Americas Regulation

Patricks Response to the ASTM


Dear Mr. Thomas:

Per our conversations, I can appreciate the ASTM business model, however, you should also consider the small business model. I don’t know if you aware of my history with ASTM F-38 but I was at the first meeting in Reno, Nevada in May 2005. It was from there this issue first arose and caused me to later sever ties with the ASTM in 2011.  Yes, the ASTM did sponsor my travel on 2 occasions, but that was a mere drop in the bucket when one considers the years of work and travel I have invested on my own dime.

Furthermore, I’m sure you can imagine my frustration to hear that documents that I produced were rewritten without my consent.  My negative votes where summarily dismissed.   At the time I was told that the “public” would have to pay to see the standards that will be part of the law.  After my public disassociation with ASTM and writing letters to the FAA administrator, Congress et al. ASTM had agreed to make the published standards public.

As a member of the “public” I am not willing to pay to see what will be part of the law that will affect my business plan.   We have already seen an example of what happens when we are told we “must pass this law so we can see what is in it”

I intend to press forward with this request and I will not sit back and allow that to transpire.

Very respectfully

Patrick Egan

The original letter from the ASTM

Dear Mr. Egan;

Your recent article entitled “ASTM Advertises F38 Standards for Sale” in sUAS News has been brought to my attention.

For over 115 years, ASTM has served society as a not-for-profit standards development organization.  As you noted, voluntary consensus standards developed by ASTM are sometimes cited by government regulations and laws as tools that help to protect society and promote health, safety, and the environment.   ASTM has a policy of being flexible and reasonable in working with Federal agencies and routinely provides public access – at no cost – to ASTM standards during the public review and comment period of proposed rulemakings that seek to incorporate ASTM standards.  In addition, ASTM provides public access – at no cost – to over 1,000 standards that are incorporated by reference in the U.S. Code of Federal Regulations through the Reading Room on our ASTM web site:

There are many costs in the process of developing, publishing, and maintaining voluntary consensus standards.  ASTM receives no Federal or State funding to underwrite such costs.  The model that ASTM has chosen to pay for our standards development activities is one that requires payment by end users of our documents, rather than front-loaded standards development fees charged to industry, governments and other important stakeholders such as consumer and environmental advocacy organizations.  Because the costs of developing our standards are spread out among thousands of users who buy standards on a reasonable basis, ASTM is able to keep the barriers to participation in the process very low.  As a result, over 50 percent of participants in our standards development activities come from small and medium sized companies.

The revenue ASTM receives from the distribution of our standards is invested to meet commitments to our members and stakeholders, and to ensure the long-term vibrancy of our standards development activities.  We have looked at other systems and we continue to find that our current model of standards development and distribution is the most effective way to protect the public, meet the needs of government, and ensure that ASTM can continue to provide value and innovate to meet new challenges of the future. 


James A. Thomas

President, ASTM International

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