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ECPC Responses on Public Comments Regarding Changes for 2012

By Document Number

12-001 General — Alternate Aggregation Structure

Docket Number 12-001
General — Alternate Aggregation Structure

Docket 12-001 requested the adoption of a higher-level aggregation structure within NAICS of less than 20 sectors to facilitate greater publication of county and other small area data cells. The ECPC discussed this issue during the development of NAICS and in subsequent revisions.

To address the need, the ECPC developed a recommended aggregation structure for use by programs that were not able to publish data at the sector level. The recommended alternate aggregation structure was reviewed by the Agencies of the ECPC and the Office of Management and Budget. The alternate aggregation structure is available on the Internet at: http://www.census.gov/eos/www/naics/history/docs/cm_2.pdf

The ECPC recommends that the commenter contact the statistical programs producing data and request that tabulations be prepared using that recommended alternative aggregation. The alternate aggregation structure is a recommended option, but it is not an official part of the NAICS classification.

12-002 Sector 54 Professional, Scientific, & Technical Services. Keyword — Graphic Design Services

Docket Number 12-002
Sector 54 Professional, Scientific, & Technical Services — Graphic Design Services

Docket 12-002 requested changes in the title and definition of NAICS 541430, Graphic Design Services. The proposed title for the industry was Communication Design Services and the proposed content was extended to include design of video screen displays, interactive navigation, film and television, and information systems.

The ECPC recognizes the expanded use of graphic designers and communications consultants in a wide range of businesses. However, businesses that are primarily engaged in advertising, computer programming, television and film production, and development of software and system integration activities are classified to existing industries in NAICS. Adding these services to the definition of graphic design services would create unnecessary confusion within NAICS. There were a number of suggested changes to the definition that do not change content and are recommended for adoption in 2012. These changes are in italics in the proposed 2012 definition for NAICS 541430, Graphic Design Services in 2012:

This industry comprises establishments primarily engaged in planning, designing, and managing the production of visual communication in order to convey specific messages or concepts, clarify complex information, or project visual identities. These services can include the design of advertising and promotional artwork, corporate identity programs (logos, brands, letterhead, etc.), printed materials, exhibition and signage systems, and packaging. This industry also includes commercial artists engaged exclusively in generating drawings and illustrations requiring technical accuracy or interpretative skills.

12-003 General — Green Jobs/ Green Economy

Docket Number 12-003
General — Green Jobs/ Green Economy

Docket 12-003 requested unspecified changes to NAICS for 2012 in response to President Obama's launch of the green jobs and green economy initiative.

Updating 2012 NAICS by adding green jobs or green industries was a dominant theme in many of the responses to the 2007 Federal Register Notice. With the adoption of many new national policies and the push towards future legislation involving a healthier environment, ecosystem, etc., it is evident that the identification of green jobs and a green economy needs to be addressed. The ECPC recognizes the need for statistical information about green jobs, but the industry classification is not the most appropriate tool for developing green jobs data. The ECPC recommendations do include changes to industries to reflect renewable energy generation industries in accordance with the principles of NAICS.

A working definition of environmental goods and services (EGS) is being developed as part of a Bureau of Labor Statistics initiative to develop statistics for this area of the economy.

12-004 General — Standard Industrial Classification

Docket Number 12-004
General — Standard Industrial Classification

Docket 12-004 requested that the ECPC cut ties with the Standard Industrial Classification (SIC). The SIC was replaced when NAICS was adopted in 1997. The Office of Management and Budget requires the use of NAICS for Federal statistical purposes. The ECPC recognizes the confusion caused by multiple industry standards, but non-statistical uses of the industry classifications are not within the purview or jurisdiction of the committee.

The ECPC does recommend that the Office of Management and Budget update Statistical Policy Directive No. 8 to remove references to the Standard Industrial Classification and to incorporate explicitly the use of the North American Industry Classification System for Federal statistical purposes.

12-005 Sector 51 Information. Keyword — Mobile Caller ID

Docket Number 12-005
Sector 51 Information — Mobile Caller ID

Docket 12-005 requested a new NAICS industry for mobile caller ID separate from NAICS 517210, Wireless Telecommunications Carriers (except Satellite). The separate industry would comprise units that develop software applications linking incoming wireless phone numbers to a centrally maintained database and display a name with the incoming phone number. Industries in NAICS must include enough establishments to publish statistical data. The ECPC was not able to identify a significant number of providers of this type of application. The ECPC does not recommend a separate industry for mobile caller ID providers.

NAICS 517210 includes carriers that operate the wireless telephone infrastructure. Establishments that create software and make their applications available to others are classified to NAICS 511210 as software publishers. Creating and disseminating applications define the production process and there is no industry distinction for each particular application. If this mobile caller ID is provided as a service rather than a separate software application, the activity of providing information services over infrastructure operated by others would be classified to NAICS 517919, All Other Telecommunications.

12-006 Sector 11 Agriculture, Forestry, Fishing and Hunting. Keyword — Game Birds

Docket Number 12-006
Sector 11 Agriculture, Forestry, Fishing and Hunting — Game Birds

Docket 12-006 requests the addition of text in the NAICS manual to clearly classify several types of game birds, including Chukar and Hungarian partridges that are not currently listed. The proposal also requested a separate Census collection category for commercial game preserves, and proposed changes to the questionnaires used in the Census of Agriculture.

The production of Chukar and Hungarian Partridges is a large portion of the game bird production industry. Partridge production should be added as both an illustrative example and an index item under NAICS 112390, Other Poultry Production. Chukar and Hungarian partridges are species of partridges, and should be added as index items to clarify the classification of these activities.

The numbers and revenues of commercial game preserves do appear to justify breaking out detail from Outfitters including fishing, hunting, and rafting in Economic Census questionnaires.

The ECPC referred proposed changes to an Agriculture Census questionnaire to USDA/NASS, who agreed to work with the commenter to clarify the process for requesting any changes to Agriculture Census forms.

12-007 Sector 23 Construction. Keyword — Sediment and Erosion Control Contractors

Docket Number 12-007
Sector 23 Construction — Sediment and Erosion Control Contractors

Docket 12-007 proposed the creation of a new NAICS industry in the construction sector for establishments primarily engaged in sediment and erosion control activities. The proposed industry would be comprised of establishments primarily engaged in grassing, matting, and silt fencing to prevent water pollution and soil loss during the construction process. These are measures taken to comply with erosion control as set out by the Source Water Assessment and Protection Program (SWAPP) and the Environmental Protection Agency (EPA), among other federal and state agencies.

The ECPC noted the importance of these activities, but also noted that a wide range of establishments included in the construction sector provides them. As products, these can be performed by establishments primarily engaged in earth moving, foundation work, and civil engineering, as well as general contractors for all types of building projects. The lack of substantial establishment specialization in these activities only does not align well with principles of NAICS. The most appropriate method of collecting data on sediment and erosion control would be to treat the activity as a product and collect data from all establishment types providing the services.

12-008 Sector 54 Professional, Scientific, & Technical Services. Keyword — Rehabilitation Engineering

Docket Number 12-008
Sector 54 Professional, Scientific, and Technical Services — Rehabilitation Engineering

Docket 12-008 proposed the creation of a new industry for rehabilitation engineering in NAICS to include, service providers who apply engineering principles to the design, modification, customization and/or fabrication of assistive technology for persons with disabilities.

Establishments primarily engaged in using engineering principles to design assistive technology are classified within NAICS 541330, Engineering Services. The underlying application of engineering principles defines the production process rather than specializations such as mechanical engineering, electrical engineering, aerospace engineering, or rehabilitation engineering. The ECPC therefore does not recommend creation of a new industry for this branch of engineering services.

The ECPC does not recommend the addition of an index item for rehabilitative engineering because the definition provided would cross sectors in the existing classification to include activities classified in Sector 54, Professional, Scientific and Technical Services and in sector 31-33, Manufacturing.

12-009 General — Geographic Expression of NAICS

Docket Number 12-009
General — Geographic Expression of NAICS

Docket 12-009 requested the presentation of geographic data using the NAICS system. In particular, the commenter requested information on NAICS application to land use and topographic mapping.

The ECPC thanks the commenter, but is not aware of any current use of NAICS to define land use patterns. The ECPC did research the proposal and found numerous classification systems for compilation and mapping of land use/land cover for use in local, state, interstate regional, and national planning. Two that appear to be used often as a starting point for development of more detailed state classification systems are: 1) the U.S. Geological Surveys (USGS) land use and land cover classification system for use with remote sensor data; and 2) the Standard Land Use Coding Manual developed by the U.S. Urban Renewal Administration and the Bureau of Public Roads. Both are multi-level, hierarchical systems.

The ECPC suggests that the commenter coordinate with those, or similar agencies, to incorporate or concord the NAICS system to their existing frameworks.

12-0010 Sector 54 Professional, Scientific, & Technical Services. Keyword — Nanotechnology Research and Development Services

Docket Number 12-0010
Sector 54 Professional, Scientific, and Technical Services — Nanotechnology Research and Development Services

Docket 12-0010 requested the creation of a new industry for nanotechnology research and development within NAICS industry group 5417, Scientific Research and Development Services.

There are three specific components of the nanotechnology definition that establishments engaged in nanotechnology R&D must follow to achieve industry recognition. First, establishments must work with or manipulate materials that are 100 nanometers or less. Second, establishments must be able to understand and control the material they are working with. Third, new properties must emerge from the manipulation of these materials that expand the knowledge in the broader area of nanotechnology.

Many establishments conducting research in nanotechnology are also involved in researching other scientific areas. Due to the lack of agreement on a universal definition of nanotechnology, it is not uncommon for establishments to avoid the label of nanotechnology R&D. Also, it is often the case that establishments may be working with nanomaterials, but may not necessarily be fully engaged in all the aspects of the nanotechnology R&D industry. Going back to the three components that make up the nanotechnology definition, this would imply these particular establishments should not be classified as nanotechnology R&D. The point was made that conducting research while adhering to those three components are what set apart nanotechnology R&D from other R&D services. Just because an establishment is engaged in one component of the nanotechnology definition, it is not a requirement that they be engaged in the other two.

For example, nanomaterials appear in objects that are researched in all kinds of laboratories, but if it is not the focus of the laboratory to manipulate these materials in attempts to find new properties then this laboratory would fall outside the nanotechnology R&D industry. It is extremely difficult to strictly define which establishments should be classified in this industry.

There is also a growing presence of nanobiotechnology that combines aspects of nanotechnology and biotechnology.

The ECPC does not recommend a new industry for nanotechnology research and development because of the potential problems with mutual exclusivity with existing industries in NAICS.

12-0011 Sector 55 Management of Companies and Enterprises. Keyword — Additional Industry Detail

Docket Number 12-0011
Sector 55 Management of Companies and Enterprises — Additional Industry Detail

Docket 12-0011 proposed the creation of new industries for establishments classified as Corporate, Subsidiary, and Regional Managing Offices in NAICS 551114 to more narrowly define the classification of the enterprise that they are serving. The docket also recommended a separate sector in NAICS for units that outsource manufacturing transformation activities. A general response, included separately from docket summaries, addresses the ECPC position on outsourcing.

