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3.1 The purpose of this standard practice is to provide the minimum requirements for the conduct of compliance audits.3.2 The intended use of standard is to provide a basis for an internal or external entity to develop an audit program. An audit program defines specific requirements for the execution of audits for a particular objective. An example of an audit program would be an external (third party) audit of LSA manufacturer’s quality assurance system.3.3 Compliance to this standard would insure that audit programs and those who develop and execute them are following a consensus set of minimum requirements.3.4 This standard does not mandate either internal or external audits.3.5 An auditing entity cannot request or approve an audit.3.6 Other Audit Criteria—Other audit criteria may be included in the audit scope if specified in the audit plan. Examples include safety, technical, operational, and management requirements. Items that are outside the scope of auditable criteria may be submitted as observations for possible resolution. However these are not binding and are not mandatory.3.7 Additional Services—Additional services are outside the scope of an audit objective. Examples of such services are consultation to resolve negative or open findings or any other service where the auditing entity conducts an activity other than an audit for the audited entity.3.8 Compliance Assurance—An audit is only an indicator of the compliance health of the facility and/or organization during only the period under review and therefore has limited compliance assurance and is not assumed to be exhaustive.3.9 Level of Review is Variable—The audit scope may vary to meet different audit objectives. For example, the audit scope may include only selected audit criteria, selected period under review, or selected portions of a facility or organization.1.1 This standard practice establishes the minimum set of requirements for auditing programs, methods, and systems, the responsibilities for all parties involved, and qualifications for entities conducting audits against ASTM standards on Light Sport Aircraft.1.2 This standard provides requirements to enable consistent and structured examination of objective evidence for compliance that is beneficial for the LSA industry and its consumers. It is the intent of this standard to provide the necessary minimum requirements for organizations to develop audit programs and procedures.1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.

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3.1 The general approach to this practice is to serve as an “overlay” of requirements to the ASTM F3411-22a Standard Specification for Remote ID and Tracking by identifying mandatory portions, substituting values as needed, overriding items that may be optional, and providing additional requirements that are beyond the scope of Specification F3411, yet are necessary to provide proper guidance to meet the requirements set forth in Part 89.3.2 Furthermore, this practice provides additional details on minimal testing requirements for those submitting a DOC based on this MOC.1.1 This practice provides a Means of Compliance (MOC) that gives sufficient clarity to the Unmanned Aircraft System (UAS) or Broadcast Module manufacturers to produce a compliant Remote ID (RID) System (RIDS) such that submitting a Declaration of Compliance2 (DOC) to this MOC will satisfy the requirements of the Federal Aviation Administration (FAA) 14 CFR Part 89 (Part 89) rule.3 This practice also explains what to expect from aircraft operating in compliance to this MOC.1.2 The FAA provided three options to comply with the Remote ID regulations: Standard Remote ID UAS, Remote ID Broadcast Modules, and FAA-recognized identification areas (FRIAs). The scope of this MOC is to cover both Standard RID and RID Broadcast Modules.1.3 The FRIA portion of the rule is out of scope since it provides a means to avoid the technical RID requirements by operating within administrative boundaries.1.4 Both SI and non-SI units are used in this document. Since this is an aviation standard and it addresses FAA rules, some units are used in preference of being consistent with industry and regulatory norms.1.5 Table of Contents:Title Section 1Referenced Documents 2 3Subset of Options in the F3411 Specification Considered 4Requirements and Exceptions from the F3411 Specification 5Alternative Applications of Specification F3411 to Meet Part 89    Requirements 6MOC Requirements Not Covered by the Practice 7Test Methods 8Precision and Bias 9Satisfaction of Rule Requirements 10Keywords 11ANNEX A1—Simulation Option for Accuracy Testing Annex A1APPENDIX X1—External Device for GCS Location Source Rationale Appendix X1APPENDIX X2—Power Level Rationale Appendix X21.6 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.1.7 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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1.1 This guide covers fencing and lighting only. More sophisticated security systems may be appropriate for the facility but discussion of these types of systems is beyond the scope of this document.1.2 The information included in this guide is intended for petroleum bulk storage facilities. It is not intended for use with retail fueling and other motor fueling facilities, refineries, chemical plants, docks, oil production facilities, or electric power generation, transmission, distribution and service center facilities. Fencing, lighting or other security measures designed to prevent unauthorized access to the bulk storage facility may be components of Best Management Practices (BMPs) that the facility uses to prevent releases of petroleum to storm water discharges. There are several different types of fencing and lighting that can be effective. The intent of this document is to outline a method for providing security fencing and lighting that has been effectively used. There are other fencing and lighting methods that may be adequately effective. Some facilities may be considered adequately secure without fencing or lighting. An analysis of the threat level should be made to determine the type of security system to employ.1.3 Any facilities must meet local, state, and federal