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Notes in the running text of a standard cannot carry a requirement, and four drafting manuals say so. The ISO/IEC Directives, Part 2, in its ninth edition of 2021, provide at clause 24.5 that notes "shall not contain requirements," and clause 25.5 says the same of examples.¹ The 2021 IEEE SA Standards Style Manual provides that notes "shall not include mandatory requirements."² The 2023 National Electrical Code Style Manual says at 2.1.10.2 that informational notes "shall not be written in mandatory language and shall not contain requirements, make interpretations, or make recommendations."³ ASTM states the rule in the IEEE manual's words at clause A27.1 of Form and Style for ASTM Standards, and then supplies a way of applying it.⁴

A test for telling a note from a requirement

Clause A27.1 puts clarification of required apparatus or procedure in the text itself, and then gives the test.⁴ "If inclusion of the contents yields a different result, then that information is considered mandatory for the performance of the standard and shall be located in the text."⁴ The same clause states a different rule for tables, where "Table notes are a part of the table and are mandatory provisions."⁴ A note under a table and a note in the running text are two kinds of writing, and only one of them sits outside the requirements.

Five tables of verbal forms, and the one two manuals warn against

The Directives sort the verbal forms into five tables in clause 7. Table 3 gives shall for a requirement, Table 4 should for a recommendation, Table 5 may for a permission, and Table 6 can for possibility and capability.¹ Each carries listed equivalents, so a requirement may also be written "is to," "is required to," "it is required that," or "has to."¹ Table 7 gives must, and unlike shall it states no requirement of the document, marking instead a constraint that comes from outside it.¹ The Directives then add an instruction: "Do not use 'must' as an alternative for 'shall'."¹ The stated reason is to avoid confusion between the requirements of a document and external constraints.¹

The IEEE manual arrives at the same rule, saying that must "is deprecated and shall not be used when stating mandatory requirements," and is used only to describe unavoidable situations.² The Directives add one further caution, that "Negative permissions are ambiguous and should not be used."¹ A sentence saying that something may not be done reads either as a prohibition or as an absence of permission, and those are not the same statement.

What placement is worth once a standard is incorporated into law

The deeming that follows is limited to one paragraph of the statute. Under 5 U.S.C. 552(a)(1), matter "reasonably available to the class of persons affected thereby is deemed published in the Federal Register when incorporated by reference therein".⁵ The incorporation has to carry "the approval of the Director of the Federal Register."⁵ The Administrative Committee of the Federal Register requires by rule that a publication be "reasonably available to and usable by the class of persons affected."⁶ In judging usability the Director considers the completeness and ease of handling of the publication, and whether it "is bound, numbered, and organized, as applicable."⁶

One sentence in the same part fixes the version. Incorporation by reference "is limited to the edition of the publication that is approved," and "Future amendments or revisions of the publication are not included."⁶ Under that rule a revision published by the body is not the incorporated text until an agency acts.

Two definitions of one word

Consensus is defined in two authoritative places, and the definitions do not match. OMB Circular A-119, revised January 27, 2016, gives consensus as "general agreement, but not necessarily unanimity," reached while comments and objections are considered "using fair, impartial, open, and transparent processes."⁷ The ANSI Essential Requirements, edition of January 2025, give consensus as "substantial agreement has been reached by directly and materially interested parties," signifying "the concurrence of more than a simple majority, but not necessarily unanimity."⁸ One of the two names a threshold. A procedures document that quotes one where it means the other has stated a different test for agreement.

What we work on in a draft standard

Technical content, the resolution of a comment, whether a requirement is testable, and whether a process met a policy are decided by the working group, the body's own editors, and its procedural staff. None of it is put to us. We also give no view on whether a draft would pass a ballot.

A conformance requirement written with must is visible on the page, as is a sentence written with shall inside a note. Where a term is defined in one clause and used differently in another, the definition and the use are two sentences in the same document. A cross-reference that survived a renumbering unchanged now points at whatever carries that number. Client documents are confidential from the moment they arrive.

A standard is read one clause at a time, usually by someone deciding whether a product conforms. A drafter who varies the verb for the sake of the sentence has changed what that reader is being told to check. Where the standard has been incorporated by reference, the corrected edition reaches the regulation only after the agency asks for the change and the Director of the Federal Register approves it.⁶