+-------+----+---------------------------------+---------------------+
| **No. | *  | > **Comments**                  | **Response of       |
| of    | *C |                                 | TC9/SC1             |
| R7    | ou |                                 | Secretariat**       |
| 6-1** | nt |                                 |                     |
|       | ry |                                 |                     |
|       | ** |                                 |                     |
+=======+====+=================================+=====================+
|       |    |                                 | The abbreviations   |
|       |    |                                 | used in the         |
|       |    |                                 | following mean:     |
|       |    |                                 |                     |
|       |    |                                 | P+ = Proposal       |
|       |    |                                 | accepted and        |
|       |    |                                 | considered in the   |
|       |    |                                 | 2CD                 |
|       |    |                                 |                     |
|       |    |                                 | P-- = Proposal not  |
|       |    |                                 | accepted            |
+-------+----+---------------------------------+---------------------+
| Ge    | AU | > We have recently become very  | We assume that your |
| neral |    | > concerned regarding aspects   | concerns are        |
|       |    | > of instrument design and      | expressed in your   |
|       |    | > functioning which have been   | specific comments   |
|       |    | > approved by other             | and proposals       |
|       |    | > authorities, but which we     | below.\             |
|       |    | > feel either clearly do not    | These have -- to a  |
|       |    | > meet current requirements, or | great extent - been |
|       |    | > do not meet even more basic   | accepted and        |
|       |    | > criteria of being suitable    | considered in the   |
|       |    | > for use for trade (that is in | 2CD.                |
|       |    | > some cases it may be          |                     |
|       |    | > difficult to provide an       |                     |
|       |    | > objective criteria in R76     |                     |
|       |    | > which is not met --           |                     |
|       |    | > unfortunately some of the     |                     |
|       |    | > most important aspects in R76 |                     |
|       |    | > are rather subjective). We    |                     |
|       |    | > feel that the emphasis of     |                     |
|       |    | > type approval evaluation has  |                     |
|       |    | > become too fixated on         |                     |
|       |    | > 'performance' aspects and     |                     |
|       |    | > that a return to careful      |                     |
|       |    | > consideration and enforcement |                     |
|       |    | > of usage and suitability      |                     |
|       |    | > aspects is essential.         |                     |
+-------+----+---------------------------------+---------------------+
| Ge    | C  | > Although CECIP has no vote we | OK                  |
| neral | EC | > would like to inform you that |                     |
|       | IP | > we support the voting "yes"   |                     |
|       |    | > in respect to the 1 CD but    |                     |
|       |    | > ask for some changes as       |                     |
|       |    | > listed below.                 |                     |
+-------+----+---------------------------------+---------------------+
| Ge    | CA | Please Note: We have included   | There is a special  |
| neral |    | comments that were not          | situation with the  |
|       |    | addressed in the CD-1, but were | Canadian comments,  |
|       |    | ultimately accepted by the      | because we didn't   |
|       |    | Secretariat. This is simply to  | receive the         |
|       |    | ensure they get carried forward | respective Email in |
|       |    | to the next revision.           | time. The           |
|       |    |                                 | secretariat has     |
|       |    | Comments missed in the          | therefore responded |
|       |    | devlopment of CD-1 appear in    | separately (March   |
|       |    | ORANGE                          | 2005) and has now   |
|       |    |                                 | considered both the |
|       |    | Canada's New comments appear in | old comments (on    |
|       |    | GREEN                           | the WD) and the new |
|       |    |                                 | comments (on the    |
|       |    | And our continuing concerns     | 1CD).               |
|       |    | appear in RED                   |                     |
|       |    |                                 | Chapter 1           |
|       |    | Canada is concerned that there  | (Introduction) and  |
|       |    | is potential for confusion and  | Chapter 2 (Scope    |
|       |    | inconsistency of application by | and field of        |
|       |    | having Annex B duplicate        | application) of     |
|       |    | requirements from OIML D-11**.  | OIML document D11   |
|       |    | We are not sure why this        | say that D11 has to |
|       |    | recommendation does not simply  | be taken into       |
|       |    | reference D-11?**               | account when        |
|       |    |                                 | drafting OIML       |
|       |    | > This problem will be          | recommendations.    |
|       |    | > exasperated when either R76   | This should be done |
|       |    | > or D-11 is modified in the    | by implementing the |
|       |    | > future. If a specific         | D11 requirements    |
