Introduction
Have you ever wondered what you have to do/must do/can do when you come across a “shall” statement or a “should” statement in an industry regulation, an industry FEMI standard, or even in your own internal company standards? If so, read on. This Reynolds Wrap Up is all about 50+ years of my experience with writing and interpreting “shall” vs. “should” statements in FEMI codes, standards, and regulations, as well as providing expert testimony for the legal defense of industry clients and then deciding what needs to be done. There are plenty of modal action verbs used in standards/contracts/regulations, but I will address primarily the ones labeled on the doors shown in Figure 1 that we typically deal with in order to understand all our requirements and options. Modal verbs typically show necessity, options, intent, possibility, or ability.

Modal Verbs Used in API and Other FEMI Standards
Let’s start with how the API uses the terms shall, should, may, and can in their published industry FEMI standards. The written forms (and I’m quoting here) used to express these provisions in API Standards are as follows:
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