building, architectural, hazardous material handling and storage, and fire protection codes.1.4 The values stated in inch-pound units are to be regarded as standard. No other units of measurement are included in this standard.1.5 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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4.1 This guide provides some major themes and examples for consideration related to compliance which are not necessarily captured in any single standard pertinent to light sport aircraft. The outline of this document is intended to loosely reflect the process that an organization would go through in order to reach and maintain production of a light sport aircraft that is demonstrably compliant with the applicable ASTM standards.4.2 These considerations are applicable to manufacturers which are responsible for conformity to processes and procedures required in ASTM standards for light sport aircraft. Manufacturers are encouraged to think through the contents of this guide, reference the ASTM light sport aircraft standards, establish, document and follow their own procedures.4.3 Manufacturers are responsible for determining which standards and revisions thereof are part of the regulatory package of any given CAA, along with any other requirements applicable within the agency’s jurisdiction.4.4 Following this guide does not ensure compliance of a particular light sport aircraft; however, following the explanations provided herein should assist manufacturers in avoiding common pitfalls of declaring compliance prematurely, determining shortcomings in current declarations of compliance, and maintaining a body of documentation sufficient to support a declaration of compliance.1.1 This document provides guidance to assist manufacturers in understanding and meeting ASTM standards for light sport aircraft. This guidance material presents philosophies, practices and considerations recommended by industry consensus, but does not present technical or business requirements that must be met.1.2 It is the intent of this guide to provide processes to be considered by organizations looking to develop or improve objective evidence of compliance for light sport aircraft. It does not attempt to identify all of the standards, regulations or other requirements that may be applicable to a given aircraft, production or testing process.1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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4.1 This guide may be used for environmental compliance performance assessment in the United States in a wide variety of applications and is not particularly limited to one type of user. The following groups of users may find the guide particularly helpful:4.1.1 Small businesses or enterprises;4.1.2 Service industries;4.1.3 Federal, state or local facilities and regulators, including departments of health and fire departments;4.1.4 Financial and insurance institutions;4.1.5 Waste managers, including liquid and solid waste haulers, treatment, recycling, disposal and transfer;4.1.6 Consultants, auditors, inspectors and compliance assistance personnel;4.1.7 Educational facilities;4.1.8 Property, buildings and grounds management, including landscaping;4.1.9 Non-regulatory government agencies, such as the military; and4.1.10 Specific industrial sectors such as dry cleaners, printers, photo processors, laboratories, health care, and vehicle fueling, maintenance and delivery.4.2 This guide is intended as a first step in crafting simplified management goals for assessing compliance with a wide variety of multimedia environmental performance standards. The framework describes a process by which the user may categorize current waste management, air quality, water, and release prevention practices in order to manage the risks associated with noncompliance. The technique classifies common environmental performance standards into tiers based on relative risks to human health, the environment and business operations. The tier classifications found in this guide reflect the general requirements of State, Federal and local compliance and enforcement programs. These authorities generally classify groups of similar environmental performance standards according to the significance of any noncompliance within each group of standards.NOTE 1: Users in the United States are encouraged to review the EPA’s Audit Policy Program: Frequently Asked Questions (2021)5 for additional guidance on the Agency’s expectations of compliance performance assessments.4.3 The guide helps the user to realize the benefits of environmental compliance. These benefits may include but not be limited to:4.3.1 Ability to set priorities for environmental management activities;4.3.2 Marketing environmental awareness and sensitivity;4.3.3 Assessing compliance with permits and other requirements;4.3.4 Risk management, underwriting; loss control and history; premiums and claims;4.3.5 Liability assessment and qualifications for loans;4.3.6 Standardization, consistency and certification of facility specific evaluations;4.3.7 Educating employees, clients and customers;4.3.8 Generating multi media and cross medium information;4.3.9 Evaluating vendors; and4.3.10 Reducing costs and preventing pollution.4.4 Users may consider various benefits of environmental compliance performance assessment.4.4.1 This guide is a basic primer on environmental compliance and may serve to introduce the subject for organizations unfamiliar with requirements.4.4.2 Many government enforcement agencies, fiduciaries and business organizations publish environmental compliance records over the internet. The public will soon have the systematic ability to access environmental compliance information on individual businesses. Therefore, businesses need guidance on how to assess the nature and potential risks of environmental non-compliance, and a programmatic approach for reducing or eliminating those risks through pollution prevention and other proactive management systems.4.4.3 Reduced operation and maintenance costs and paperwork may be realized through a tiered evaluation of environmental compliance and pollution prevention opportunities.4.4.4 Compliance may be streamlined and simplified so that all levels in an organization may participate in environmental