TITLE PAGE

CONFIDENTIAL

Note: This audit report and the information contained herein shall remain

confidential and shall not be disclosed to any person other than the auditee,

appropriate ANSI staff, the auditor, and, as appropriate, members of the reviewing

bodies (i.e., the Executive Standards Council and the ANSI Appeals Board). The

auditee may provide the audit information and reports received to whomever it

deems appropriate.

Introduction

The authority for ANSI to audit ANSI-accredited standards developers is included in

clause 4.1.3 of the ANSI Essential Requirements: Due Process Requirements for

American National Standards (ANSI Essential Requirements). The purpose of an audit is

to determine whether there is any evidence of non-compliance with the criteria for

accreditation and to ascertain as far as possible if the procedures and practices of an

ANSI-accredited standards developer continue to be consistent with the current ANSI

Essential Requirements. When possible, in a separate report, the auditor will recommend

changes to the operation of the auditee that are intended to increase efficiency or

effectiveness.

The ANSI Auditing Policy and Procedures allow an auditee to provide all relevant

standards material to ANSI via the mail or electronically under circumstances approved

by the Director of the ANSI Standards Developer Audit Program. The audit will then be

performed without an on-site review of the developer's standards related documentation.

It was determined that the Optics and Electro-Optics Standards Council (OEOSC) was

eligible for a mail-in audit.

Dr. H. Glenn Ziegenfuss served as the auditor. A pre-audit telephone conference was

held on 11 July 2006 with Gene Kohlenberg, Executive Director, OEOSC; Glenn

Ziegenfuss, ANSI Auditor; and Jay Moskowitz, Director, ANSI Standards Developer

Audit Program. This provided an opportunity for questions and answers from both

parties. The mail-in audit was conducted during July and August 2006 at the location of

the auditor.

Background

The Optics and Electro-Optics Standards Council (OEOSC) was formed in April 1993,

with participation by APOMA, COM, LEOMA, OSA, and SPIE. It has been serving as

the administrative sponsor and secretariat for the Accredited Standards Committee for

Optics and Electro-Optical Instruments (ASC OP) since its accreditation as an ANSI

Accredited Standards Committee on 23 February 2000. Some of the original sponsoring

organizations have discontinued their involvement, but the National Institute of Standards

and Technology has become a sponsor.

OEOSC has begun to provide training services for companies that want assistance in

testing their optical products optical surface appearance imperfections.

ASC OP sponsors two American National Standards, ANSI/OEOSC OP3.001-2001 and

ANSI/OEOSC OP1.002-2006. The first standard was developed using the Model

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Procedures for an Accredited Standards Committee. The second standard was developed

using procedures that were adapted from the Model Procedures for an Accredited

Standards Committee.

Scope of the Audit

The audit involved a review of the operations of OEOSC as related to standards

development and associated activities, including continuity of administrative oversight

and support of the standards activities. As it was determined by the Director, ANSI

Standards Developer Audit Program, that ASC OP qualified for a mail-in audit, all

available documentation concerning the development of their newly developed standard,

OEOSC OP1.002-2006, For optics and electro-optical instruments Optical elements and

assemblies Appearance imperfections, was reviewed. The previous audit reviewed the

development of their other standard.
This audit report, including the findings, is based solely on the standards and

documentation actually reviewed. The audit report should not be viewed or relied

upon as evidence of anything beyond the scope of the documentation reviewed. The

audit did not involve the accounting or financial aspects of OEOSC.
The audit took into consideration the practices and actions, records, and reports of

OEOSC in implementing the operating procedures to comply with ANSI criteria, rules,

procedures, and requirements including, but not limited to, the following items:

· Criteria for Accreditation
· Due Process Requirements
· Criteria for Approval and Withdrawal of American National Standards
· Other ANSI Requirements

Audit Objectives

The following audit objectives formed the basis of the audit:

· Based on the evidence reviewed, confirm adherence by OEOSC to the criteria

for accreditation.

· Based on the evidence reviewed, confirm that OEOSC procedures and

practices continue to be consistent with the approved procedures and with

current ANSI Requirements.

· Recommend changes in procedure when, in the opinion of the auditor, such

changes would result in more efficient or effective operations.

