Our notes may have crossed, but my interpretation from my other is: There are two requirements generally, given in simple form in section 1.2 (with certain exceptions): *The average of the sample must equal or exceed the declared contents. *No individual shortfall (from declared) may exceed MAV. The MAVs come from lookup tables based on mass, volume, etc. Frankly, the requirements for uniformity don't seem very stringent.
--- On Sun, 3/27/11, Kilopascal <[email protected]> wrote: From: Kilopascal <[email protected]> Subject: Re: [USMA:50212] Re: Williams Changes Their Label -- I had an impact To: [email protected], [email protected], "U.S. Metric Association" <[email protected]> Date: Sunday, March 27, 2011, 4:41 PM I didn't think there was a problem with the contents being too much. It didn't make sense for it to be. Simply if you want give your product away why would anyone be opposed? On the other hand I can see where there would be a problem if you gave less than what you claimed, as that would be cheating. So without getting too detailed, what is your interpretation of the law? From: John M. Steele Sent: Sunday, 2011-03-27 16:15 To: [email protected] ; U.S. Metric Association ; Kilopascal Subject: Re: [USMA:50212] Re: Williams Changes Their Label -- I had an impact The MAVs are in one of the appendices. They only apply to measured shortfalls. No one cares if you're over net contents. --- On Sun, 3/27/11, Kilopascal <[email protected]> wrote: From: Kilopascal <[email protected]> Subject: [USMA:50212] Re: Williams Changes Their Label -- I had an impact To: [email protected], "U.S. Metric Association" <[email protected]> Date: Sunday, March 27, 2011, 4:10 PM Nothing in your post states what the MAV actually is. As far as I understand it, it is the maximum amount that an actual measurement can vary from the declared value but no actual reference is given. Item #4 states that the inspector evaluates what he measures to the "requirement". It may be that the deviation may be plus/minus a certain percentage from the declaration in which an amount less than the declared value is acceptable, but it may also be that the negative (less than) variation may be zero from the declared value and only a positive variation is acceptable. We don't know. In item #3 it does say the MAV is to be found in some table. So, I can't say from what you posted that your point is proved. I'm sure someone else may be able to determine if you are interpreting the regulation correctly or if the MAV is plus/minus or plus only. If you are in fact correct then this seems like the system used in the EU where products that have an average amount based on the contents declaration and fall within acceptable variants are marked with the "e" symbol. [USMA:50212] Re: Williams Changes Their Label -- I had an impact mechtly Sun, 27 Mar 2011 12:45:05 -0700 The testing of packages for compliance with legal marketing requirements is based on the idea of "Maximum Ållowable Variation (MAV) as follows: 1. An Inspector selects random samples from a lot (a shipment) of the product. 2. The amount in each package from the samples is measured and tabulated. 3. The Inspector determines the MAV from a Random Number Table. 4. The Inspector evaluates compliance with the MAV requirement. 5. The Inspector reports deviations from the MAV for enforcement actions. Documentation is in NIST Handbook 133, Chapter 2. "Basic Test Procedure" (also a free download). Numerical examples of Sample Size, Measured Values (some over and some under the "declared value"), and MAV are in the Appendix of Handbook 133. Is this the explanation you want? EAM ---- Original message ---- >Date: Sun, 27 Mar 2011 14:31:33 -0400 >From: "Kilopascal" <[email protected]> >Subject: [USMA:50210] Re: Williams Changes Their Label -- I had an impact >To: <[email protected]>, "U.S. Metric Association" <[email protected]> > > Seeing that the document is 298 pages in the PDF > format, can you direct me to the page where it > states that the contents of a package may be less > than what is declared? > > > http://ts.nist.gov/WeightsAndMeasures/Publications/upload/HB130-2009-PDF-FullDoc.pdf > > I'm not sure what you refer to as "some" and what > their exceptions may be. >[USMA:50210] Re: Williams Changes Their Label -- I had an > impact > > mechtly > Sun, 27 Mar 2011 10:57:47 -0700 > > "Kilopascal" <[email protected]> claimed: > ... > > in the US, the > > declarations represent minimum quantities. > > Everything is going to be a few grams or more over > > stated value. > > Not True! Some packages may be *under* the amount stated on the label.. > See NIST Handbook 130 (a free download). No virus found in this message. Checked by AVG - www.avg.com Version: 10.0.1204 / Virus Database: 1498/3533 - Release Date: 03/27/11