management.4.4.5 Some enterprises may be more competitive in the marketplace with improved environmental compliance programs.4.4.5.1 The State of Minnesota allows small firms with an environmental management system to operate under a flexible air permit.4.4.5.2 Firms in Indiana with an Environmental Management System are eligible to participate in the state’s Environmental Stewardship Program which provides regulatory flexibility.4.4.5.3 Firms operating in Wisconsin that develop and implement an environmental management system may be eligible to apply to the Department of Natural Resources Green Tier program. Green Tier can offer eligible companies flexibility in state issued permits and compliance methods.4.4.5.4 International firms and organizations may have significant competitive advantages through implementation of an environmental management system that conforms to ISO 14001:2015.4.4.6 Setting priorities can allow planning and evaluation of new environmental requirements.4.5 This guide establishes a framework of common, environmental risk management requirements in the United States and will allow the user to evaluate the potential level of risk from non-compliance. Compliance requirements would then be evaluated for pollution prevention opportunities in order to continually reduce the risks from non-compliance.4.6 Noncompliance with Tier 1 Environmental Performance Standards represents the highest risk because Tier 1 Standards prevent, mitigate or respond to imminent hazards for human health or the environment. Tier 2 Standards address areas of significant risk, where noncompliance could result in penalties, primarily for failure to obtain required approval for releases or modifications to the environment. Tier 3 Standards require operation and maintenance of approved controls on releases or modifications to the environment, where repeat noncompliance could represent a risk. Tier 4 Standards represent the lowest direct risk from noncompliance; however, they are still important for documenting environmental management, the details of the compliance record, environmental compliance costs and pollution prevention measurements.1.1 Overview—This guide is an organized collection of information and series of options for industry, regulators, auditors, consultants and the public, intended to measure compliance with environmental performance standards against established benchmarks. It focuses on compliance with air, water, waste prevention, waste management, and toxic reduction standards for facilities in the United States. While the guide does not recommend a specific course of action, it establishes a tiered framework of essential components, beginning with those standards where a deviation presents the greatest potential public health, environmental, and business risks. In each identified pathway, at each tier or step of analysis, the guide outlines ways to identify compliance options and reduce pollution in iterative steps. The goal in using the guide is to lower environmental, public health and business risks from Tiers 1 and 2 to Tiers 3 and 4, by evaluating the performance standards described in this guide. While this guide provides a simplified framework of explicit steps for users, a qualified professional should conduct detailed, site-specific risk analysis. This guide may act as a starting point for organizations with limited experience in systematic environmental assessment. As facilities develop their specific plan framework, they will find that risk is weighted by more than just a few parameters. For each facility risk is the complex interaction among location, size, history, surrounding community and ecological zones.1.2 Differences Among Standards—This guide focuses on compliance with environmental performance standards in the United States. As such it includes a unique, risk-based method to analyze specific groups of legal requirements, as well as risk reduction techniques, sometimes called “pollution prevention.”1.2.1 Use of this guide provides a system to evaluate the relative priority of compliance and pollution prevention activities. Unlike environmental management systems, it provides a framework to triage critical issues, based on consideration of actual risk of harm to public health and the environment.1.2.2 Environmental regulatory requirements in the United States are administered primarily by the United States Environmental Protection Agency (USEPA) and the parallel State and Local Agencies with similar regulatory authority. Certain other Federal regulatory agencies and State and local counter parts may also have legal requirements relating to environmental performance standards. Examples include the Departments of Transportation (DOT) and Agriculture (USDA) and the Occupational Safety and Health Administration (OSHA). Similar to the ISO 14001:2015 standard, this guide uses the major groups of environmental regulatory standards in the United States for air and water quality, waste management, release prevention, and toxic materials use reduction, in order to organize the compliance analysis framework.1.2.3 This guide derives general information about regulatory requirements from common elements of Federal, State and local programs, including statutes, regulations, guidance and policies. Since agencies may have overlapping authorities and different emphasis for particular issues such as waste management, the user should consult the applicable program for detailed interpretation of specific requirements in a particular jurisdiction.1.2.4 Pollution prevention generally refers to source reduction as a preferred option as opposed to other less preferable alternatives, such as, re-use, recycling, treatment, or disposal/release. ISO 14001:2015 Clause 8.1 requires that “consistent with a life cycle perspective”, the organization shall take a number of actions as a part of operational controls and planning activities including establishing controls, determining its environmental requirements for procurement, communicating its relevant environmental requirements as well as considering the need to provide information about potential significant environmental impacts, inter alia. Further, ISO 14001:2015 Clause 9.1.2 explicitly requires that “…organization shall establish, implement, and maintain the