Summary of Audit Results

The audit identified areas where activities are notable, as indicated in Section 8A of this

report. Under separate cover, suggestions for potential improvements in efficiency and

effectiveness are offered for consideration.

The audit reviewed the recommendations

from the regular audit of the Accredited Standards Committee for Optics and Electro-

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Optical Instruments (ASC OP), held in December 2001, and efforts made to address non-

compliances. The results of this review are contained in Section 8B of this report.

The

audit also identified several areas where the auditor believed certain findings and

recommendations were appropriate, as indicated in Sections 8C and 8D of this report.

Conduct of the Audit

After initial preparation, including the completion of the pre-audit checklist by OEOSC,

the audit was conducted in three phases: an examination of records and documentation by

the auditor; development of audit findings, recommendations, and comments by the

auditor; and a post-audit conference with OEOSC staff.

Examination of Records and Documents

OEOSC provided the auditor with a copy of the completed pre-audit questionnaire

(Attachment A), as well as documentation substantiating the responses. A review of the

pre-audit questionnaire and the accompanying documentation provided the following

general findings:

OEOSC, as an ANSI-accredited standards developer, has unique accredited procedures,

the ASC OP Procedures for the Development and Coordination of American National

Standards, dated 2 May 2005. The standards development process is as follows: The

procedures have been adapted and updated from Annex A of the ANSI Procedures for the

Development and Coordination of American National Standards. There are a few items

that are not consistent with the current edition of the ANSI Essential Requirements that

should be addressed. These items are as follows:

a) In 3.1 d) and e) there is a referral to 11.3 regarding interpretations. Clause

11.3 just refers back to 3.1. There should to be a policy included in the procedures or as a

separate document indicating whether and how OEOSC handles interpretations.

b) In 5.4 interest categories are mentioned in the very general sense, but they are

not listed nor are they defined. The interest categories should be included either in the

procedures or in a separate document along with definitions of those categories. In the

14 July 2006 edition of these procedures, this item has been addressed. These new

procedures have not been submitted to ANSI for approval.

c) In Section 6, subgroups are discussed, but their official role in developing

standards is not defined. If the subgroups are responsible for any standards, they need to

be defined and they need to comply with the rules for balance, voting, and all the other

rules for standards committees. If they are only advisory to the main committee, that

should be so stated. In the 14 July 2006 edition of these procedures, the item is

addressed. However, changing these groups to consensus bodies may cause additional

problems with balance and participation due to the relatively low number of participants.

The 14 July 2006 edition has not been submitted to ANSI for approval.

d) In 8.1, reasons are required for all negative or abstain votes. Consideration

should be given regarding providing reasons for personnel matters and perhaps have this

requirement deleted for those items.

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e) In 8.6, the procedures need to be revised to reflect that all objectors need to be

advised in writing regarding the disposition of their comments and they also need to be

advised in writing regarding their rights to appeal. In the 14 July 2006 edition of the

procedures the second item has been addressed, but the first item has not. These new

procedures have not been submitted to ANSI for approval.

f) In 9.2, the procedures should be revised to reflect that ANSI no longer requires

two copies of the standard. The list of items in this clause should be updated to reflect

the current edition of the ANSI Essential Requirements. In the 14 July 2006 edition of the

procedures, this item has been addressed. These new procedures have not been submitted

to ANSI for approval.

OEOSC sponsors two ANSI-approved standards. The organization staff member

responsible for the maintenance of OEOSC's American National Standards is Mr. Gene

Kohlenberg, Executive Director.

Internationally, OEOSC is responsible for the TAG activities for ISO TC 172, Optics and

photonics. They participate in the standards development activities of this ISO

committee and propose OEOSC standards for adoption as ISO standards. They also

consider ISO TC 172 standards for adoption as American National Standards, but none

has been adopted to date.

Nationally, OEOSC does not have any formal relationships with other standards

developers, but members of OEOSC are members of other organizations, specifically

ASTM International committees.

The staff of OEOSC does not participate on the ANSI Organization Member Forum or

any other ANSI committee.

Since there is only one staff member in OEOSC, training consists of this person

monitoring the ANSI web site and other ANSI media for information on standards and

the requirements for American National Standards.

There was no project management mechanism provided in the data provided to track the

standards for OEOSC. Since they only have two standards, the auditor considers it

impractical to develop a system to track the standards.