NAICS identifies industries based on differences in production functions. Corporate, subsidiary, and regional managing offices are classified together in NAICS because the process of managing groups of establishments is similar regardless of the particular activities of the establishments. The further identification of separate industries based on who is served in NAICS does not adhere to the principles outlined in this and previous notices.

The ECPC considered this issue when recommending a treatment of auxiliary or support units in the development of NAICS. A more complete summary of the ECPC recommendation is available at: http://www.census.gov/eos/www/naics/history/docs/cm_3.pdf

The ECPC continues to support this position, and does not recommend additional industries within Sector 55 defined in terms of the enterprise being served.

12-0012 Sector 81 Other Services (except Public Administration). Keyword — Heavy Truck Repair Services

Docket Number 12-0012
Sector 81 Other Services (except Public Administration) — Heavy Truck Repair Services

Docket 12-0012 requested a new industry for heavy truck repair and maintenance services. These activities are currently combined with all motor vehicle repair and maintenance services within Industry Group 8111, Automotive Repair and Maintenance.

The ECPC does not recommend splitting out a separate industry for repair of heavy-duty trucks (or diesel truck repair). There is merit to the proposal because there are clearly establishments that are primarily engaged in repair of heavy-duty trucks. Providing such services requires larger facilities as well as specially trained mechanics. However, the line between heavy trucks and passenger vehicles is not clearly defined. Previous attempts to collect kind-of-business data for heavy truck and bus repair were not successful.

The ECPC does recommend that the definitions and illustrative examples for the industries in 8111 be expanded to clarify that establishments primarily engaged in the repair of heavy-duty trucks are included in these industries.

12-0013 Sector 31-33 Manufacturing. Keyword — Valves, Hydrants, and Sampling Stations

Docket Number 12-0013
Sector 31-33 Manufacturing — Valves, Hydrants, and Sampling Stations

The ECPC does not recommend a new industry, but does recommend changes to existing index items to clearly classify the valve, hydrants, and sampling stations that are the subject of this proposal. The generic index item for hydrant manufacturing should be augmented with a new index item that clearly includes flushing hydrants. NAICS should also include an index item for sampling stations to Industry 332911, Industrial Valve Manufacturing.

The ECPC does not recommend index items for water distribution flushing hydrants and water distribution sampling devices in Industry 221310, Water Supply and Irrigation Systems. Establishments in this industry are primarily engaged in operating water treatment plants and/or operating water supply systems. A water supply system is a system for the collection, transmission, treatment, storage and distribution of water from source to consumers, which include homes, commercial establishments, irrigation facilities and public agencies for water-related activities (firefighting, street flushing and so forth).

Finally, the ECPC does recommend that index items be added for flushing hydrants installation and water sampling station installation in Industry 237110, Water and Sewer Line and Related Structures Construction.

Summary: Add the following index items:

332911 Flushing hydrant manufacturing

332911 Sampling station manufacturing

237110 Water sampling station installation

237110 Hydrant and flushing hydrant installation

12-0014 Sector 31-33 Manufacturing. Keyword — Vertically Integrated Foundry and Valve Manufacturing

Docket Number 12-0014
Sector 31-33 Manufacturing — Vertically Integrated Foundry and Valve Manufacturing

Docket 12-0014 requested a new industry for vertically integrated copper foundries and valve manufacturing. The docket requested a specific size standard for this new industry.

In general, NAICS addresses this type of combined activity by classifying vertically integrated establishments in either the first stage or the final stage of the integrated process (depending on the specific manufacturing area), rather than creating combination industries. This is explained on page 21 of the 2007 NAICS Manual as follows:

Vertical integration involves consecutive stages of fabrication or production processes in which the output of one step is the input of the next. In general, establishments will be classified based on the final process in a vertically integrated production environment, unless specifically identified as classified in another industry. For example, paper may be produced either by establishments that first produce pulp and then consume that pulp to produce paper or by those establishments producing paper from purchased pulp. NAICS specifically specifies that both of these types of paper-producing processes should be classified in NAICS 32212, Paper Mills, the industry, or the final step in paper manufacturing, rather than in NAICS 32211, Pulp Mills. In other cases, NAICS specifies that vertically integrated establishments be classified in the industry representing the first stage of the manufacturing process. For example, steel mills that make steel and also perform other activities such as producing steel castings are classified in NAICS 33111, Iron and Steel Mills and Ferroalloy Manufacturing, the first stage of the manufacturing process.

As for vertically integrated copper foundries that further process into products, the following cross-reference for Industry 331525, Copper Foundries (except Die-Casting), clearly indicates classification with the final stage:

Establishments primarily engaged in -- Manufacturing copper castings and further manufacturing them into finished products -- are classified based on the specific finished product.

NAICS revisions and the Small Business Administrations (SBA) size standards are not developed concurrently. Decisions about NAICS revisions are based on NAICS principles and the conceptual framework behind the classification system, not on SBAs size standards or other non-statistical uses of NAICS. Therefore, the ECPC does not recommend the creation of a new industry for vertically integrated copper foundries and valve manufacturing activities. The ECPC encourages the respondent to contact the Small Business Administration with any concerns about the application of size standards by the agency.

12-0015 Sector 22 Utilities. Keyword — Renewable Energy Generation, Transmission, and Distribution

Docket Number 12-0015
Sector 22 Utilities — Renewable Energy Generation, Transmission, and Distribution

Docket 12-0015 requested a new industry group and 21 new industries to separately identify the generation, transmission, and distribution of renewable energy including solar, wind, biomass, geothermal, and tidal power sources.

The transmission and distribution of renewable energy cannot be separately identified in a useful way in NAICS because of the nature and operation of the transmission and distribution systems in the United States. According to the U.S Department of Energy, Distributed Energy Program, the electrical transmission grid pools electricity for a large number of power generation facilities. This arrangement increases the reliability of supply, but creates problems for the separate identification of transmission or distribution of electricity from renewable sources.

The ECPC considered the recent growth of renewable power in the electricity generation area and recommends the creation of the following new industries:

221114 Solar Electric Power Generation
221115 Wind Electric Power Generation
221116 Geothermal Electric Power Generation
221117 Biomass Electric Power Generation
221118 Other Electric Power Generation

All of the proposed industries were part of NAICS 221119, Other Electric Power Generation in NAICS United States 2007.

The ECPC recommendation is based on the expectation that these industries will continue recent growth trends into the future. The ECPC is concerned that the presence of co-generation facilities classified elsewhere in NAICS based on their primary activity may result in classification confusion. As the principles of NAICS specify, establishments will be classified to these industries only if electric power generation is the primary activity of the unit. This might lead to the movement of establishments from NAICS 562213, Solid Waste Combustors and Incinerators to the Utilities sector if the primary source of value added is determined to be electricity generation rather than solid waste treatment and disposal.

12-0016 General — Enterprise Classification

Docket Number 12-0016
General — Enterprise Classification

Docket 12-0016 requested the classification of enterprises using the NAICS based on the largest share of gross receipts for the enterprise.

NAICS is an establishment classification rather than a company or enterprise classification system. There are numerous problems with using NAICS to classify entire enterprises on a consolidated basis. While there are many programs that do use NAICS to code enterprises, the results are often ambiguous based on the variable that is used to evaluate enterprise classification. Common variables used include gross revenues, as suggested by the respondent, but also number of establishments, number of workers, payroll, or value added shares. The choice of variable used can, and often does, result in different classifications.

Because these issues are primarily implementation issues rather than issues related to the core classification, the ECPC does not recommend a change or additional text in the NAICS United States 2012 Manual to discuss classification of enterprises. The ECPC encourages the respondent to work with data collection programs to ensure that the method of classifying enterprises using NAICS codes is understood and changed if necessary to meet their individual needs. Specifically, the ECPC recommends that the respondent contact the Census Bureau where an enterprise statistics program is currently in development.

12-0017(a) Various — Various Proposals from Census Bureau Subject Matter Areas

Docket Number 12-0017(a)
Various — Various Proposals from Census Bureau Subject Matter Areas

Based on implementation experience, the Census Bureau submitted numerous change requests to NAICS United States in the non-manufacturing sectors of NAICS. Each of the recommendations was evaluated and considered by the ECPC when developing recommendations. The following is a summary of the requests and the ECPC recommendations:

a) The ECPC does not recommend the addition of institutional pharmacies to the definitions of NAICS 454111, Electronic Shopping, NAICS 454113, Mail-Order Houses, or NAICS 454390, Other Direct Selling Establishments. However, because the classification of institutional pharmacies could be ruled to wholesale just as easily as to retail, the ECPC should add appropriate index items to clarify their placement in retail, such as Institutional pharmacies, on-site in 446110; Institutional pharmacies, off-site, mail-order in 454113; and Institutional pharmacies, off-site, exclusively on Internet in 454111.

b) The ECPC does not recommend adding on-line pharmacies to the definition of NAICS 454111, Electronic Shopping, or mail-order pharmacies to the definition of NAICS 454113, Mail-Order Houses. There is also no need to add index items, since the definitions for those industries should make clear that retailing on-line (regardless of what is being retailed) goes into 454111, and retailing through mail-order (regardless of what is being retailed) goes into 454113. If we start adding index items for different products that may be retailed on-line or through mail order, where do we draw the line?

c) The ECPC does recommend adding index items to clarify that pharmacies of pharmacy benefit management companies are included in 454111 or 454113, based on method of selling. The difficulty is in finding appropriate wording to address this.

d) The ECPC does not recommend modifying the definitions of NAICS 446110, Pharmacies and Drug Stores, NAICS 446199, All Other Health and Personal Care Stores, or, NAICS 454390, Other Direct Selling Establishments, to include establishments with predominant sales of prescriptions (drugs, medical equipment, prosthetics) in combination with related health care services. Pharmacies primarily engaged in dispensing and reselling drugs should continue to be classified in 446110 even if they provide services to administer the dispensed drugs. Home Health Care Service providers are primarily engaged in providing services such as oxygen therapy, respiratory therapy, infusion therapy, and administering drugs which are prescribed by a doctor and dispensed by a pharmacy; therefore they should continue to be classified in 621610. The ECPC does recommend modifying the definition of 446110 to clarify that they dispense prescription drugs.

e) The ECPC does not recommend adding specialty pharmacies to the definitions of NAICS 454111, Electronic Shopping or NAICS 454113, Mail-Order Houses.

f) The ECPC does recommend modifying the definitions and cross-references for 447110 and 447190, to reconsider the use of known as and to clarify the treatment of separate convenience stores and gas pumps at the same physical location. There is no clear action to take on bulk fuel retailers. It appears that there are gasoline stations, bulk fuel terminals, or storage and warehousing facilities maintained by gasoline companies to supply their own gasoline stations.

