Public Access to ASTM E681

Standard Test Method for Concentration Limits of

Flammability of Chemicals (Vapors and Gases)
The 1985 edition of ASTM E681 is incorporated by reference into law at by PHMSA at 49 CFR
173.115. The standard may be used to determine guidelines for the safe handling of volatile
chemicals ... particularly in assessing ventilation requirements for the handling of gases and
vapors. The American Society for Testing and Materials (ASTM) makes available the 2009
edition of the standard for $46.00 and also has the 1998, 2001, and 2004 versions available for
sale.
The 1985 version that is incorporated by reference is not available for purchase at any outlet.
The standard as an individual document is not available in any public library in the United
States. Two libraries in Australia have the 1985 edition of Section 14 of the ASTM Annual Book of
Standards which may contain this document. In the United States, access is limited to a few elite
universities that have subscribed to the ASTM annual service or by a personal visit to the PHMSA
or Ofce of the Federal Register reading room. Public.Resource.Org was able to nd this
standard and several others by purchasing over 70 random volumes of ASTM standards that we
found on the Amazon.Com used book marketplace, and then carefully compared the tables of
contents to the registry of standards incorporated by reference looking for matches.
ASTM standards are particularly problematic for incorporation by reference. PHMSA
incorporates 74 unique standards in their section of the CFR. In some cases, multiple
incompatible (and currently obsolete) versions of standards are incorporated. For example,
PHMSA incorporates both the 1990 and 2000 versions of ASTM A516 in different sections of the
CFR. ASTM has continued to revise this standard, issuing new editions in 2001, 2003, 2004, 2005,
2006, and 2010.
ASTM has lobbied aggressively against public access to standards incorporated by reference.
When the Department of Homeland Security wanted to make standards for emergency
responders available, they were only able to do so under limited conditions and after paying a
fee to ASTM.
We understand that standards bodies need money to function. However, with a $58 million
revenue stream, million-dollar CEO salaries, and an important leadership role in the U.S.
engineering community, ASTM could do much more. Access to the law is a cardinal principle of
the American system of government and only a small portion of the ASTM standards base has
ben incorporated into law. ASTM could do much more to meet their obligations to the American
public while still meeting their nancial goals.

Public Safety Analysis:

Carl Malamud, Public.Resource.Org
July 9, 2012
 By Authority Of
THE UNITED STATES OF AMERICA
Legally Binding Document
By the Authority Vested By Part 5 of the United States Code 552(a) and
Part 1 of the Code of Regulations 51 the attached document has been duly
INCORPORATED BY REFERENCE and shall be considered legally
binding upon all citizens and residents of the United States of America.
HEED THIS NOTICE: Criminal penalties may apply for noncompliance.

e
Document Name: ASTM E681: Standard Test Method for Concentration
Limits of Flammability of Chemicals

CFR Section(s): 49 CFR 173.115(a)(2)

Standards Body: American Society for Testing and Materials

Official Incorporator:
THE EXECUTIVE DIRECTOR
OFFICE OF THE FEDERAL REGISTER
WASHINGTON, D.C.