For the most part, OEOSC provides information in electronic form to its consensus

bodies and to ANSI. In the beginning of the development of this standard some items

were handled in paper, but at the end of the process everything appears to have been

handled electronically.

OEOSC does not really have a Standards Interpretation Policy. It is mentioned in clause

11.3 of their Procedures for the Development and Coordination of American National

Optical Standards, but does not provide any detail on the mechanism for handling the

interpretations. According to OEOSC, no interpretations have been received in the past

year.

OEOSC has a Records Retention Policy. It is contained in Clause 14 of their Procedures

for the Development and Coordination of American National Optical Standards. It is in

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compliance with the minimum requirements of the current edition of the ANSI Essential

Requirements.

OEOSC has a Metric Policy. It is contained in Clause 16 of their Procedures for the

Development and Coordination of American National Optical Standards. It states that

the International System of Units (SI) is the preferred system for units of measure. In the

standard audited, metric units are used throughout without US customary units.

OEOSC does not have a Commercial Terms and Conditions Policy. A review of the

standard revealed that there were no commercial terms and conditions in the standard. In

the 14 July 2006 edition of their procedures, a new Section 18 has been added stating that

OEOSC will comply with the ANSI Essential Requirements regarding Commercial Terms

and Conditions. These new procedures have not been submitted to ANSI for approval.

OEOSC does not have a Patent Policy and reports that no patent issues have been raised

or identified. In the 14 July 2006 edition of their procedures, a new Section 17 has been

added stating that OEOSC will comply with the ANSI Patent Policy. These new

procedures have not been submitted to ANSI for approval.

According to the records at ANSI, the 2002 and 2003 Compliance Forms were not

submitted prior to the initiation of this audit. They were submitted during the conduct of

this audit.

The auditor reviewed the questionnaire completed by OEOSC (Attachment A), as well as

documentation substantiating the responses. All of the documentation necessary to

complete this audit was available.

The auditor emphasized the following specific areas in the examination of OEOSC

documentation:

A. Review of Documentation Indicating Evidence of Consensus and Due Process.

The auditor reviewed OEOSC OP1.002-2006, For optics and electro-optical

instruments Optical elements and assemblies Appearance imperfections.

A PINS form was submitted on 25 April 2002 with the title, "Optics and electro-optical

instruments Optical elements and cemented subassemblies surface imperfection." A

revised PINS form was submitted on 14 December 2002 with the revised title, "Optics

and electro-optical instruments Optical elements and assemblies Appearance

imperfections." Both were completed correctly and in timely fashion.

The first BSR-8 form was submitted but there was no copy in the documentation. The

initial public review was incorrectly listed in the 2 July 2004 issue of Standards Action

under the PINS section (see Attachment B). ANSI acknowledged the error (see

Attachment C) and it was re-listed in the 23 July 2004 issue of Standards Action for a

period of 60 days and a comment deadline of 21 September 2004 (see Attachment D). A

second BSR-8 form was submitted on 28 November 2005 after having addressed a

number of comments from ANSI staff on their first BSR-9 form. A single page of

changes to the document was included. The BSR-8 form was completed correctly. It

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was submitted after the consensus ballot was complete. A second public review

announcement for OEOSC OP1.002-2006 appeared in the 9 December 2005 issue of

Standards Action with a thirty-day comment deadline of 8 January 2006.

An initial BSR-9 form was submitted, on 25 October 2004 (see Attachment E), but ANSI

staff returned it with a request for clarification on several items (see Attachment F).

There were several problems with the responses on the form, but it did show a balanced

consensus body with four producers, three users, and five general interest members. A

second BSR-9 form was submitted, but it was also returned for additional information

(see Attachment G). There was no copy of this form in the documentation. The revised

form was submitted on 3 March 2006 (see Attachment H). During the audit, OEOSC

located an email message forwarding the revised form with the consensus body ballot

results to the members of the consensus body. The revised form was completed correctly

and included a complete consensus body listing including interest categories. However,

the consensus body was completely different from what was listed on the first BSR-9

form (nine producers, five general interest, and no users). The three users were now

listed as producers. There was also no documentation to explain as to whether the

members changed their interest category or whether the first BSR-9 form was in error.

The second BSR-9 form was submitted within one year of the close of the second public

review period.