g) The ECPC recommends eliminating the six-digit industries under NAICS 45431 but retain the five-digit industry as national level detail (454310) in NAICS United States 2012.

h) The ECPC recommends modifying the definitions of NAICS 452111, Department Stores (except Discount Department Stores) and NAICS 452112, Discount Department Stores to emphasize the presence of sales associates. The ECPC recommends known as discount department stores be added to the definition of NAICS 452112.

i) The ECPC recommends deleting or modifying the index item Manufactured (mobile) home parts and accessory dealers in NAICS 453930. The ECPC recommends adding a cross-reference under 453930 indicating that establishments primarily engaged in retailing parts and accessories for mobile homes without retailing mobile homes would be classified to the industry corresponding to the parts and accessories that they retail.

j) The ECPC recommends combining NAICS 441221, Motorcycle, ATV, and Personal Watercraft Dealers with NAICS 441229, All Other Motor Vehicle Dealers to create a new industry NAICS 441228, All Other Motor Vehicle Dealers in NAICS United States 2012.

k) The ECPC does not recommend expanding the definition of NAICS 453310, Used Merchandise Stores, to include junk yards and salvage yards that sell significant amounts to household consumers because NAICS industry distinctions should be made based on production process, not on class of customer. However, the ECPC recommends adding an index item for 453310 for architectural salvage dealers, since these establishments more closely resemble other types of retail stores in terms of production process.

l) The ECPC recommends adding a cross-reference to NAICS 441110, New Car Dealers:
Establishments primarily engaged in-
  • Merchant wholesale distribution of new medium- and heavy-duty trucks, buses, and other motor vehiclesare classified in U.S. Industry 423110, Automobile and Other Motor Vehicle Merchant Wholesalers.
The ECPC recommends adding the following cross-reference to NAICS 441120, Used Car Dealers:
Establishments primarily engaged in-
  • Merchant wholesale distribution of used medium- and heavy-duty trucks, buses, and other motor vehiclesare classified in U.S. Industry 423110,.
  • Automobile and Other Motor Vehicle Merchant Wholesalers.
To make even clearer the fact that establishments primarily engaged in the sale of medium- and heavy-duty trucks and buses are classified in wholesale trade (and a retail component is not recognized in NAICS), the above cross-references could be modified to say: Establishments primarily engaged in reselling new . . . or reselling used.

m) The ECPC recommends adding the following cross-reference to NAICS 441320, Tire Dealers:
Establishments primarily engaged in-
  • Merchant wholesale distribution of new/used tires for medium- and heavy-duty trucks, buses, and other motor vehiclesare classified in U.S. Industry 423130, Tire and Tube Merchant Wholesalers.
n) The ECPC recommends structure changes within Sector 44-45 as follows: Combine 443112, Radio, Television, and Other Electronics Stores; 443120, Computer and Software Stores; 443130, Camera and Photographic Supplies Stores; and 451220, Prerecorded Tape, Compact Disc, and Record Stores to create a new 6-digit industry 443142 Electronics Stores under a new 5-digit NAICS industry 44314 Electronics and Appliance Stores;
Change code for Household Appliance Stores to 443141, under the new 44314;
Change title of Subsector 451 to "Sporting Goods, Hobby, Musical Instrument, and Book Stores"; and
Change title of Industry Group 4512 to "Book Stores and News Dealers".

Note that this will be reusing codes 443 and 4431 with modified content (addition of prerecorded tape, CD and record stores) and reusing codes 451, 4511, and 4512 with modified content (removal of prerecorded tape, CD, and record stores). This seems to be the least disruptive approach.

The revised 443 will be as follows:
443 Electronics and Appliance Stores
4431 Electronics and Appliance Stores
44314 Electronics and Appliance Stores
443141 Household Appliance Stores
443142 Electronics Stores

o) The ECPC recommends making the following modification to the cross-reference under NAICS 451140, Musical Instrument and Supplies Stores, so that the word rare is included:

Establishments primarily engaged in
  • Retailing used musical instruments (including used rare musical instruments), sheet music, and related supplies--are classified in Industry 453310, Used Merchandise Stores.


p) The ECPC recommends making the following modification to the cross-reference under NAICS 451211, Book Stores, so that the word rare is included:

Establishments primarily engaged in
  • Retailing used books (including used rare books) --are classified in Industry 453310, Used Merchandise Stores.
q) The ECPC recommends modifying the following cross-reference under NAICS 453310, Used Merchandise Stores, so that the word antique is included:

Establishments primarily engaged in
  • Retailing a general line of used and/or antique merchandise on an auction basis (except electronic auctions)--are classified in U.S. Industry 453998, All Other Miscellaneous Store Retailers (except Tobacco Stores).
The ECPC recommends making the following modification to the definition of NAICS 453920, Art Dealers:

This industry comprises establishments primarily engaged in retailing original and limited edition art works. Included in this industry are establishments primarily engaged in displaying works of art for retail sale in art galleries or at art auctions.

r) The ECPC does not recommend modifying the definition of NAICS 453998, All Other Miscellaneous Store Retailers (except Tobacco Stores), but it should modify the following cross-reference listed under this industry, so that it includes art auctions:

Establishments primarily engaged in
  • Retailing original and limited edition art works, including on an auction basis (except electronic auctions)--are classified in Industry 453920, Art Dealers
The ECPC recommends adding the following as an index item to NAICS 453310, Used Merchandise Stores: Used rare collectors items (e.g., autograph, coin, card, stamp) shops

The ECPC recommends adding the following cross-reference to NAICS 453998, All Other Miscellaneous Store Retailers (except Tobacco Stores): Establishments primarily engaged in
  • Retailing used (included used rare) collectors items (e.g., autograph, coin, card, stamp)are classified in Industry 453310, Used Merchandise Stores
s) The ECPC does not recommend combining NAICS 454112, Electronic Auctions, with NAICS 454111, Electronic Shopping, to form one combined industry.

As a side note, the ECPC does recommend minor modifications to the definitions for Subsector 454, Nonstore Retailers, and NAICS Industry 45411, Electronic Shopping and Mail-Order Houses, to clearly indicate that electronic auctions are included.

t) The ECPC recommends adding the following as an index item to NAICS 441310, Automotive Parts and Accessories Stores: Batteries, automotive, dealers

The ECPC also recommends adding the following as an index item to NAICS 453998, All Other Miscellaneous Store Retailers (except Tobacco Stores): Batteries, except automotive, dealers

The ECPC does not recommend adding Batteries, watch, retail as an index item to NAICS 448310, Jewelry Stores. This does not appear to be a primary activity.

The ECPC does not recommend adding On-line gift cards/certificates, retail as an index item to NAICS 454111, Electronic Shopping.

The ECPC does not recommend adding junk yards or salvage yards as index items in the Wholesale Trade Sector, but does recommend adding an item for architectural salvage dealers in NAICS 453310, Used Merchandise Stores.

The ECPC recommends adding the following as an index item to NAICS 454319, Other Fuel Dealers: Alternative fuels, direct selling

12-0017(b) Various — Various Proposals from Census Bureau Subject Matter Areas

Docket Number 12-0017(b)
Various — Various Proposals from Census Bureau Subject Matter Areas

Based on implementation experience, the Census Bureau submitted numerous change requests to NAICS United States in the non-manufacturing sectors of NAICS. Each of the recommendations was evaluated and considered by the ECPC when developing recommendations. The following is a summary of the requests and the ECPC recommendations:

a) Sales offices of publishers is addressed in a separate summary.

b) Classification of logistics service providers is addressed in a separate summary.

c) The ECPC does not recommend adding Pharmacy Benefit Managers (PBM) as an index item to any existing NAICS code. The PBM label is too vague and the activities performed by individual establishments within the larger Pharmacy Benefit Management company or enterprise are the basis for classification. The classification of PBM establishments depends on the primary activity of each establishment. If an establishment is primarily engaged in claims processing services (third-party) they are classified in NAICS 524292, Third Party Administration of Insurance and Pension Funds. If an establishment is primarily engaged in selling prescriptions on-line they are classified in NAICS 454111, Electronic Shopping. If an establishment is primarily engaged in selling prescriptions via mail order, they are classified in NAICS 454113, Mail-Order Houses.

The ECPC does recommend classifying all types of group purchasing organizations in the Wholesale Trade Sector, including captive procurement offices. This would help eliminate any confusion over the exceptions that currently exist, while still adhering to NAICS principles. The term group purchasing organizations should be listed with the other examples laid out in the sector description for Wholesale Trade:

Group purchasing organizations buying and selling goods are included in Subsectors 423 and 424. Group purchasing organizations that are arranging for the purchase of goods on an agency basis are classified in Subsector 425. Administrative offices arranging for the purchase of goods to be used in production rather than resold are classified in NAICS 561990.

d) Home health care services and specialty pharmacies are addressed under the summary for 12-0017(a).

e) The ECPC recommends adding an index item for medical care management services and an index item for medical case management services to NAICS 621999.

f) The ECPC recommends modifying the existing index item for discount buying services to read, Discount buying services, including medical cards and similar negotiated discount plans for individuals in NAICS 812990, All Other Personal Services.

12-0017(c) Various — Various Proposals from Census Bureau Subject Matter Areas

Docket Number 12-0017(c)
Various — Various Proposals from Census Bureau Subject Matter Areas

Based on implementation experience, the Census Bureau submitted numerous change requests to NAICS United States in the non-manufacturing sectors of NAICS. Each of the recommendations was evaluated and considered by the ECPC when developing recommendations. The following is a summary of the requests and the ECPC recommendations:

a) The ECPC does not recommend a new index item for conversion of gasoline internal combustion engines to natural gas because it is not considered a primary activity.

b) The ECPC does not recommend a new index item for agra-entertainment.

c) The ECPC does not recommend a new index item for ice cream parlors that manufacture on site. If establishments were manufacturing ice cream on the premises for retail sale, according to the treatment of tortillas and retail bakeries, they would be classified to manufacturing. There are many establishments that add prepared mix to a freezing unit (e.g., soft serve ice cream), and those establishments would not be considered manufacturers selling at retail. They would be snack shops or other eating establishments depending on the characteristics of the establishment.

d) The ECPC does not recommend a new index item for restaurant management. However, as is the case with hotels, a unit that manages and operates a restaurant is classified in NAICS as a restaurant.

e) The ECPC does not recommend a new index item for retail sale of prefabricated sheds and similar buildings.

f) The ECPC does not recommend a new index item for manufacturers sales representative. This is an occupation.

g) The ECPC does not recommend a new index item for nautical chart supplier.

h) The ECPC does not recommend a new index item for kiosks in retail trade. The term kiosk refers to the specific structure that items are being sold from, the retail space, not what the primary business activity is. Semi-permanent kiosks with displayed merchandise should be classified as store retailers rather than non-store retailers. The units would only be considered non-store retailers if they were fully portable and moved from location to location following demand. Kiosks in shopping malls are examples of semi-permanent locations that would be considered store retailers.

