On Jun 25, 2014, at 12:48 PM, Crown, Linda D. <[email protected]> wrote:
> Dear Mr. Mechtly, > > Thank you for your query and the answers to your questions follow. > > In response to your question in 1: > > Be advised that NIST does not have any regulatory authority. Regulatory > responsibility for packaging and labeling is the responsibility of the > States, the Food and Drug Administration (FDA), Federal Trade Commission > (FTC), the U.S. Department of Agriculture and other federal agencies. When > the SI revisions to the Fair Packaging and Labeling Act (FPLA) were > incorporated into regulations in the early 1990s, the suggestion of requiring > that SI units be displayed first (i.e., primary position) in a quantity > declaration was considered. The proposal was not adopted for several reasons > including (1) the FPLA itself did not specify which units had to be in the > primary position in the quantity declaration, and (2) at the time many > packagers provided both customary and SI units on packages with the SI in the > secondary position and there was no justifiable reason to render those > packages unacceptable under FPLA. > > In response to your question in 2: > > The Uniform Packaging and Labeling Regulations adopted by the National > Conference on Weights and Measures in 1993 and which is enforced by State and > Local Weights and Measures Officials was developed to specifically promote > the use of the SI. The method of displaying the quantity of contents you > mentioned is already permitted under Section 6.3.1 "Use of Net Mass or Net > Weight" which is shown below. > > 6.3.1. Use of "Net Mass" or "Net Weight." - A quantity declaration may stand > alone [e.g., "200 g (7 oz)" or "1 lb (453 g)"] or may include the term "net > mass" or "net weight" either preceding or following the declaration. The > term "net" by itself may be used on food labels. However, the quantity of > contents shall always declare the net quantity of contents even when such > terms are not used. > (Amended 1993) > > Have a wonderful day. > > Linda > > Linda Crown > Weights and Measures Coordinator > Publications > National Institute of Standards and Technology > 100 Bureau Drive, M/S 2600 > Bldg. 222, Room B250 > Gaithersburg, MD 20899-2600 > E-mail: [email protected] > Phone: (301) 975-3998 > Fax: (301) 975-8091 > URL: http://www.nist.gov/pml/wmd/ > > > -----Original Message----- > From: mechtly, eugene a [mailto:[email protected]] > Sent: Monday, June 23, 2014 12:54 PM > To: Crown, Linda D.; Butcher, Kenneth S. > Cc: Warfield, Lisa; Hockert, Carol; U.S. Metric Accociation > Subject: Legal Metrology Connection, Volume 5 Issue 5 > > I completed a reading of *Legal Metrology Connection* 5-5, (aka W&M > Connection).and ask the following questions: > > 1. In view of the *fact*, that three federal laws declare that units of > measurement from the International System of Units (SI) are preferred for > trade and commerce in the Unites State, > > NIST has ample authority to *require* that declarations of net amounts inside > packages and containers be expressed In *first place* in Units from the SI, > and only in second place in units from outside the SI, as required by the > current FPLA, even though the NCWM has not yet arrived at this > forward-looking requirement. > > 2. Why does NIST not promote, if not require, declarations of amount simply > by a number and the SI Unit, with "NET" or "NET CONTENTS" or "NET AMOUNT" as > *optional* modifiers? > > Eugene Mechtly > > ________________________________________ > From: Linda Crown [[email protected]] > Sent: Friday, June 20, 2014 12:11 AM > To: mechtly, eugene a > Subject: Weights and Measures Connection, Volume 5 Issue 5 > > Dear Readers, > > In this edition of the "Weights and Measures Connection," we introduce a new > member of the Office of Weights and Measures team, Mr. Clark Cooney. Some of > you may already know Clark; however, we have provided a brief introduction > for those who do not. There is also guidance on the use of "Principal > Display Panels on Random Packages" and an update on an educational outreach > effort conducted at a nearby middle school. > > Please remember to check out the updated "Calendar" to see what OWM is > offering in the training area as well as scheduled meetings. > > Online access is available to the newsletter at > http://www.nist.gov/pml/wmd/pubs/upload/WMConnections.pdf, and for your > convenience an Acrobat (.pdf) copy is attached. > > As always, we would be happy to get your feedback and ideas for future > articles. > > Happy reading, > > Linda > Editor, "Weights and Measures Connection" > [email protected] > (301) 975-3998