ANSI provided a notice of final approval on 7 March 2006 and the announcement was

included in the 17 March 2006 issue of Standards Action.

B. Review of Documentation Indicating the Disposition of Views and Objections

There was a total of five ballots issued: 23 November 2003, 29 December 2003,

4 November 2004, 29 January 2005, and 12 July 2005. None of the ballots could be

considered recirculation ballots since they were all reissued because of an insufficient

response or they were rewritten due to comments submitted on the previous ballot. All of

the ballots were issued for a thirty-day period. Each included the issue date and the due

date. Reminder letters were sent about ten days before the end of the balloting period and

in some cases again right before the end of the ballot due date.

All of the comments and negatives were circulated to the members of the consensus

body, but the members were not asked to reaffirm or change their votes. Technically, this

was not a recirculation ballot, but instead the document was revised and sent out for

ballot again. Some of this reballoting appeared to be a reaction to the ANSI response to

the first BSR-9 form that was submitted and returned for clarification. After the last

ballot there were no negatives and only editorial comments to resolve. Since there were

no objectors, there were no notifications of rights to appeal sent.

Two public reviews were held. One was after the first two ballots and the second was

after the last ballot.

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The minutes (see Attachment I) of the 21 January 2006 meeting of the OEOSC

Committee on this standard discussed several changes that would be incorporated in the

next revision.

C. Balance and Interest Categories of Consensus Body

The auditor noted that there was no representation in the user interest category and an

participation fee. The participation fee is based on the number of employees at the

member's company. Apparently, the fee can be waived if the member teaches a course

related to the standard. There is nothing in the procedures regarding the waiver policy.

Nno one has been removed from the consensus body involuntarily.

OEOSC included documentation showing how they try to attract members of the US

TAG to ISO TC 172, Optics and Photonics, but there was little information documenting

any outreach efforts for the OEOSC domestic standards activity. There was a

considerable amount of correspondence showing how new memberships are processed,

and one indication that a potential member from Pakistan was discouraged from joining

(see Attachment J). There does not appear to be any restriction in the OEOSC procedures

regarding participants from other countries.

There was no evidence in the documentation submitted that the consensus body list was

circulated to the members on an annual basis as required by their procedures. However,

OEOSC reported that they maintain the consensus body list on their web site which the

ExSC deems sufficient in lieu of distributing hardcopies of the roster.

According to the final BSR-9 form, the consensus body is seriously out of balance (see

Attachment G). There were nine producers and five general interest members, with no

users. As noted earlier in this report, this is a significant shift in membership from the

original BSR-9 form. The procedures call for reasonable balance, with no dominance

from a single interest category. With a substantial majority of the members in the

producer category, this is not in compliance with the ANSI Essential Requirements.

The standard is not a safety or safety related standard, but the balance requirements were

not met in either case.

The numerical consensus requirements were met even though there was a relatively high

number of not returned ballots.

D. Appeals

OEOSC has an Appeals Procedure. It is contained in Clause 12 of their Procedures for

the Development and Coordination of American National Optical Standards. The

procedure mirrors the one that was used previously in the ANSI Procedures for the

Development and Coordination of American National Standards, except that it has been

updated to reflect that the ExSC does not participate in creating the appeals panel. It

meets the minimum requirements of the ANSI Essential Requirements. OEOSC reported

that they have had no appeals since the last audit.

In 8.6 of their Procedures for the Development and Coordination of American National

Optical Standards, each objector is to be notified of their right to appeal. As noted in the

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section above regarding recommended changes to these procedures, OEOSC needs to add

"in writing" when notifying objectors of their right to appeal.

E. Compliance with ANSI Requirements for Publication and Maintenance of Standards

In reviewing OEOSC compliance with ANSI requirements for publication of standards,

the auditor notes that OEOSC arranges for publication of their American National

Standards. The American National Standards include on the cover the words "Approved

American National Standard" and the approved ANSI Logo. The date of ANSI approval

is included on the title page. A unique alphanumeric designation is used to identify their

American National Standards. For some unexplained reason, the title of the published

standard was slightly different than the title included on the corrected PINS form, the

BSR-8 form, and the BSR-9 form. It appears to be only a small grammatical difference.