i) The ECPC does not recommend new index items for retailing fruit baskets or wholesaling fruit baskets.

j) The ECPC recommends that a new index item be added to NAICS 713990, All Other Amusement and Recreation Industries for paintball, laser tag, and similar fields and arenas. These are fast growing and popular recreational activities with specially designed and designated areas for play.

k) The ECPC recommends a new index item for hydrographic printing in NAICS 323119, Other Commercial Printing (or the equivalent industry in case of roll-up in the printing area).

l) The ECPC recommends a new index item for personal organizer services in NAICS 812990, All Other Personal Services.

m) The ECPC recommends a new index item for lactation consulting services in NAICS 812990, All Other Personal Services.

n) The ECPC does not recommend a new index item for flipping real estate.

o) The ECPC does not recommend a new index item for monogramming.

p) The ECPC does not recommend a new index item for recruiting services.

q) The ECPC notes that the existing index item for office management services is adequate.

r) The ECPC does not recommend a new index item for real estate development. This term is too complex and can be used to describe too many processes, to be placed under one specific industry in NAICS.

s) The ECPC recommends a new index item for life coach services in NAICS 812990, All Other Personal Services.

t) The ECPC does not recommend a new index item for community development. The term is multifaceted and refers to several different services that several different kinds of establishments provide.

u) The ECPC recommends a new index item for identity theft protection services in NAICS 561611, Investigation Services.

v) The ECPC recommends a new index item for radio frequency identification (RFID) equipment wholesaling in NAICS 423690, Other Electronic Parts and Equipment Merchant Wholesalers. The ECPC does not recommend a new index item for RFID equipment manufacturing.

w) The ECPC does not recommend a new index item for information/data assurance services.

x) The ECPC does not recommend a new index item for E-learning. Specific language was added to education industries where appropriate for electronic and distance learning in the 2007 NAICS Manual update.

y) The ECPC recommends a new index item for landman services in NAICS 531390, Other Activities Related to Real Estate.

z) The ECPC does not recommend a new index item for real estate investor.

aa) The ECPC does not recommend a new index item for real estate owner.

bb) The ECPC does not recommend a new index item for paper tickets.

cc) The ECPC does not recommend a new index item for cake decorating services.

dd) The ECPC does not recommend a new index item for real estate investing, personal.

ee) The ECPC does not recommend a new index item for professional witness.

ff) The ECPC does not recommend a new index item for inflatables manufacturing.

12-0017(d) Various — Various Proposals from Census Bureau Subject Matter Areas

Docket Number 12-0017(d)
Various — Various Proposals from Census Bureau Subject Matter Areas

Based on implementation experience, the Census Bureau submitted numerous change requests to NAICS United States in the non-manufacturing sectors of NAICS. Each of the recommendations was evaluated and considered by the ECPC when developing recommendations. The following is a summary of the requests and the ECPC recommendations:

a) The ECPC recommends a new index item for film preservation services in NAICS 512199, All Other Motion Picture and Video Industries.

b) The ECPC recommends removal of language from the definition of NAICS 512210 that addresses record production in terms of records and CDs. The primary activity of these establishments is contracting with artists and financing the production of their master recordings. If the entity further produces and distributes the physical recordings, they are more appropriately classified in NAICS 512220, Integrated Record Production/Distribution.

c) The ECPC recommends review of the text describing ISPs. The review should consider use of terminology such as always-on connection rather than broadband.

d) The ECPC does not recommend adding language to opticians for eye examinations.

e) The ECPC does not recommend a change in the classification of establishments that have a racetrack and slot machines. Classification should be based on the primary activity.

f) The ECPC does not recommend a new index item for religious foundations because that term is not unambiguously classified to a single NAICS industry.

12-0018 Sector 22 Construction. Keyword — Specialty Trade Contractors

Docket Number 12-0018
Sector 23 Construction — Specialty Trade Contractors

  1. The ECPC does not recommend combining all six industries under NAICS 2383, Building Finishing Contractors, into one collective industry for 2012 NAICS. Economic data, as well as research, shows that the existence of the six separate industries is justified.
  2. The ECPC does not recommend altering the organizational structure of NAICS 2381, Foundation, Structure, and Building Exterior Contractors, or NAICS 2383, Building Finishing Contractors for 2012 NAICS. The current structure adequately organizes the necessary industries.
  3. The ECPC does not recommend a new industry for sheet metal contractors or boiler contractors for 2012 NAICS. The existing index entries for these activities are sufficient.
  4. The ECPC does not recommend movement of NAICS 238910, Site Preparation Contractors, to Industry Group NAICS 2381, Foundation, Structure, and Building Exterior Contractors for 2012 NAICS.
  5. The ECPC does not recommend altering the organizational structure of NAICS 2382.

12-0019 Various — Modeling and Simulation

Docket Number 12-0019
Various — Modeling and Simulation

The ECPC does not recommend creating new NAICS industries for modeling and simulation equipment manufacturing or for modeling and simulation services. While the impact of this technology is obvious, it would violate NAICS production-based principles to separate out activity relating to modeling and simulation. Research indicates that there are two main processes involved with M&S. The first is the creation of the programs for simulation, the models, which belong under NAICS 541511 Custom Computer Programming Services. The second, as is the case with flight simulators, is the actual manufacturing of simulators. These belong in NAICS 333319 Other Commercial and Service Industry Machinery Manufacturing.

(from 07-0051)

While the modeling and simulation process is widely used by many types of establishments, grouping all of the establishments that develop or use modeling and simulation is not possible within the current structure and principles of NAICS. Simulation is clearly a separate and growing use of modern computer technology. Simulations can be relatively simple taking the form of video games or much more complex, such as simulation of military situations or testing and evaluation models used by engineers to evaluate catastrophic failure of mechanical systems. Simulation is not an industry, simulation is a method or a specialized regimen that is produced and consumed in the provision of other services - training, testing, entertainment, etc. Quantitative modeling is used in a wide range of disciplines including economics, statistics, engineering, etc. to simulate the effect of exogenous variables on systems. As such, the method is not classifiable as an industry any more than project management is classifiable as an industry or analysis is classifiable as an industry.

It is clear that engineering firms who evaluate the systems to be simulated and develop technical interpretations of those systems can provide simulation services. Custom computer software developers take the technical interpretations or models and convert these into programs which operate within computer systems. Finally, there are developers of systems that use the complete output to provide training or learning environments for specific situations. These units are providing an education service.

The ECPC does not recommend creating a new industry for Modeling and Simulation Services because the industry would cause problems with mutual exclusivity. The request is a use-based request, and units doing similar things for other computer system development and application would be classified differently based on the intended use of the integrated computer system.

12-0020 Sector 31-33 Manufacturing. Keyword — Ethyl Alcohol

Docket Number 12-0020
Sector 31-33 Manufacturing — Ethyl Alcohol

Docket 12-0020 points out a problem in the current classification of ethyl alcohol. The two basic processes used to produce ethyl alcohol (hydration of ethylene and fermentation of sugars) are not clearly delineated in NAICS. Currently, Industry 312140, Distilleries, includes the production of potable ethyl alcohol (using fermentation or synthetic processes), while all non-potable ethyl alcohol is classified in 325193, Ethyl Alcohol manufacturing.

A clear production function approach to classification of ethyl alcohol would identify the two production processes separately. NAICS currently separates ethyl alcohol based on the use - potable with beverages and non-potable with chemicals.

The ECPC does not recommend separate industries for ethyl alcohol produced by fermentation and ethyl alcohol produced by hydration of ethylene. While there is merit to the proposal to separate industries by production function, NAICS would combine the potable and non-potable by production process and the new industries would need to include producers in both 312140 and 325193. It is not clear that the resulting data would be more useful at the industry level.

12-0021 Various — Solar Structure Construction/ Photovoltaic Module Manufacturing

Docket Number 12-0021
Various — Solar Structure Construction/ Photovoltaic Module Manufacturing

The ECPC reviewed the proposals and notes that the growth, in both size and revenue, of photovoltaic technology manufacturing globally is on the rise.

However, the production of the PV cells in NAICS 334413, Semiconductor and Related Device Manufacturing is different from the assembly of the cells into modules. The ECPC recommends the addition of an index item in NAICS 335999, All Other Miscellaneous Electrical Equipment and Component Manufacturing for units that purchase PV cells and assemble them into modules for specific applications. The ECPC should leave the manufacture of photovoltaic cells from semiconductor materials in NAICS 334413 or the equivalent industry if the proposal to split semiconductor integrated circuits into a new separate NAICS industry is adopted.

The ECPC does not recommend creating a new NAICS industry for solar power structure construction.

12-0022 Sector 11 Agriculture, Forestry, Fishing and Hunting. Keyword — Plant Aquaculture

Docket Number 12-0022
Sector 11 Agriculture, Forestry, Fishing and Hunting — Plant Aquaculture

The ECPC does not recommend changing the terminology in the Agriculture, Forestry, Fishing and Hunting Sector, from total agricultural production to total value of agricultural production.

The ECPC does not recommend inserting primarily into the titles of each industry. The NAICS industry definitions include title, narrative description, examples (or index items) and cross references. The current narrative descriptions include the primarily engaged in language and repeating the terminology in the title is not necessary.

The ECPC does not recommend that aquaculture of plant products be moved from Industry Group 1125, Aquaculture back to Industry 111998, All Other Miscellaneous Crop Farming. However, the ECPC does recommend changing the title of Subsector 112 to "Animal Production and Aquaculture" to clarify that all forms of aquaculture are included.

12-0023 Sector 23 Construction. Keyword — Firestop Contractors

Docket Number 12-0023
Sector 23 Construction — Firestop Contractors

The ECPC does not recommend the creation of a new industry within Industry Group 2383 for Firestop Contractors. The ECPC noted the specialization of these units and the increasing number of contractors providing these services over the past 15 years based on changes to building codes, but in international discussions could not reach agreement with our NAICS partners on creation of this NAICS industry. However, the ECPC did obtain agreement from Mexico and Canada that existing NAICS index items associated with the primary activities of firestop contractors could be moved into Industry 23831, Drywall and Insulation Contractors. Therefore, the ECPC recommends that the existing index items "building fireproofing contractors" and "fireproof flooring construction contractors" be moved to US Industry 238310. The ECPC further recommends that the requester contact the Manufacturing and Construction Division at the Census Bureau to discuss the potential addition of inquiries related to firestop contractor activities in the 2012 Census of Construction.