process(es) needed to evaluate fulfillment of its compliance obligations…” This guide compliments and supports actions required under ISO 14001:2015 by establishing a well-documented process for environmental compliance performance assessment.1.2.5 Pollution prevention is a specific term used in United States environmental compliance management programs. The term usually refers to source reduction actions. Unlike the term “prevention of pollution,” which is used in certain international environmental management standards, pollution prevention does not generally include end-of-pipe or top-of-stack control actions.1.3 Limitations of this Guide—Given the variability of the different types of facilities that may wish to use this guide, and the existence of State and Local regulations that may impose requirements greater than those required by USEPA, it is not possible to address all the relevant standards that might apply to a particular facility. This guide uses generalized language and examples to guide the user. If it is not clear to the user how to apply standards to their specific circumstances, it is recommended that users seek assistance from qualified professionals. An Environmental Regulatory Compliance Audit, such as Practice E2107, may assist a facility with areas of non-compliance and potential liabilities. This can be a starting point for development of facility specific environmental compliance management programs.1.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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4.1 Intended Use—This practice is intended for use by parties who wish to perform or direct an audit, or rely upon audit findings or an audit report. Such use includes audits by internal and external auditors.4.2 Other Audit Criteria—Other audit criteria may be included in the audit scope if specified in the audit plan. Examples include safety and health requirements, and technical, operational, and management requirements.4.3 Related ASTM Standards—This practice is related to Practice E1527, which addresses CERCLA liability, and Practice E1528, which addresses due diligence for commercial real estate. A number of terms and procedures from these practices are similar to terms and procedures associated with this practice but they may not be the same. Guide E2365 addresses environmental compliance assessment and may be an appropriate tool for some environmental regulatory compliance audits. The user is advised that Guide E2365 is not an all-encompassing compliance assessment tool. Guide E3123 addresses the five types of environmental liabilities named in generally-accepted accounting principles (asset retirement obligations, environmental obligations, commitments, contingencies and guarantees).4.3.1 Not Interchangeable—Although distantly related to Practices E1527 and E1528, this practice is designed to achieve different results. Therefore, these practices shall not be used interchangeably with, or in place of, this practice.4.4 Related ISO Guidelines—The International Organization for Standardization (ISO) has developed guidelines addressing environmental auditing. These are ISO 14001-2015 and 19011-2018. A number of terms and procedures from these guidelines may be similar to terms and procedures associated with this practice but they may not be the same. ISO 14001-2015 added several compliance evaluation criteria, including Section 9.1.2 (Evaluation of Compliance) and Section 9.2 (Internal Audits).4.4.1 Not Interchangeable—Although related to ISO guidelines, this practice is designed for a different purpose. Therefore, these ISO guidelines shall not be used interchangeably with, or in place of, this practice.4.5 Additional Services—A number of issues may arise as a result of an audit, but are outside the scope of this practice. Such issues include, but are not limited to, development of action plans and cost estimates to address audit findings.4.6 Conditions—The following conditions shall govern the application of this practice.4.6.1 Not Exhaustive—A audit shall not constitute an exhaustive review of audited entity compliance with all potentially applicable audit criteria unless explicitly intended and stated as an audit objective in the audit plan.4.6.2 Level of Review is Variable—The audit scope may vary to meet different audit objectives. For example, the audit scope may include only selected audit criteria, selected period under review, or selected portions of a facility or organization.4.6.3 Continued Viability of Environmental Audit—An audit completed in accordance with this practice shall be valid for only the period under review. Because audit criteria and audited entity conditions may change over time, it shall not be assumed that an audit report is reliable, or has continued viability, for other than the period under review.4.6.4 Usage of Prior Audits—Information contained within reports from prior audits should be used only if it has continued viability and if use of that information is appropriate.1.1 Purpose—This practice2 identifies minimum requirements for environmental regulatory compliance audits (audits). It also provides information on the terms and procedures associated with audits as practiced in the United States of America (USA) and other jurisdictions subject to the laws thereof. It provides a reference to which interested parties may refer for definition and description of accepted audit terms and procedures.1.2 Background: 1.2.1 Awareness of Benefits Associated with Audits—Various benefits have been attributed to audits. These benefits may include a better understanding of the compliance status of a facility or organization, identification of opportunities for environmental management systems improvements, reduction or elimination of potential legal and financial liabilities when implemented as part of a comprehensive compliance management program, better communications and improved relationships with governmental agencies, communities, and other stakeholders, providing information for development of both short-term and long-term environmental expenditures, and education of employees.1.2.2 Awareness of Risks Associated with Audits—It is also important to recognize that certain risks have been associated with audits. These risks may be managed and controlled