The title of the published standard is "For optics and electro-optical instruments Optical

elements and assemblies Appearance imperfections."

OEOSC announces the availability of their standards on their web site at

www.optstd.org

The standards are available in either paper or electronic form. The standards are also

available through the ANSI Store.

In reviewing OEOSC compliance with ANSI requirements for maintenance of standards,

the auditor noted that this audit only covered their newly completed standard, and the

previous standard has not yet exceeded the five-year review period.

Development of Audit Findings, Recommendations and Comments:

The auditor developed the following findings, recommendations, and comments:

The auditor noted the following:

The auditor noted that OEOSC encourages and promotes broad

participation of interested persons and organizations.

ii)

The auditor noted that OEOSC utilizes their web site (www.optstd.org) to

announce information for those who are interested and have access to the

web. The auditor believes that use of the web site increases the visibility

of the standards and potentially increases participation on the consensus

body.

iii)

The auditor noted that OEOSC makes a substantial effort to resolve all

comments and objections and to ensure that consensus is achieved. In

reviewing the actions taken, the auditor found that the consensus body was

willing to make substantive technical changes, even though the time for

approval of the standard was lengthened.

iv)

The auditor noted that OEOSC presently conducts the ANSI public review

after the conclusion of the consensus ballot and any attempts to resolve

objections. OEOSC staff indicated that the public review is held after the

conclusion of the consensus ballot because of the changes that are made to

the document as a result of the consensus ballots.

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The auditor noted that membership is not restricted on the basis of

technical qualifications. Participation is not conditional upon membership

in any organization.

vi)

The auditor noted that the interest category of participants is determined

through self-declaration.

vii)

The auditor noted that OEOSC has submitted a PINS form to ANSI when

the title of the standard changed.

viii)

The auditor noted that OEOSC submits ANSI PSA forms electronically,

thus reducing the potential for delays and errors.

ix)

The auditor noted that no appeals of the approval of the OEOSC standards

have been filed. The appeals process is outlined in Clause 12 of their

Procedures for the Development and Coordination of American National

Optical Standards.

The auditor noted that OEOSC does not have any formal liaisons with

other standards developers as the standard is unique and there is no need

for harmonization or coordination.

xi)

The auditor noted that OEOSC actively participates in international

activity in the area of standardization, specifically in ISO TC 172, Optics

and Photonics.

xii)

The auditor noted that OEOSC American National Standards are available

as individual documents, in paper or electronically, and in the ANSI

Standards Store.

xiii)

The auditor noted that OEOSC provided a written statement during the

course of the audit that the ANSI Patent Policy found in clause 3.1 of the

ANSI Essential Requirements will be used as the OEOSC patent policy.

xiv)

The auditor noted that the completed OEOSC 2006 Compliance Form is

on file with ANSI.

xv)

The auditor noted that OEOSC has a Policy on Evidence of Compliance,

which is contained in Clause 14 of their Procedures for the Development

and Coordination of American National Optical Standards. It is in

compliance with the minimum requirements of the current edition of the

ANSI Essential Requirements, and is on file at ANSI.

xvi)

The auditor noted that OEOSC has a Metric Policy, which is contained in

Clause 16 of their Procedures for the Development and Coordination of

American National Optical Standards and is on file at ANSI. It states that

the International System of Units (SI) is the preferred system for the units

of measure.

xvii) The auditor noted that OEOSC has recently revised their operating

procedures. The auditor noted that many of the concerns raised in this

audit report are addressed in the proposed revision provided in the 14 July

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2006 edition. The auditor further noted OEOSC intends to submit the

final version to ANSI as soon as possible after this audit.

The auditor reviewed the recommendations from the December 2001 regular audit

of OEOSC and observed the following:

2001 Audit Recommendation

. The auditor recommends that, in

accordance with clause 1.2.6 of the ANSI Procedures, ASC OP submit a

PINS form at the initiation of the project to develop or revise an American

National Standard, rather than ten days prior to the submission of the

BSR-8 form (this was also six months after accreditation of the

committee). In the opinion of the auditor such initiation begins when the

project is approved by ASC OP. Registration of projects using the PINS

form is designed to provide a central databank of information relative to

voluntary national standards. It is useful for providing direct information

to all interested parties and is a key element in planning and coordination.