12-0024 Sector 31-33 Manufacturing. Keyword — Cryogenic Treatment of Metal

Docket Number 12-0024
Sector 31-33 Manufacturing — Cryogenic Treatment of Metal

Docket 12-0024 requested a new industry for establishments primarily engaged in cryogenic treatment of metal. The ECPC considered the activity and agreed that all temperature treating of metal should be classified to NAICS 332811, Metal Heat Treating. The ECPC discussed but does not recommend a change to the industry title to include all temperature treatment of metals because terminology such as temperature treating was not used within the industry. The ECPC does recommend new index items in 332811 as follows:

332811 Cold treating metals for the trade
332811 Cryogenic treating metals for the trade

12-0025 Sector 31-33 Manufacturing. Keyword — Outsourcing

Docket Number 12-0025
Sector 31-33 Manufacturing — Outsourcing

The ECPC recommendation for outsourcing is included in a separate summary.

12-0026 Sector 31-33 Manufacturing. Keyword — Outsourcing, Manufacturing Detail Reduction

Docket Number 12-0026
Sector 31-33 Manufacturing — Outsourcing, Manufacturing Detail Reduction

The ECPC recommendations on outsourcing and reduction of manufacturing detail are included in separate summaries.

12-0027 General — Standardized Industry, Occupation, and Product Taxonomies

Docket Number 12-0027
General — Standardized Industry, Occupation, and Product Taxonomies

The ECPC thanks the respondent for comments on standardizing taxonomies and hierarchies for the industry, occupational, and product classification systems and linking data collected using those classification systems. The ECPC encourages the respondent to contact programs collecting data on those variables when attempting to develop an end-to-end jobs solution for unemployed individuals.

12-0028 General — General Comments

Docket Number 12-0028
General — General Comments

The ECPC thanks the respondent for their comments noting that none of the proposals in the Federal Register raise concerns.

12-0029 Sector 31-33 Manufacturing. Keyword — Sign Manufacturing, Outsourcing

Docket Number 12-0029
Sector 31-33 Manufacturing — Sign Manufacturing, Outsourcing

Docket 12-0029 requested a change to the sign manufacturing industry to include establishments from NAICS 339950, Sign Manufacturing; 323110, Commercial Lithographic Printing; 323113, Commercial Screen Printing; 323115, Digital Printing; 541430, Graphic Design Services; 541850, Display Advertising; and 541890, Other Services Related to Advertising in a single industry. The ECPC does not recommend this change based on the principles of NAICS. The request is for an end use category rather than an industry based on a unique and separable production process.

The ECPC recommendation on outsourcing is included in a separate summary.

12-0030 Sector 31-33 Manufacturing. Keyword — Outsourcing

Docket Number 12-0030
Sector 31-33 Manufacturing — Outsourcing

The ECPC recommendation on outsourcing is included in a separate summary.

12-0031 Sector 31-33 Manufacturing. Keyword — Hybrid Engine Manufacturing, No Reduction in 336, Outsourcing

Docket Number 12-0031
Sector 31-33 Manufacturing — Hybrid Engine Manufacturing, No Reduction in 336, Outsourcing

The ECPC does not recommend a new industry for hybrid engine manufacturing in the Transportation Equipment subsector of NAICS. The ECPC recognizes the importance and rapid growth of clean motor vehicle propulsion systems but notes that many different manufacturers are involved in producing the parts that are assembled in a hybrid gas/electric system in motor vehicles. It is common to have one manufacturer build the internal combustion engine component (NAICS 336312), another produce the batteries (NAICS 335911), and yet another produce the alternator or generator used in the system (NAICS 336322). These inputs come together on the automobile assembly line where the hybrid propulsion system is completed and installed in a motor vehicle. The individual activities performed are classified within the existing industry structure of NAICS.

The ECPC recommendation on outsourcing is included in a separate summary.

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0032 Various — Manufacturing Detail Reduction, Outsourcing, Distribution Centers, REITs

Docket Number 12-0032
Various — Manufacturing Detail Reduction, Outsourcing, Distribution Centers, REITs

Docket 12-0032 provided comments on each of the issues listed for comment in the Federal Register notice and included a separate request to move REITs from the Real Estate Sector to the Finance Sector in NAICS.

The ECPC recommendations on the other Federal Register Notice questions are included in separate summaries. The ECPC does not recommend a change to move REITs from NAICS Sector 53, Real Estate and Rental and Leasing to NAICS Sector 52, Finance and Insurance.

12-0033 Sector 31-33 Manufacturing. Keyword — Manufacturing Detail Reduction

Docket Number 12-0033
Sector 31-33 Manufacturing — Manufacturing Detail Reduction

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0034 Sector 62 Health Care and Social Assistance. Keyword — Prosthetic and Orthopedic Appliance Delivery

Docket Number 12-0034
Sector 62 Health Care and Social Assistance — Prosthetic and Orthopedic Appliance Delivery

Docket 12-0034 requested a new industry for prosthetic and orthopedic appliance delivery services. It is clear that demand for this type of health care service is growing and that establishments providing these services are doing far more than simply supplying prosthetics. NAICS currently classifies the manufacture of these appliances in 339113, Surgical Appliance and Supplies Manufacturing. NAICS classifies establishments primarily engaged in selling these appliances with no associated health care services in 446199, All Other Health and Personal Care Stores. NAICS classifies practices of medical doctors providing prosthetic and orthopedic health care services in NAICS 621111, Offices of Physicians (except Mental Health Specialists). NAICS currently classifies practices of certified practitioners other than physicians in 621399, Offices of All Other Miscellaneous Health Practitioners.

Because the manufacture, sale, and medical services associated with prosthetic and orthopedic appliance delivery are classified in a variety of industries based on the production functions of different establishments, the ECPC does not recommend creating a new industry in Sector 62. The ECPC does recommend adding new index items to NAICS 621399, Offices of All Other Miscellaneous Health Practitioners for Orthotists offices (e.g., centers, clinics) and Prosthetists offices (e.g., centers, clinics) to clearly indicate where the office of these specialized practitioners are classified in NAICS.

12-0035 Sector 23 Construction. Keyword — Various Proposals Delivery

Docket Number 12-0035
Sector 23 Construction — Various Proposals Delivery

Docket 12-0035 requested several changes to the NAICS construction sector. The changes requested are 1) Modifying the terminology and description for three of the four U.S. industries within the residential building construction NAICS industry, 2) Creating separate residential and nonresidential national industries within each specialty trade contractor NAICS industry, 3) Creating a new structured wiring technology contractors NAICS industry within the building equipment contractors industry group, and 4) Creating a new U.S. industry for residential community associations, distinct from the sports and athletic organizations with which they are currently grouped.

The ECPC recommends changing the terminology within the titles of three 6-digit industries under Industry 23611, replacing the phrase "Operative Builders" with "For-Sale Builders". The ECPC does not recommend splitting each specialty trade contractor NAICS industry into separate industries for nonresidential and residential. A previous study in this area showed that construction trade contractors often perform both residential and nonresidential work, and separating the industries based on the intended client does not align with the principles of NAICS. The ECPC does not recommend creating a separate industry for structured wiring technology contractors because of the similarity in process for other wiring installation. The ECPC did make a title change and narrative changes to Industry 238210, Electrical Contractors and Other Wiring Installation Contractors in 2007 to clarify classification of the other wiring contractors. The ECPC does not recommend creating a separate industry for residential community associations under 81399, consisting of homeowners' associations, condominium homeowners' associations, condominium corporations, condominium owners' associations, and cooperative owners' associations because the activities of these associations often overlap with neighborhood associations that are responsible for maintenance of certain common elements as well.

12-0036 Various — Distribution Centers, Logistics, Publishers Sales Offices

Docket Number 12-0036
Various — Distribution Centers, Logistics, Publishers Sales Offices

The ECPC recommendations on Distribution Centers, Logistics, and Publishers Sales Offices are included in separate summaries.

12-0037 Sector 62 Health Care and Social Assistance. Keyword — Prosthetic and Orthopedic Appliance Delivery

Docket Number 12-0037
Sector 62 Health Care and Social Assistance — Prosthetic and Orthopedic Appliance Delivery

Docket 12-0037 requested a new industry for prosthetic and orthopedic appliance delivery services. It is clear that demand for this type of health care service is growing and that establishments providing these services are doing far more than simply supplying prosthetics. NAICS currently classifies the manufacture of these appliances in 339113, Surgical Appliance and Supplies Manufacturing. NAICS classifies establishments primarily engaged in selling these appliances with no associated health care services in 446199, All Other Health and Personal Care Stores. NAICS classifies practices of medical doctors providing prosthetic and orthopedic health care services in NAICS 621111, Offices of Physicians (except Mental Health Specialists). NAICS currently classifies practices of certified practitioners other than physicians in 621399, Offices of All Other Miscellaneous Health Practitioners.

Because the manufacture, sale, and medical services associated with prosthetic and orthopedic appliance delivery are classified in a variety of industries based on the production functions of different establishments, the ECPC does not recommend creating a new industry in Sector 62. The ECPC does recommend adding new index items to NAICS 621399, Offices of All Other Miscellaneous Health Practitioners for Orthotists offices (e.g., centers, clinics) and Prosthetists offices (e.g., centers, clinics) to clearly indicate where the offices of these specialized practitioners are classified in NAICS.

12-0038 Various — Visualization Technology

Docket Number 12-0038
Various — Visualization Technology

Docket 12-0038 requested two new NAICS industries for visualization technology products and visualization technology services.

The products and services provided by establishments engaged in visualization technology includes 3D modeling, gaming, GIS and GPS systems and applications, etc. The processes involve application of custom or off-the-shelf software products to develop new applications.

The proposal notes that providers of visualization technology generally are currently classified in NAICS 511210, Software Publishers; 541511, Custom Computer Programming Services; 541512, Computer Systems Design Services; 541519, Other Computer Related Services; 541614, Process, Physical Distribution, and Logistics Consulting Services; and 541618, Other Management Consulting Services.

The ECPC does not recommend adding new industries for visualization technology products and services because the groupings are demand-based rather than based on a unique separable production process. The existing industries are defined in terms of the processes used rather than the final application of the resulting products or services.

12-0039 Various — Green Industries

Docket Number 12-0039
Various — Green Industries

Docket 12-0039 requested that the following 22 new NAICS industries be created:

  1. Growing corn for fuel production
  2. Growing plants for fuel production
  3. Manufacturing solar panels
  4. Installation of solar panels
  5. Manufacturing solar reflecting insulation film
  6. Installation of solar reflecting insulation film
  7. Installation of solar water heaters
  8. Installation of windmills for commercial use
  9. Energy consulting
  10. Energy research
  11. Energy efficiency auditing
  12. Manufacturing green household cleaners
  13. Solar farms
  14. Converting tidal power to electric energy
  15. Converting wind power to electric energy
  16. Biomass companies
  17. Carbon offsets and trading
  18. Using cellulosic byproducts (such as orange, sugar cane, forestry) for ethanol production
  19. LEED (Leadership in Energy and Environmental Design) certified architectural design
  20. Building retrofitting to improve energy efficiency
  21. Using landfills to extract methane gas
  22. Manufacturing biodegradable bottles and containers

The ECPC does not recommend creating new industries for all these items. Many of the requests are based on end use (such as growing crops for fuel), rather than a separable production function. Several of the industries requested are too small to be identified as industries. However, the ECPC will add index items in appropriate industries for some of these activities. Under separate dockets, the ECPC is creating new industries for wind, solar, and other renewable source electricity generation, clarifying the treatment of incinerators that burn waste to produce electricity, and other actions included within the list above.