by giving thoughtful consideration to the audit process before beginning an audit. These risks may include increased potential legal and financial liabilities for the audited entity if audit findings are not corrected in a timely manner, disclosure of confidential business information or trade secrets, inadvertent admissions against interest because of the wording of audit findings, disclosure of audit findings intended to be kept confidential under audit privilege laws or attorney-client privilege or work product doctrine, and inaccurate audit findings.1.2.3 Awareness of Legal Issues—A number of important legal issues are associated with audits. Example legal issues include the qualification for one or more evidentiary privileges, the qualification for limited immunity, the protection of trade secrets and confidential information, the application of a number of government policies associated with environmental audits (including federal and state programs that provide incentives for detecting, disclosing, and correcting potential violations through auditing), the form and language of audit reports, the necessity of reporting certain information to the government (either federal, state, or local agencies), the potential liability of auditors, and the importance of promptly addressing issues identified during audits. Prior to initiating and during an audit, interested parties should consider potential legal issues and consult legal counsel or other experts as appropriate.1.3 Organization—This practice is organized in the following manner:  Section 1Referenced Documents 2Terminology 3 4Responsibilities 5Auditor Qualifications and Staffing 6The Audit Process 7Evaluation and Report Preparation 8Keywords 91.4 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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This specification covers agencies engaged in system analysis and compliance assurance for manufactured building. The administrative agency may utilize the services and facilities of building-evaluation agencies in carrying out its responsibilities for evaluating manufactured building systems. By providing criteria for evaluating these agencies, this standard's objective is to (1) utilize the voluntary standards system to provide a common base for the various regulatory approaches employed by the authorities having jurisdiction, and (2) make provision for varying degrees of optional technical support for the certification of manufactured building. The system analysis agency is responsible for determining whether a building system, including the design, materials, and fabrication process, is in conformance with applicable requirements. The documents of the system analysis function are: product description document, compliance assurance manual, and installation documents. The general procedures for system analysis are presented in details. The tasks of system analysis project manager, technical staff evaluating building systems, technical staff evaluating compliance assurance manuals, and project manager evaluating building systems are presented in details. The requirements and criteria for compliance assurance agencies are presented. The task of compliance assurance agency project manager, technical staff preparing compliance assurance manuals, compliance assurance supervisor of inspection, and compliance assurance inspector are presented in details.1.1 This specification provides the criteria for the administrative agency that has regulatory authority as granted by the authority having jurisdiction AHJ to evaluate the capabilities and qualifications of building evaluation agencies, that performs system analysis or compliance assurance or both for certification of manufactured building on behalf of an authority having jurisdiction (AHJ) that meet the needs of regulatory programs. Administrative agencies and building evaluation agencies (third-party agencies) are the primary users of the standard.1.2 To establish an appropriate degree of intra- and inter-state credibility regarding building system evaluations made through governmental or private agencies, the authorities having jurisdiction should utilize an oversight and approval process for the building-evaluation agencies that provide the services of system analysis or compliance assurance on behalf of the AHJ that may include: approval by the AHJ for both oversight and or auditing of the regulatory body, or approval by the AHJ and oversight, and or auditing by an independent auditor for the regulatory body, or approval with the AHJ and oversight, and auditing by an independent accreditation agency.1.3 Building-evaluation agencies examined under this specification may include governmental or private agencies or both.1.4 Practice E651 may be used to support the evaluation of building-evaluation agencies. Other criteria such as independence, financial stability, and objectivity may need to be considered.NOTE 1: Practice E651 is intended as a companion standard to Specification E541 and includes questions that should be asked of system analysis and compliance assurance agencies in order for the administrative agency to evaluate their competency.1.5 These criteria set forth the minimum personnel requirements and the technical and organizational procedures required for building-evaluation agencies engaged in evaluating manufactured building.1.6 Criteria are included for building-evaluation agencies evaluating innovative as well as conventional building systems, against applicable requirements.1.7 Building-evaluation agencies involved in testing, quality assurance, and evaluating building components can be evaluated by using Specification E699.1.7.1 Specification E699 is used in conjunction with Specification E541 and Practice E651. This specification defines the minimum requirements for agencies engaged in inspections and testing performance in accordance with ASTM standards for factory-built building components and assemblies. The criteria in this specification are provided for assessing the competence of an agency to properly perform designation testing, quality assurance, and inspection.1.8 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.1.9 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

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