Don, I am *not* asking the NCWM to change the *intent* (objective) of any of its statements in NIST Handbooks 44, 130 and 133 for implementing the FPLA and the UPLR!
I am asking only that statement expresed in Units of Measurement from the SI, be separated (isolated) from statements expressed in units of measurement from outside the SI (i.e. in inch-pound unts, or more recently in so called "U.S. Cusromary units", which are not part of the SI). This can be done editorally with *no changes in enforcement consequences* as a requirement for the separation *entirely by editorial action.* This should be done in anticipation of approval of metric-only labeling by either a ruling of the FTC or by amendment of the FPLA to accept metric-only labeling to harmonize with the nearly universal practices in global trade and commerce. Form 15 should not be necessary to implement this separation. I find it difficult to believe that members of the NCWM are satisified with the current entangled and confusing mixture of SI Units with non-SI units as they appear in the current editions of the three NIST Handbook Eugene Mechtly ________________________________________ From: owner-u...@colostate.edu [owner-u...@colostate.edu] on behalf of mechtly, eugene a [mech...@illinois.edu] Sent: Wednesday, July 23, 2014 11:41 AM To: U.S. Metric Association Cc: Crown, Linda D.; Butcher, Kenneth S.; U.S. Metric Accociation; Don Onwiler (don.onwi...@ncwm.net) Subject: [USMA:54190] RE: SI in NIST Handbooks 130 and 133 Don and Carol, What can I do (short of filing Form 15) to persuade the NCWM to *completely separate* provisions in NIST Handbooks 44, 130 and 133, expressed in Units of Measurement from the SI from provisions expressed in units of measurement from outside the SI, to facilitate enforcement of the FPLA in metric-only units of measurement, assuming that the FTC will rule that metric-only declarations of net amounts in packages of consumer commodities are acceptable under the FPLA? Eugene Mechtly ________________________________________ From: Hockert, Carol [carol.hock...@nist.gov] Sent: Friday, July 18, 2014 2:04 PM To: mechtly, eugene a Cc: Crown, Linda D.; Butcher, Kenneth S.; U.S. Metric Accociation; Don Onwiler (don.onwi...@ncwm.net) Subject: RE: SI in NIST Handbooks 130 and 133 Eugene, We do not make structural or organizational changes to the handbooks without vetting the proposed changes with the NCWM board, committees, and users of the handbooks. I suggest you use the formal process if you would like to see these changes. I'm copying the NCWM Executive Director, Don Onwiler, in case you'd like to discuss your other questions with him. (I cannot speak for the NCWM.) Carol -----Original Message----- From: mechtly, eugene a [mailto:mech...@illinois.edu] Sent: Tuesday, July 15, 2014 11:05 PM To: Hockert, Carol Cc: Crown, Linda D.; Butcher, Kenneth S.; U.S. Metric Accociation Subject: Re: SI in NIST Handbooks 130 and 133 Carol, I understand that your personnel are converting all entries of the term "inch-pound" in Handbooks 44, 130, and 133 to the term "U. S. customary" by editorial action. My hope is that, also entirely by editorial action, provisions expressed in SI Units can be *separated* from provisions expressed in units from outside the SI, without amending the verbatim wording of any of those provisions, by the formality of Form 15. Enforcement of all provisions, whether expressed in SI Units or not in SI units, by State, regional, or local officials would not be affected by such an editorial *separation* and the foundation for guiding metric-only labeling would be clarified and established for the future. Since there would be no changes in any of the actual provisions specified in the three Handbooks, only relocations of their statements, I don't see how any voting members of the NCWM could object, unless they are adamant defenders of traditional non-metric practices. Why do only appointed or elected Enforcement Officials have voting rights in the NCWM? I pay my annual membership dues to the NCWM (as purely a consumer) but have no voting rights! Voters in the NCWM exercise all three functions, legislative, executive, and judicial. Should not consumers have stronger legislative input than the officials who both legislate and enforce? Eugene Mechtly. On Jul 15, 2014, at 1:30 PM, Hockert, Carol <carol.hock...@nist.gov> wrote: > Dear Eugene Mechtly, > > The process for making changes to NIST Handbooks 130 and 133 is spelled out > in the introduction section of Handbook 130. It requires the requester to > submit a Form 15 to NCWM. The filled out Form 15 will be circulated to the > regions for consideration. > > Please let me know if I can be of further assistance. > > Best regards, > > Carol Hockert > > -----Original Message----- > From: mechtly, eugene a [mailto:mech...@illinois.edu] > Sent: Monday, July 14, 2014 1:48 PM > To: Hockert, Carol; Crown, Linda D.; Butcher, Kenneth S. > Cc: U.S. Metric Accociation > Subject: SI in NIST Handbooks 130 and 133 > > Dear Professionals in the Field of Legal Metrology, > > As a persistent advocate of SI and as an indirect-partial employer of NIST > personnel, I request that the contents of NIST Handbooks 130 and 133 be > deliberated edited to completely separate provisions expressed in SI Units of > Measurement from provisions expressed in units from outside the SI (in > so-called US Customary or inch-pound units). > > Full justification for this separation is Federal Laws which declare the > International System of Units (SI) as the *Preferred* System of Units of > Measurement for Trade and Commerce in the United States. > > The objective, of course, it efficient transition to SI-only regulation of > consumer commodities in retail marketplaces when SI-only labels become > permitted by amendment of the FPLA or by rulings of the FTC, USDA, FDA, ATF > and other federal agencies, or by prevailing practices in the States, > irrespective of the entangled wordings of provisions which continue to be > drafted by the NCWM. > > Eugene Mechtly