12-0040 Sector 31-33 Manufacturing. Keyword — Photonics

Docket Number 12-0040
Sector 31-33 Manufacturing — Photonics

Docket 12-0040 requested several changes to the NAICS manufacturing sector. The commenter requested specifically that the term photonics be added to the descriptions and index items of the NAICS manual. The terms optical and photonic are often used interchangeably and both should be included when describing the activities.

The ECPC will consider language and terminology changes to NAICS during preparation of the manual. The ECPC recommends that appropriate index items be considered to clearly indicate the classification of certain photonic product manufacturing in the appropriate industries within subsector 334. The ECPC does not recommend title changes to any of the current NAICS industries to add the term photonic. The ECPC further recommends adding an index item for photonics research and development services in 541712, Research and Development in the Physical, Engineering, and life Sciences (except Biotechnology).

12-0041 Sector 31-33 Manufacturing. Keyword — Wind Turbines

Docket Number 12-0041
Sector 31-33 Manufacturing — Wind Turbines

Docket 12-0041 requested that a new NAICS category be created for the wind industry, specifically for the manufacturing and installation of wind turbines.

In response to Docket 12-0015, the ECPC recommended the creation of a new industry in Sector 22 for Wind Electric Power Generation, recognizing the growing importance of wind energy as an alternative renewable energy source. However, the ECPC does not recommend creating a new NAICS industry for the manufacturing and installation of wind turbines. The ECPC recognizes the growing demand for wind turbines as demand for generation of wind energy increases, and acknowledges the significant increase in production of wind turbines over the last several years. However, while it is also clear that the specific components of a wind turbine are unique or highly specialized for this application, the production processes used for the manufacturing of wind turbines are already generically defined in NAICS. For example, casting is an industry in NAICS. Bearings, generators, and similar components are separately identified by process rather than use. Placing all of the production processes used in the manufacture and installation of wind turbines into one industry would draw activities from across multiple NAICS sectors and violate the production function orientation of NAICS.

The ECPC notes the following industries where primary production processes related to manufacturing and installation of wind turbines are classified, though not necessarily clearly delineated within the industry definitions:

  • NAICS 237130, Power and Communication Line and Related Structures Construction, includes index items for Wind power structure construction and Alternative energy (e.g., geothermal, ocean wave, solar, wind) structure construction.
  • NAICS 333611, Turbine and Turbine Generator Set Units Manufacturing, currently includes index items for Wind turbine (i.e., windmills) manufacturing and Windmills, electric power, generation-type, manufacturing. These items are descriptive in a generic sense, but should be more accurately defined. The ECPC recommends that the existing items be deleted and replaced with Wind turbine, electric power generation, manufacturing.
  • NAICS 333612, Speed Changer, Industrial High-Speed Drive, and Gear Manufacturing includes the manufacturing of gear boxes for wind turbines as separate components, although the specific delineation of use is not included in the definition. The ECPC recommends that an index item be added to this industry for Wind turbine gear box manufacturing.
  • NAICS 335312, Motor and Generator Manufacturing, includes the manufacture of the generator and yaw drive components used in the manufacture of a complete wind turbine, although the specific uses of equipment are not delineated in the current definition. The ECPC recommends that index items be added to this industry for manufacture of induction generators and manufacture of yaw drives.

The manufacture of one major component of wind turbines blades is not easily identified based on the language used in NAICS. Traditional glass fiber with resin or epoxy blade manufacture is currently classified in NAICS 326199, All Other Plastics Product Manufacturing. The process is very similar to the production of other fiberglass products. Carbon fiber reinforced polymer parts for aircraft are classified as aircraft parts and reinforced glass/resin boats are classified as boats. It might be useful to note that wind turbine blade production is focusing on improved materials and processes.

While blade manufacture is specialized, it is not clear that there are enough specialized establishments to reliably create industry statistics. The ECPC recommends that the Economic Census attempt to identify blades in the product collections for 2012 in order to more accurately identify the number of producers and the value of shipments for reconsideration of the request after the 2012 Economic Census.

12-0042 Sector 31-33 Manufacturing. Keyword — Outsourcing, Manufacturing Detail Reduction

Docket Number 12-0042
Sector 31-33 — Outsourcing, Manufacturing Detail Reduction

The ECPC recommendations on outsourcing and reduction of manufacturing detail are included in separate summaries.

12-0043 Sector 31-33 Manufacturing. Keyword — Manufacturing Detail Reduction

Docket Number 12-0043
Sector 31-33 Manufacturing — Manufacturing Detail Reduction

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0044 Sector 62 Health Care and Social Assistance. Keyword — Elderly, Persons with Disabilities

Docket Number 12-0044
Sector 62 Health Care and Social Assistance — Elderly, Persons with Disabilities

Docket 12-0044 requested a restructuring for the health care and social assistance service industries that focus on the provision of health-related and social assistance services to the elderly and persons with disabilities. The request asked for revisions in several areas to address terminology issues, to clarify examples and titles, and to address a setting-based distinction between residential and institutional care.

For NAICS 623210, Residential Mental Retardation Facilities and NAICS 623220, Residential Mental Health and Substance Abuse Facilities, the docket requested that larger or institutional settings be separated from community-based settings. In addition, the docket requested that the term intellectual and development disabilities replace mental retardation. Within industry group NAICS 6233, Community Care Facilities for the Elderly, the proposal requested that: 1) industries be redefined to distinguish along a dimension other than whether on-site skilled nursing care is offered; 2) the 6-digit industries be re-titled with terms that are more intuitive and reflective of actual groupings of residential care establishments for the elderly and those with non-IDD disabilities; and 3) provide more examples of establishments to be classified here. For NAICS 6239, Other Residential Care Facilities, the docket requested that if an other category is necessary, then the types of facilities that should be included within this 4-digit group should be more clearly specified. For NAICS 624120, Services for the Elderly and Persons with Disabilities, the proposal requested that the definitional problem related to the combined use of the terms social assistance and non-medical home care be addressed. Additionally, it was requested that greater direction regarding the extent to which fiscal agents and public authorities should be sampled be provided. Lastly, it was requested that this industry be reclassified as a 4-digit industry group, specifying 5-digit industries that correspond to employment captured by fiscal intermediaries, home care agencies, services provided in day programs, and suggesting that an additional 3-digit grouping corresponding to health assistance be considered.

The ECPC does not recommend adopting the recommendations related to changing content of, or restructuring, the industries referenced in this document, but does recommend adopting certain revisions in terminology, industry titles, and listing of examples. The ECPC recommends against using a size criterion to separately identify larger or institutional settings from smaller or community-based settings, as requested for NAICS 623210 and NAICS 623220. NAICS does not use size criteria when defining industries. The ECPC does not recommend redefining the industries within 6233, based on a different criterion than on-site nursing care. The on-site provision is the production function difference between continuing care retirement facilities and homes for the elderly. As for specifying the types of facilities included in NAICS 6239, the illustrative examples listed under 623990 (the only 6-digit industry under 6239) are quite specific.

With respect to requests for changes in NAICS 624120, the services provided to the elderly and persons with disabilities in this industry are defined as being provided by establishments providing non-residential social assistance services. The industry specifically excludes residential care and in-home health services. Fiscal intermediaries and home care agencies are not included in the scope of NAICS 624120 and should not be moved into the industry. In addition, ownership of establishments by private parties or public authorities is not a classification criterion in NAICS. However, establishments providing nonmedical services in the home of the client are included in the industry.

The terms 'nonmedical' and 'social assistance' are describing the same types of social assistance being offered. For NAICS purposes, services are either medical -- provided by a doctor, nurse, or other credentialed provider -- or they are nonmedical. It is recognized that a variety of services are often provided to the elderly/disabled populations by medical professionals, but nonmedical professionals do not provide medical services.

The ECPC recommends the following modifications to improve the terminology and clarify the content of the existing industries:

In NAICS 623311, add the terms board and care and congregate housing to the definition or as illustrative examples to clarify content by using terms known in the industry; In the definition of NAICS 624120, clarify that services can be provided in either a facility or a client's home.

The ECPC recommends changing the following NAICS titles:

6233 Continuing Care Retirement Communities and Assisted Living Facilities for the Elderly 62331 Continuing Care Retirement Communities and Assisted Living Facilities for the Elderly 623311 Continuing Care Retirement Communities 623312 Assisted Living Facilities for the Elderly. 6232 Residential Intellectual and Developmental Disability Facilities 62321 Residential Intellectual and Developmental Disability Facilities 623210 Residential Intellectual and Developmental Disability Facilities 623110 Nursing Care Facilities (Skilled Nursing Facilities)

The ECPC recommends adding the following index items:

624120 Activity centers for disabled persons, the elderly, and persons diagnosed with intellectual disabilities 624120 Companion services for disabled persons, the elderly, and persons diagnosed with intellectual disabilities 624120 Day care centers for disabled persons, the elderly, and persons diagnosed with intellectual disabilities 623210 Group homes, intellectual disability 623210 Homes with or without health care, intellectual disability 623210 Hospitals, intellectual disability 623210 Hospitals, mental (except intellectual disability) 623210 Intermediate care facilities, intellectual disability 623210 Intellectual disability intermediate care facilities 623210 Intellectual disability facilities (e.g., homes, hospitals, intermediate care facilities), residential 623210 Intellectual disability homes 623210 Intellectual disability hospitals 622210 Mental (except intellectual disability) hospitals 624120 Self-help organizations for disabled persons, the elderly, and persons diagnosed with intellectual disabilities 624190 Self-help organizations (except for disabled persons, the elderly, persons diagnosed with intellectual disabilities)

12-0045 Sector 62 Health Care and Social Assistance. Keyword — Prosthetic and Orthopedic Appliance Delivery

Docket Number 12-0045
Sector 62 Health Care and Social Assistance — Prosthetic and Orthopedic Appliance Delivery

Docket 12-0045 requested a new industry for prosthetic and orthopedic appliance delivery services. It is clear that demand for this type of health care service is growing and that establishments providing these services are doing far more than simply supplying prosthetics. NAICS currently classifies the manufacture of these appliances in 339113, Surgical Appliance and Supplies Manufacturing. NAICS classifies establishments primarily engaged in selling these appliances with no associated health care services in 446199, All Other Health and Personal Care Stores. NAICS classifies practices of medical doctors providing prosthetic and orthopedic health care services in NAICS 621111, Offices of Physicians (except Mental Health Specialists). NAICS currently classifies practices of certified practitioners other than physicians in 621399, Offices of All Other Miscellaneous Health Practitioners.