It is therefore crucial that submission of a PINS form be timely.
2006 Audit Finding. The auditor noted that the PINS form was submitted

soon after the project was approved. This item has been fully addressed.

ii)

2001 Audit Recommendation

. The auditor recommends that, in

accordance with clause A.8.1 of the ANSI Procedures, ASC OP issue a

ballot that includes the four options of Affirmative; Affirmative, with

comment; Negative, with reasons, and Abstain, with reasons. As noted in

Part 7 of this report, no actual ballot was issued to the members of the

consensus body.
2006 Audit Finding. The auditor noted that the ballots issued included

the options of yes; yes, with comments; no, with comments; and abstain,

with comments. This item has been fully addressed.

iii)

2001 Audit Recommendation. The auditor recommends that, in

accordance with clause A.8.1.3 of the ANSI Procedures, ASC OP issue a

ballot for a fixed period of six weeks. In reviewing the standard, the

auditor found that no actual letter ballot was issued, although all members

of the consensus body apparently did submit a final vote.
2006 Audit Finding. The auditor noted that the ballot period in their new

procedures is thirty days, or earlier if all ballots have been submitted. All

ballots were issued for thirty days. This item has been fully addressed.

iv)

2001 Audit Recommendation. The auditor recommends that ASC OP

substantiate all votes in writing, particularly in those instances where the

vote is obtained via email or other electronic means. The auditor noted

that in two instances ASC OP recorded votes from members of the

consensus body but there was no back-up documentation verifying the

vote. Accurate record-keeping of votes cast is essential in order to provide

evidence of consensus.

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2006 Audit Finding. The auditor noted that all ballots were in the

documentation and recorded properly. This item has been fully addressed.

2001 Audit Recommendation. The auditor recommends that, in

accordance with clause A.8.7 of the ANSI Procedures, ASC OP report

final results of voting to the committee. The auditor found that the results

are reported only to

ANSI via the BSR-9 form. Methods of reporting can

include a written report or a report given at a meeting and so recorded in

the meeting minutes.
2006 Audit Finding. After a thorough review of all the documentation

submitted, the auditor was unable to find any evidence that the final voting

results were reported to the members of the consensus body. During the

audit, OEOSC located an email forwarded the final BSR-9 form and the

consensus body voting tally to the members of the consensus body. This

item has been addressed.

vi)

2001 Audit Recommendation. The auditor recommends that, in

accordance with clause 1.2.2 of the ANSI Procedures, ASC OP take

additional efforts to ensure that the committee is balanced and no interest

category is more than half of the total. The auditor reviewed the current

consensus body roster and found that there is only one producer, two

users, and four general interest members. In addition to being quite small,

there is a clear imbalance of members.
2006 Audit Finding. Although the balance situation has tilted in the

completely opposite direction, it is now out of balance with far too many

producers versus either of the other two interest categories. This area still

needs considerable effort and is not yet resolved.

vii)

2001 Audit Recommendation. The auditor recommends that, in

accordance with A.7.1 of the ANSI Model Procedures for Accredited

Standards Committees ASC OP ensure that meeting announcements are

made in ANSI's Standards Action. The auditor was unable to find

evidence that this was being done.
2006 Audit Finding. The auditor noted that OEOSC has made a

commendable effort in announcing meetings in Standards Action. There

was documentation showing announcements for seven meetings. This

item has been fully addressed.

viii)

2001 Audit Recommendation. The auditor recommends that, in

accordance with A5.5 of the Model Procedures for Accredited Standards

Committees ASC OP maintain and update the ASC OP membership list

and provide it to committee members at least once per year.
2006 Audit Finding. The auditor could find no evidence that the

membership list was being provided to the members on an annual basis.

During the audit, OEOSC reported that they intend to maintain the

membership roster on their web site. This item has not been addressed.

