ANSI BSR Upholds Appeal of AFDE Member Andrew Sulner, MSFS, JD, finding the AAFS Academy Standards Board (ASB) Violated ANSI Essential Requirements
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The ANSI Appeals panel decision illustrates the critical importance of standard development organizations (SDOs) actively ensuring that their consensus bodies are properly balanced between competing materially interested stakeholders.
NEW YORK - Txylo -- ANSI BSR Upholds Appeal of AFDE Member Andrew Sulner, MSFS, JD, finding that the AAFS Academy Standards Board (ASB) Violated ANSI Essential Requirements for Due Process
NEW YORK, N.Y., August 24, 2026 — The Association of Forensic Document Examiners (AFDE) is pleased to announce the recent success of one of its members, Andrew Sulner, MSFS, J.D. (Forensic Document Examinations, LLC) in his appeal of the ANSI BSR's approval of ASB 155 Standard for Minimum Training Requirements for Forensic Document Examiners as an American National Standard (ANS).
Minimum Training Requirements for Forensic Document Examiners were first published in 2005 by ASTM. When the forensic document examination committee of ASTM was disbanded in 2012 that standard transferred to the FBI-funded SWGDOC, which adopted the ASTM training standard verbatim in 2013. Those standards set the duration for training at 4000 hours (two years of full time training) and allowed an equivalent part-time training program of up to four years in duration. This was important because in the private sector, the trainer and trainee are typically already working and can not devote full-time efforts to a training program. In governmental agencies (FBI, IRS, State Crime Labs, etc.), trainers and trainees are paid employees.
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What caught Mr. Sulner's attention and caused him great concern with the proposed ASB Standard 155 is that it would have made it substantially impossible for new FDEs to emerge out of the private sector. The ASB 155 standard states, "A trainee may or may not be a salaried employee and is expected to work almost daily with the instructor in their laboratory or office." The concept of equivalent part-time training is not mentioned, and the only allowance to deviate from the defined duration is for "exigent circumstances," and even then, the extension can be no longer than one year. (emphasis added)
The ANSI BSR found for the Appellant, Mr. Sulner, on the issue of dominance, finding that the American Academy of Forensic Sciences (AAFS) had failed to investigate a written claim of dominance made to it, which it was obligated to do. The ANSI BSR specifically noted that "AAFS's evidentiary submission in support of ASB 155's approval did not establish that [Mr. Sulner's] written claim of dominance was ever investigated or considered, as required" by Sections 1.0, 1.2, and 2.2 of the ANSI Essential Requirements for Due Process.
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The Association of Forensic Document Examiners considers the outcome of Mr. Sulner's appeal a successful one for its members, as well as the broader FDE community and the public. We look forward to working on a training standard that is both procedurally and substantively fair to all industry stakeholders.
Mr. Sulner's July 21, 2026 appeal letter, the ASB response, and the August 21, 2026 decision of the ANSI BSR Appeals Panel are available at https://afde.org.
NEW YORK, N.Y., August 24, 2026 — The Association of Forensic Document Examiners (AFDE) is pleased to announce the recent success of one of its members, Andrew Sulner, MSFS, J.D. (Forensic Document Examinations, LLC) in his appeal of the ANSI BSR's approval of ASB 155 Standard for Minimum Training Requirements for Forensic Document Examiners as an American National Standard (ANS).
Minimum Training Requirements for Forensic Document Examiners were first published in 2005 by ASTM. When the forensic document examination committee of ASTM was disbanded in 2012 that standard transferred to the FBI-funded SWGDOC, which adopted the ASTM training standard verbatim in 2013. Those standards set the duration for training at 4000 hours (two years of full time training) and allowed an equivalent part-time training program of up to four years in duration. This was important because in the private sector, the trainer and trainee are typically already working and can not devote full-time efforts to a training program. In governmental agencies (FBI, IRS, State Crime Labs, etc.), trainers and trainees are paid employees.
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What caught Mr. Sulner's attention and caused him great concern with the proposed ASB Standard 155 is that it would have made it substantially impossible for new FDEs to emerge out of the private sector. The ASB 155 standard states, "A trainee may or may not be a salaried employee and is expected to work almost daily with the instructor in their laboratory or office." The concept of equivalent part-time training is not mentioned, and the only allowance to deviate from the defined duration is for "exigent circumstances," and even then, the extension can be no longer than one year. (emphasis added)
The ANSI BSR found for the Appellant, Mr. Sulner, on the issue of dominance, finding that the American Academy of Forensic Sciences (AAFS) had failed to investigate a written claim of dominance made to it, which it was obligated to do. The ANSI BSR specifically noted that "AAFS's evidentiary submission in support of ASB 155's approval did not establish that [Mr. Sulner's] written claim of dominance was ever investigated or considered, as required" by Sections 1.0, 1.2, and 2.2 of the ANSI Essential Requirements for Due Process.
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The Association of Forensic Document Examiners considers the outcome of Mr. Sulner's appeal a successful one for its members, as well as the broader FDE community and the public. We look forward to working on a training standard that is both procedurally and substantively fair to all industry stakeholders.
Mr. Sulner's July 21, 2026 appeal letter, the ASB response, and the August 21, 2026 decision of the ANSI BSR Appeals Panel are available at https://afde.org.
Source: Association of Forensic Document Examiners
Filed Under: Business, Government
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