Because the manufacture, sale, and medical services associated with prosthetic and orthopedic appliance delivery are classified in a variety of industries based on the production functions of different establishments, the ECPC does not recommend creating a new industry in Sector 62. The ECPC does recommend adding new index items to NAICS 621399, Offices of All Other Miscellaneous Health Practitioners for Orthotists offices (e.g., centers, clinics) and Prosthetists offices (e.g., centers, clinics) to clearly indicate where the offices of these specialized practitioners are classified in NAICS.

12-0046 Various — Various Proposals from Bureau of Labor Statistics, PPI

Docket Number 12-0046
Various — Various Proposals from Bureau of Labor Statistics, PPI

The Producer Price Index program from the Bureau of Labor and Statistics submitted numerous change requests to NAICS in the non-manufacturing sectors of NAICS. Each of the recommendations were evaluated and considered by the ECPC when developing recommendations. The following is a summary of the requests and the ECPC recommendations:

a) The ECPC does not recommend creating a separate sub-sector for manufacturer's sales branches and offices (MSBOs). Another option is to move manufacturer's sales offices to agents and brokers (425) and leave manufacturer's sales branches in merchant wholesale (423, 424). While there is a conceptual basis to make the change, there are problems. MSBOs are somewhat different than either merchants or agents and brokers. The manufacturer's sales branches can often provide inventory data but not necessarily cost of goods sold. The manufacturer's sales offices are not able to report commissions.
b) The ECPC recommends combining NAICS 443112, Radio, Television, and Other Electronics Stores; 443120, Computer and Software Stores; 443130, Camera and Photographic Supplies Stores; and 451220, Prerecorded Tape, Compact Disc, and Record Stores.
c) Due to the different production functions that are currently identified in radio networks and radio stations, the ECPC does not recommend combining industries 515111, Radio Networks and 515112, Radio Stations for 2012.
d) Due to the nature of the terminology and the intent of the industry, the ECPC does not recommend changing the title of 518210 to include the term business process management. This term is too broad to accurately describe the intent of the industry.
e) The ECPC does not recommend collapsing NAICS 541211, Offices of Certified Public Accountants and NAICS 541219, Other Accounting Services. The major difference between Offices of CPAs and Other Accounting Services in NAICS is not just the certification of CPAs but rather the fact that Offices of CPAs can perform audits while other accounting services cannot.
f) Agents are included in the content of 532, rental and leasing services. The ECPC recommends providing specific language in the 2012 NAICS manual for clarification.
g) The ECPC recommends that no changes are needed to clarify the establishments that are acting as agents or brokers in the sale of insurance and annuities. Re-insurance is still an insurance product and agents or brokers primarily engaged in selling insurance are included in 524210
h) The ECPC does not recommend adding an index item for risk management. Risk management services are undefined in the proposal. It is unclear what, if anything, could be added to the NAICS manual list of index items for risk management, particularly for only one industry.
i) The ECPC does not recommend deleting NAICS 541850, Display Advertising. Instead, the ECPC recommends changing the title of this industry back to Outdoor Advertising, since that title more accurately describes the intended content of this industry, and the term Display Advertising is increasingly being used to describe Internet advertising, which is not the intended coverage of this industry.
j) The ECPC does not recommend creating a separate industry for design build. This issue was reviewed in 1997, 2002, and 2007. While some practices have changed, particularly growth in the design/build/operate area, classification practices should remain unchanged.
k) The ECPC does not recommend combining NAICS 561311, Employment Placement Agencies and NAICS 561320, Temporary Help Services. The production processes of these industries are very different.

12-0047 Various — Ecosystem Health Care and Assistance

Docket Number 12-0047
Various — Ecosystem Health Care and Assistance

The ECPC does not recommend creating "Ecosystem Health Care and Assistance" as a new 2-digit NAICS sector for 2012 NAICS. This proposal requests that a wide range of activities with different production functions be brought together into a single sector in NAICS. This is an end-use or demand-based proposal rather than the identification of unique production functions. The emphasis of this proposed sector is outcome-based (i.e. a healthy ecosystem), with little focus on production processes. If this new sector were added to NAICS, it would have to be defined to include activities from all existing sectors in NAICS including activities such as organic farming, sustainable forest practices, LEED building construction, etc.

An argument can be made that the Ecosystem activities as a sector are just as valid a concept as health care or administrative and support services. In order to implement the concept of an Ecosystem sector, industries from throughout NAICS would need to be brought together. This would result in modifications to the existing sectors that would not be intuitive or necessarily analytically useful. For example, the existing Construction Sector would include all construction except that which is environmentally friendly or low impact on the environment. The same would apply to manufacturing, trade, professional services, and other areas. The ECPC does recognize the political and social implications of creating an Ecosystem sector. However, the resulting disruption would result in less useful data overall for other analytical purposes.

The author of the proposal should be encouraged to generate an alternative aggregation of existing industries that can be used for analytical purposes.

12-0048 Various — Ecosystem Health Care and Assistance

Docket Number 12-0048
Various — Ecosystem Health Care and Assistance

Docket 12-0048 requested creating a new 2-digit NAICS sector (top tier) for Ecosystem Health Care and Assistance.

The ECPC does not recommend creating "Ecosystem Health Care and Assistance" as a new 2-digit NAICS sector for 2012 NAICS. This proposal requests that a wide range of activities with different production functions be brought together into a single sector in NAICS. This is an end-use or demand-based proposal rather than the identification of unique production functions. The emphasis of this proposed sector is outcome-based (i.e. a healthy ecosystem), with little focus on production processes. If this new sector were added to NAICS, it would have to be defined to include activities from all existing sectors in NAICS including activities such as organic farming, sustainable forest practices, LEED building construction, etc.

An argument can be made that the Ecosystem activities as a sector are just as valid a concept as health care or administrative and support services. In order to implement the concept of an Ecosystem sector, industries from throughout NAICS would need to be brought together. This would result in modifications to the existing sectors that would not be intuitive or necessarily analytically useful. For example, the existing Construction Sector would include all construction except that which is environmentally friendly or low impact on the environment. The same would apply to manufacturing, trade, professional services, and other areas. The ECPC does recognize the political and social implications of creating an Ecosystem sector. However, the resulting disruption would result in less useful data overall for other analytical purposes.

The author of the proposal should be encouraged to generate an alternative aggregation of existing industries that can be used for analytical purposes.

12-0049 Various — Ecosystem Health Care and Assistance

Docket Number 12-0049
Various — Ecosystem Health Care and Assistance

The ECPC does not recommend creating "Ecosystem Health Care and Assistance" as a new 2-digit NAICS sector for 2012 NAICS. This proposal requests that a wide range of activities with different production functions be brought together into a single sector in NAICS. This is an end-use or demand-based proposal rather than the identification of unique production functions. The emphasis of this proposed sector is outcome-based (i.e. a healthy ecosystem), with little focus on production processes. If this new sector were added to NAICS, it would have to be defined to include activities from all existing sectors in NAICS including activities such as organic farming, sustainable forest practices, LEED building construction, etc.

An argument can be made that the Ecosystem activities as a sector are just as valid a concept as health care or administrative and support services. In order to implement the concept of an Ecosystem sector, industries from throughout NAICS would need to be brought together. This would result in modifications to the existing sectors that would not be intuitive or necessarily analytically useful. For example, the existing Construction Sector would include all construction except that which is environmentally friendly or low impact on the environment. The same would apply to manufacturing, trade, professional services, and other areas. The ECPC does recognize the political and social implications of creating an Ecosystem sector. However, the resulting disruption would result in less useful data overall for other analytical purposes.

The author of the proposal should be encouraged to generate an alternative aggregation of existing industries that can be used for analytical purposes.

12-0050 Various — Ecosystem Health Care and Assistance

Docket Number 12-0050
Various — Ecosystem Health Care and Assistance

Docket 12-0050 requested creating a new 2-digit NAICS sector (top tier) for Ecosystem Health Care and Assistance.

The ECPC does not recommend creating "Ecosystem Health Care and Assistance" as a new 2-digit NAICS sector for 2012 NAICS. This proposal requests that a wide range of activities with different production functions be brought together into a single sector in NAICS. This is an end-use or demand-based proposal rather than the identification of unique production functions. The emphasis of this proposed sector is outcome-based (i.e. a healthy ecosystem), with little focus on production processes. If this new sector were added to NAICS, it would have to be defined to include activities from all existing sectors in NAICS including activities such as organic farming, sustainable forest practices, LEED building construction, etc.

An argument can be made that the Ecosystem activities as a sector are just as valid a concept as health care or administrative and support services. In order to implement the concept of an Ecosystem sector, industries from throughout NAICS would need to be brought together. This would result in modifications to the existing sectors that would not be intuitive or necessarily analytically useful. For example, the existing Construction Sector would include all construction except that which is environmentally friendly or low impact on the environment. The same would apply to manufacturing, trade, professional services, and other areas. The ECPC does recognize the political and social implications of creating an Ecosystem sector. However, the resulting disruption would result in less useful data overall for other analytical purposes.

The author of the proposal should be encouraged to generate an alternative aggregation of existing industries that can be used for analytical purposes.

12-0051 Various — Ecosystem Health Care and Assistance

Docket Number 12-0051
Various — Ecosystem Health Care and Assistance

Docket 12-0051 requested creating a new 2-digit NAICS sector (top tier) for Ecosystem Health Care and Assistance.

The ECPC does not recommend creating "Ecosystem Health Care and Assistance" as a new 2-digit NAICS sector for 2012 NAICS. This proposal requests that a wide range of activities with different production functions be brought together into a single sector in NAICS. This is an end-use or demand-based proposal rather than the identification of unique production functions. The emphasis of this proposed sector is outcome-based (i.e. a healthy ecosystem), with little focus on production processes. If this new sector were added to NAICS, it would have to be defined to include activities from all existing sectors in NAICS including activities such as organic farming, sustainable forest practices, LEED building construction, etc.

An argument can be made that the Ecosystem activities as a sector are just as valid a concept as health care or administrative and support services. In order to implement the concept of an Ecosystem sector, industries from throughout NAICS would need to be brought together. This would result in modifications to the existing sectors that would not be intuitive or necessarily analytically useful. For example, the existing Construction Sector would include all construction except that which is environmentally friendly or low impact on the environment. The same would apply to manufacturing, trade, professional services, and other areas. The ECPC does recognize the political and social implications of creating an Ecosystem sector. However, the resulting disruption would result in less useful data overall for other analytical purposes.

The author of the proposal should be encouraged to generate an alternative aggregation of existing industries that can be used for analytical purposes.

12-0052 Sector 54 Professional, Scientific, & Technical Services. Keyword — Engineering Size Standards

Docket Number 12-0052
Sector 54 Professional, Scientific, and Technical Services — Engineering Size Standards

Docket 12-0052 requested that the small business size standard for NAICS 541330, Engineering Services, be raised. The author stated that otherwise, mid-sized engineering firms are effectively left on the sidelines, since they do not have the resources to compete with the larger engineering firms.