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The auditor found areas of non-compliance. The following findings and

recommendations are made to address these non-compliances:

The auditor recommends that, in accordance with clause 4.1.3 of the ANSI

Essential Requirements, OEOSC officially provide ANSI with their

current operating procedures and, if the changes are considered by the

ExSC to be substantive, the reaccreditation process shall be initiated. In

reviewing the 2 May 2005 edition of the Procedures for the Development

and Coordination of American National Optical Standards, the auditor

found that they are not in compliance with the current edition of the ANSI

Essential Requirements. The auditor also notes that these procedures were

submitted to ANSI almost one year later on 27 April 2006. The auditor

notes that several substantive changes have been proposed during the

course of this audit and are included in the 14 July 2006 version. The

auditor recommends that the new edition be completed after this audit and

submitted to ANSI in a timely manner. OEOSC is required by clause

4.1.3 of the ANSI Essential Requirements to notify ANSI of any changes

to procedures on record at ANSI. Further details regarding recommended

procedural changes are included in Section 7 of this report and in several

places in this section.

ii)

The auditor recommends that, in accordance with clauses 3.0 and 3.5 of

the ANSI Essential Requirements, OEOSC document the Standards

Interpretation Policy and provide ANSI with a copy. The primary purpose

for providing an Interpretation Policy is to protect the accredited OEOSC

from liability resulting from incorrect or improper interpretations. The

establishment of a formal method by which interpretations are offered

diminishes this risk of liability. The auditor considers the current

information in clauses 3.1 d), 3.1 e), and 11.3, to be inadequate. Further

details are contained in Section 7 of this report.

iii)

The auditor recommends that, in accordance with clauses 3.0 and 3.1 of

the ANSI Essential Requirements, OEOSC either develop a patent policy

or adopt clause 3.1 of the ANSI Essential Requirements as the OEOSC

policy. The auditor notes that OEOSC has included a proposal in the

14 July 2006 edition of the Procedures for the Development and

Coordination of American National Optical Standards. These new

procedures should be submitted to ANSI for approval.

iv)

The auditor recommends that, in accordance with clauses 3.0 and 3.2 of

the ANSI Essential Requirements, OEOSC document the Commercial

Terms and Conditions Policy and provide ANSI with a copy. The auditor

notes that OEOSC has included a proposal in the 14 July 2006 edition of

the Procedures for the Development and Coordination of American

National Optical Standards. These new procedures should be submitted to

ANSI for approval. Further details are contained in Section 7 of this

report.

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The auditor recommends that, in accordance with clause 5.1 of the

Procedures for the Development and Coordination of American National

Optical Standards, OEOSC take formal action to add to the membership of

the consensus body, document such action, and advise the consensus

body, as required by the operating procedures. The auditor found that in

the case of one applicant from Pakistan, OEOSC is not handling

membership requests in accordance with the accredited procedures.

Further details are contained in Section 7C of this report.

vi)

The auditor recommends that, in accordance with clauses 1.2, 1.3, 2.2, 2.3,

and 3.3 of the ANSI Essential Requirements, OEOSC keep accurate

records of membership changes. The auditor noted that the consensus

body changed significantly for this standard from the original BSR-9 form

that was submitted to ANSI to the final BSR-9 form that was submitted.

There was no documentation indicating what occurred to justify such a

change in membership. Adequate monitoring of balance and participation

requires an accurate and up-to-date list of members of the consensus body

and associated membership records. Further details are contained in

Sections 7A and 7C of this report.

vii)

The auditor recommends that, in accordance with clauses 1.2, 1.3, 2.2, and

2.3 of the ANSI Essential Requirements and Clause 2 of the Procedures for

the Development and Coordination of American National Optical

Standards, OEOSC take additional efforts to ensure that the consensus

body is balanced and no interest category is more than a majority of the

total. The auditor noted clause 2.3 recommends that no single interest

category constitutes a majority of the membership of a consensus body

dealing with other than safety-related standards. The auditor found that

the current consensus body roster appears to be seriously out of balance.

Specifically, the final BSR-9 form indicates that there were nine producers

and five general interest members with no users. Furthermore,

The auditor suggests that OEOSC make additional efforts to

encourage additional membership and suspend those members who

are not actively participating.

Further details are contained in Section 7C of this report.

viii)

The auditor recommends that the non-compliances listed in this audit

report be reviewed at the next scheduled audit to verify that corrective

action was taken.

Post Audit Conference

The findings, recommendations, and comments were discussed during a post audit

teleconference call that was held on 25 October 2006. Those who participated were Gene

Kohlenberg, Executive Director, OEOSC; Glenn Ziegenfuss, ANSI Auditor; and Jay

Moskowitz, Director, ANSI Standards Developer Audit Program.