work through the CRI you may be able to apply the protocol of the

CRI XRF SOA program. You would need to speak with Ken MacIntosh for details as a

consideration for Professional Testings Labs might be involved.

If you would like to purchase an instrument for in house use, we certainly welcome the

opportunity to quote your requirements.

Budget consideration:


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KTI TRACER III XRF instrument $35,000.00

KTI TRACER III V XRF instrument $45,000.00

Debra, I look forward to working with you to address your needs.

Regards

Lloyd Starks

KeyMaster Technologies, Inc

www.keymastertech.com

(706) 270 0841


Subject:RE: XRF research:

Date:Tue, 2 Aug 2005 14:35:23 -0400

From:Ken McIntosh

To:Lloyd Starks,

CC:John Landefeld , Werner Braun

, Joan Seelaus

Lloyd,

I believe you have composed several viable and interesting options for Host to consider.

CRI will be glad to offer suggestions and be available at any time to move the XRF

testing technology forward in the carpet related industries.

Kmc

[Silence from equipment manufacturer after this; no returned calls.]
http://www.keymastertech.com/http://www.keymastertech.com/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.keymastertech.com/


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Appendix R

A Guide to Documentary

Standards:

http://gsi.nist.gov/global/docs/USGuide_DocStds_2001.pdf, page 17.

"Non-consensus standards," "Industry standards," "Company standards," or "de facto

standards," which are developed in the private sector but not in the full consensus

process:

http://www.whitehouse.gov/omb/circulars_a119/#3 .

Appendix S
http://gsi.nist.gov/global/docs/USGuide_DocStds_2001.pdfhttp://gsi.nist.gov/global/docs/USGuide_DocStds_2001.pdfhttp://www.whitehouse.gov/omb/circulars_a119/#3http://www.whitehouse.gov/omb/circulars_a119/#3http://www.whitehouse.gov/omb/circulars_a119/#3http://gsi.nist.gov/global/docs/USGuide_DocStds_2001.pdf

Letter to ANSI Re CRI 10-6-10

Documents

Transcript of Letter to ANSI Re CRI 10-6-10