The ECPC notes that this request is not a NAICS revision issue, and that the issue of size standards is not within its purview. The ECPC recommends that the author address his concern to the Small Business Administration.

12-0053 Sector 31-33 Manufacturing. Keyword — Outsourcing

Docket Number 12-0053
Sector 31-33 Manufacturing — Outsourcing

The ECPC recommendation on outsourcing is included in a separate summary.

12-0054 Various — Green Industries

Docket Number 12-0054
Various — Green Industries

Docket 12-0054 requested new green industry additions to the 2012 NAICS including: NAICS 238231, Residential Solar Installation Contractors, NAICS 238232, Nonresidential Solar Installation Contractors, NAICS 325194, Biological Fuels Manufacturing, NAICS 447120, Alternative Fuel Stations, and NAICS 811320 Wind Turbine Repair and Maintenance.

The ECPC recommends that the Census of Construction consider adding details in 2012 to separately identify solar system installation as product inquiries to the existing industries in the 2012 economic census and re-evaluate the situation in a future revision of NAICS.

The ECPC studied the biofuels proposal and does not recommend a new industry in NAICS 2012. The proposal requested a variety of production functions and processes be combined into an end use or demand based industry for biofuels. Programs collecting product information may wish to consider adding additional product inquiries to gauge the growth of biofuels in the appropriate industries in NAICS.

The ECPC does not recommend a new NAICS industry for alternative fueling stations. While the number of stations that supply alternative fuels is quite numerous, there is evidence that many also sell traditional motor fuels.

The ECPC does not recommend a new industry for wind turbine repair and maintenance. While there is evidence of growth in the use and construction of such structures, information about the specialization of units that repair and maintain wind turbines is not available. The ECPC recommends that the Census of Construction consider adding inquiries to the 2012 economic census similar to those for solar system installation and re-evaluate the proposal in a future revision of NAICS.

12-0055 Sector 31-33 Manufacturing. Keyword — Manufacturing Detail Reduction

Docket Number 12-0055
Sector 31-33 Manufacturing — Manufacturing Detail Reduction

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0056 Sector 31-33 Manufacturing. Keyword — Technical Ceramics

Docket Number 12-0056
Sector 31-33 Manufacturing — Technical Ceramics

Docket 12-0056 requested the creation of a NAICS code for Technical/Advanced Ceramics because technical and advance ceramics are different from tile or white ware. The respondent provided information that technical ceramics producers are specialized and represent a multi-billion dollar industry.

The ECPC considered this request coincidently with a review of the existing industries in subsector 3271, Pottery, Ceramics and Plumbing Fixture Manufacturing. In 2007, the industry group included eight (8) national level six-digit industries. An evaluation of the existing national details resulted in the recommendation to reduce the number of national industries down to two (2). Based on that recommendation the ECPC does not recommend the creation of a NAICS code for advanced/ technical ceramic product manufacturing. There is merit to this proposal to the extent that there are establishments primarily engaged in manufacturing of advanced or technical ceramic products that are separable from other producers of ceramic articles. The ECPC recommends addition of a new index item for advanced/technical ceramic product manufacturing in proposed NAICS United States 2012 industry 327110, Pottery, Ceramics, and Plumbing Fixture Manufacturing. This industry includes the entire content of the porcelain electrical supply industry from NAICS 2007. The ECPC also recommends clarifying the definition for industries 32799 and 327999, and adding cross- references for technical ceramic products out of industries 32799 and 327999.

12-0057 Sector 31-33 Manufacturing. Keyword — Manufacturing Detail Reduction

Docket Number 12-0057
Sector 31-33 Manufacturing — Manufacturing Detail Reduction

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0058 Sector 31-33 Manufacturing. Keyword — Manufacturing Detail Reduction

Docket Number 12-0058
Sector 31-33 Manufacturing — Manufacturing Detail Reduction

The ECPC recommendation on reduction of manufacturing detail is included in a separate summary.

12-0059 Sector 23 Construction. Keyword — Construction Management

Docket Number 12-0059
Sector 23 Construction — Construction Management

Docket 12-0059 requested that construction management be delineated as agency and at risk in two distinct industry codes. Currently a wide range of project delivery methods are combined in the NAICS construction industries in Subsectors 236, Construction of Buildings and 237, Heavy and Civil Engineering Construction.

Prior revisions of NAICS have focused on proposals to separate out different project delivery methods within the industry structure of NAICS. In particular, requests to create separate design/build categories have been evaluated and not recommended by the ECPC. The ECPC remains opposed to using project delivery methods to define industries in the Construction sector of NAICS. The concept of using project delivery methods was exhaustively reviewed with Canada and Mexico during the 2002 and 2007 revisions of NAICS. The ECPC notes that separate construction data were collected for at-risk and agency construction management in the 2007 Census of Construction and recommends that the respondents work with statistical data collection programs in order to ensure continued collection of variables delineating project delivery methods in future work.

12-0060 Sector 54 Professional, Scientific, & Technical Services. Keyword — Manufacturing Detail Reduction

Docket Number 12-0060
Sector 54 Professional, Scientific, and Technical Services — Manufacturing Detail Reduction

Docket 12-0060 requested the addition of a new NAICS industry entitled Cultural Resource Consulting Services, and suggested that this industry be given code 541621, as a subordinate to the existing 541620, Environmental Consulting Services. The proposed industry is also referred to as the historic preservation industry with services distinct from the natural resource and remediation services that dominate the 541620 industry in NAICS. The proposed industry would include professional consulting services conducted to comply with federal, state, and local laws and regulations regarding cultural resources. The services included in this industry involve the applied practice of several disciplines: archaeology (prehistoric and historical), architectural history, architecture, history, conservation, cultural anthropology, curation, folklore, historic preservation, land use/community planning, landscape architecture, and traditional cultural property expertise.

The ECPC considered the proposal and noted that cultural resource management, or cultural resource consulting services is a product provided by establishments in a variety of industries. Though there may be some establishments primarily engaged in providing these services, the number of establishments and total revenue of those establishments do not appear to be large enough to justify creation of a new industry. The proposal estimate of $683 million to $1 billion for these services from all providers (including establishments primarily engaged in other activities) supports the ECPC conclusion. Therefore, the ECPC does not recommend a new separate industry for cultural resource consulting. The ECPC does recommend adding an index item to 541720, Research and Development in the Social Sciences and Humanities to clarify classification of units that are primarily engaged in providing historic and cultural preservation services.

12-0061 Various — Public Health Workers Consulting

Docket Number 12-0061
Various — Public Health Workers Consulting

Docket 12-0061 requested a new NAICS industry for public health. The current classification system includes an index item for "Public health program administrator (non operating)" in Industry 923120, Administration of Public Health Programs.

The ECPC does not recommend the creation of a NAICS code for the public health. Public health is a demand-based grouping that would encompass establishments from a variety of existing NAICS industries engaged in achieving common public health goals. Public health is not a separable production function.

The ECPC recommends that the respondent work with various employment statistics programs to use existing data to determine public health workforce information.

12-0062 Sector 31 Manufacturing. Keyword — Cryogenic Treatment of Metal

Docket Number 12-0062
Sector 31-33 Manufacturing — Cryogenic Treatment of Metal

Docket 12-0062 requested a new industry for establishments primarily engaged in cryogenic treatment of metal. The ECPC considered the activity and agreed that all temperature treating of metal should be classified to NAICS 332811, Metal Heat Treating. The ECPC discussed but does not recommend a change to the industry title to include all temperature treatment of metals because terminology such as temperature treating was not used within the industry. The ECPC does recommend new index items in 332811 as follows:

332811 Cold treating metals for the trade
332811 Cryogenic treating metals for the trade

12-0063 Sector 42 Wholesale Trade. Keyword — Wholesale /Retail of Classic Cars

Docket Number 12-0063
Sector 42 Wholesale Trade — Wholesale /Retail of Classic Cars

Docket 12-0063 requested new industries for Antique and Classic Cars Specialty Retail and Antique and Classic Car Wholesalers. This latter category would include obtaining restoration services to bring the car up to the standards required by the client.

The ECPC acknowledges that there are establishments that are primarily engaged in or even exclusively engaged in selling antique and classic cars. However, the size of this niche market does not justify creation of new industries in NAICS. The ECPC does not recommend new industries in wholesale trade or retail trade for classic car dealers. Classic car specialists are currently classified in NAICS as follows:

NAICS 423110, Merchant wholesale of new or used cars
NAICS 425120, New and used car agents and brokers
NAICS 441120, Used car dealers
NAICS 454111, Internet only car dealers
NAICS 454112, Internet only auctions for used cars

12-0064 Sector 54 Professional, Scientific, & Technical Services. Keyword — Nanotechnology Research and Development Services

Docket Number 12-0064
Sector 54 Professional, Scientific, and Technical Services — Nanotechnology Research and Development Services

Docket 12-0064 requested the creation of a new industry for nanotechnology research and development within NAICS industry group 5417, Scientific Research and Development Services.

There are three specific components of the nanotechnology definition that establishments engaged in nanotechnology R&D must follow to achieve industry recognition. First, establishments must work with or manipulate materials that are 100 nanometers or less. Second, establishments must be able to understand and control the material they are working with. Third, new properties must emerge from the manipulation of these materials that expand the knowledge in the broader area of nanotechnology.

Many establishments conducting research in nanotechnology are also involved in researching other scientific areas. Due to the lack of agreement on a universal definition of nanotechnology, it is not uncommon for establishments to avoid the label of nanotechnology R&D. Also, it is often the case that establishments may be working with nanomaterials, but may not necessarily be fully engaged in all the aspects of the nanotechnology R&D industry. Going back to the three components that make up the nanotechnology definition, this would imply these particular establishments should not be classified as nanotechnology R&D. The point was made that conducting research while adhering to those three components are what set nanotechnology R&D apart from other R&D services. Just because an establishment is engaged in one component of the nanotechnology definition, it is not a requirement that they be engaged in the other two. For example, nanomaterials appear in objects that are researched in all kinds of laboratories, but if it is not the focus of the laboratory to manipulate these materials in attempts to find new properties then this laboratory would fall outside the nanotechnology R&D industry. It is extremely difficult to strictly define which establishments should be classified in this industry.

There is also a growing presence of nanobiotechnology that combines aspects of nanotechnology and biotechnology.

The ECPC does not recommend a new industry for nanotechnology research and development because of the potential problems with mutual exclusivity with existing industries in NAICS.

12-0065 General — Information on High Tech Industries and Outsourcing and Development

Docket Number 12-0065
General — Information on High Tech Industries and Outsourcing and Development

The ECPC would like to thank the commenter for the information regarding new and emerging high tech industries, and manufacturing outsourcing within the high tech industries.


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Source: U.S. Census Bureau | North American Industry Classification System (NAICS) | (888) 756-2427 | naics@census.gov | Last Revised: September 13, 2013