Comment submitted by Keith Greenaway, ANSI-ASQ National Accreditation Board

On Page 18 regarding ISO/IEC standards and throughout the entire proposed rule, ISO/IEC Guide 65:1996 has been replaced by ISO/IEC 17065:2012. ISO/IEC 17020:1998 has been replaced by ISO/IEC 17020:2012. Accreditation bodies will no longer be able to accredit to the previous versions once the implementation period expires. EPA should update the rule to include the current version of the standards. Page 21, the ILAC MRA covers ISO/IEC 17025:2005 and ISO/IEC 17020:2012. On page 29, section 1, the language implies that the IAF MLA is for ISO/IEC 17020. The IAF MLA does not cover ISO/IEC 17020, rather the ILAC MRA covers ISO/IEC 17020.