Standards will get bogged down by paperwork.
ACUS 11 – an independent agency of the United States government that was established in 1964 by the Administrative Conference.
Administrative Conference of the United States, “Administrative Conference Recommendation 2011-5,” Administrative Conference of the United States, 12-08-2011, https://www.acus.gov/sites/default/files/Recommendation-2011-5-Incorporation-by-Reference_0.pdf
Updating Regulations. Updating regulations that incorporate by reference is another challenge. Agencies are legally required to identify the Complying with Procedural Requirements. Finally, successfully incorporating by reference requires agencies to comply with detailed procedures and to draft regulations carefully. The Office of the Federal Register (OFR) is statutorily charged with approving all incorporations by reference, and has issued regulations and guidance establishing policies and procedures for doing so. Procedural errors can delay the publication of rules that incorporate by reference. Poor drafting may create confusion among regulated parties or produce a rule that does not fulfill the agency’s regulatory purpose. The Conference’s research revealed that agencies reporting few or no problems in complying with OFR’s incorporation by reference procedures followed identifiable best practices that other agencies should consider adopting