If I owned a company not sure I would violate the law just because someone says 
they “wont enforce’ it but some might.  It think the impact will be small but 
it’s a start.

Howard Ressel
Project Design Engineer
NYSDOT
1530 Jefferson Road
Rochester, NY 14623
585 272-3372


43,560 square feet in an acre
5280 feet in a mile
16 ounces in a pound
128 ounces in a gallon

23 confused kids in a class

What could be simpler?


From: owner-u...@colostate.edu [mailto:owner-u...@colostate.edu] On Behalf Of 
ezra.steinb...@comcast.net
Sent: Thursday, September 18, 2014 1:06 PM
To: U.S. Metric Association
Cc: USMA
Subject: [USMA:54379] Re: NIST Training Course for Checking the Net Amouts 
inside Packages

As always, your clarifications really help, Gene.   :-)

The bottom line for me is whether companies will interpret this new enforcement 
policy as an unofficial permission slip to label their packages using only SI 
units so long as they ensure that the amount indicated is equal to (modulo 
allowed precision and variation) or less than the amount actually in the 
package.

How do you and other folks on the list interpret the practical impact of this 
proposed new enforcement policy?

Ezra

________________________________
From: "eugene a mechtly" <mech...@illinois.edu<mailto:mech...@illinois.edu>>
To: "Ezra, Steinberg" 
<ezra.steinb...@comcast.net<mailto:ezra.steinb...@comcast.net>>
Cc: "USMA" <usma@colostate.edu<mailto:usma@colostate.edu>>
Sent: Thursday, September 18, 2014 8:53:00 AM
Subject: Re: [USMA:54373] NIST Training Course for Checking the Net Amouts 
inside Packages

Ezra,

Thanks for the compliment!

The current FPLA requires “duality” of labeling.

The NIST Handbook 133 (Page 15) requires verification of the “larger of the two 
declarations."

Amendment of the current FPLA is necessary to make metric-only *labeling* a 
legal reality.

However, Metric-Only *Enforcement* of amounts inside packages if already legal 
(in my opinion) so long as the declaration in units from the SI is the *larger* 
of the two declarations.

Machines that fill packages are not precise to six significant digits.  Hence 
the elaborate procedure of Maximum Allowed Variation (MAV) which allows some 
packages to contain less that the targeted amount.  See Page 3 on MAV in NIST 
Handbook 133.

Gene.

On Sep 17, 2014, at 12:44 PM, 
ezra.steinb...@comcast.net<mailto:ezra.steinb...@comcast.net> wrote:

Outstanding work, Gene!   :-)

So, if I understand this correctly, the FTC will let companies know that they 
will be checking only that the net contents as stated using SI units will be 
checked.

In other words, as a matter of their new selective enforcement policy, the FTC 
will not come down on anyone who puts stuff in a package that is labeled only 
in metric units (even though that technically violates the FPLA) provided that 
the stated quantity in SI units is correct.

Does that sum it up correctly?

thanks,
Ezra

________________________________
From: "eugene a mechtly" <mech...@illinois.edu<mailto:mech...@illinois.edu>>
To: "USMA" <usma@colostate.edu<mailto:usma@colostate.edu>>
Cc: "USMA" <usma@colostate.edu<mailto:usma@colostate.edu>>
Sent: Wednesday, September 17, 2014 9:55:00 AM
Subject: [USMA:54373] NIST Training Course for Checking the Net Amouts inside 
Packages

First, I want to thank Ken Butcher for sending me various files in electronic 
format concerning the NIST Training Course for Officials who have the duty of 
verifying the net amounts inside packages intended for consumers in retail 
markets.

My conclusion is that Metric-Only Enforcement of labeling declarations is 
completely compliant with requirements of both the current FPLA, and the 
current UPLR (as defined in the 2014 Editions of NIST Handbooks 130 and 133).

Although "duality" of units of measurement (units from the SI and units from 
outside the SI) continues to be required on the labels of consumer commodities 
by the current FPLA, there is absolutely no exclusion of metric-only 
verification of net amounts inside packages by the current FPLA.  The only 
limitation is that net amounts not be overstated, after rounding to three 
significant digits, by the part of the label stated in units from outside the 
SI.

My hope is that the new revised FTC rules will be consistent with this 
interpretation.

Eugene Mechtly




Reply via email to