|       |    | > requirement is changed in     | into the relevant   |
|       |    | > one, what happens to the      | Recommendation (see |
|       |    | > corresponding requirement in  | Note (1) in Chapter |
|       |    | > the other?                    | 2, D11).            |
|       |    |                                 |                     |
|       |    | Canada is concerned that there  | The same will apply |
|       |    | is potential for confusion and  | to the new OIML     |
|       |    | inconsistency of application by | document on         |
|       |    | having Annex F duplicate        | software (SW) once  |
|       |    | requirements from OIML D-SW     | this will have been |
|       |    | (correct reference?). **We are  | published, i.e. the |
|       |    | not sure why this               | software            |
|       |    | recommendation does not simply  | requirements        |
|       |    | reference D-SW?**               | proposed in an OIML |
|       |    |                                 | D SW document would |
|       |    | > This problem will be          | have to be          |
|       |    | > exasperated when either R76   | implemented at the  |
|       |    | > or D-SW is modified in the    | next but one        |
|       |    | > future. If a specific         | revision of R76.    |
|       |    | > requirement is changed in     |                     |
|       |    | > one, what happens to the      | We think this is    |
|       |    | > corresponding requirement in  | not a problem,      |
|       |    | > the other? See T.2.8.         | because if a        |
|       |    |                                 | respective          |
|       |    |                                 | requirement is      |
|       |    |                                 | changed in a        |
|       |    |                                 | general OIML        |
|       |    |                                 | document, this can  |
|       |    |                                 | and certainly will  |
|       |    |                                 | be considered at    |
|       |    |                                 | the next revision   |
|       |    |                                 | of the respective   |
|       |    |                                 | (specific)          |
|       |    |                                 | recommendation.     |
+-------+----+---------------------------------+---------------------+
| Ge    | FR | > The word "key" (T.2.2.3,      | P+ Has been         |
| neral |    | > T.2.2.4, ...) should be       | considered under    |
|       |    | > changed into a more general   | T.2.2.3             |
|       |    | > one (unless it is confirmed   |                     |
|       |    | > by the english speaking       |                     |
|       |    | > colleagues that it covers all |                     |
|       |    | > kinds of means).              |                     |
+-------+----+---------------------------------+---------------------+
| Ge    | NL | > Also refer to our "not        | We principally      |
| neral |    | > accepted" general remark on   | agree with you and  |
|       |    | > the Working draft 15 December | we welcome a clear  |
|       |    | > 2003:                         | structure of OIML   |
|       |    |                                 | recommendations.    |
|       |    | Taking into account the primary | But if the          |
|       |    | purpose of OIML                 | structure were      |
|       |    | Recommendations: to be a        | changed this should |
|       |    | recommendation for **legal      | be done completely, |
|       |    | requirements for measuring      | and not by just     |
|       |    | instruments**, it is our strong | moving some single  |
|       |    | opinion that there should be a  | requirements to     |
|       |    | strict distinction between:     | other parts. The    |
|       |    |                                 | major question is,  |
|       |    | \- the requirements             | whether we would    |
|       |    | (legislation), and              | really like to      |
|       |    |                                 | change the          |
|       |    | \- the tests / evaluation to    | structure of the    |
|       |    | investigate whether the         | R76 recommendation  |
|       |    | requirements are met, and       | at this point of    |
|       |    |                                 | time. The           |
|       |    | \- the Test Report Format as a  | consequence would   |
|       |    | tool for the testing            | be a further delay  |
|       |    | laboratories.                   | of the revision     |
|       |    |                                 | process by          |
|       |    | In this draft, there is still a | certainly more than |
|       |    | problem that in several clauses | 1 year.             |
|       |    | with **requirements for the     |                     |
|       |    | instrument**, aspects of the    | However, we were    |
|       |    | **tests** are included. For     | ready to do the job |
|       |    | instance:                       | if a majority of    |
|       |    |                                 | the TC9/SC1 members |
|       |    | [Clause 3 "Metrological         | would support that  |
|       |    | requirements"]{.underline}      | proposal.           |
|       |    | contains in **3.7** information |                     |
|       |    | about the test standards to be  |                     |
|       |    | used for type examination and   |                     |
|       |    | verification, in **3.9.1.1**    |                     |
|       |    | about the tilting-test, and in  |                     |
|       |    | **3.10** information about      |                     |
|       |    | "type evaluation tests and      |                     |
|       |    | examinations".                  |                     |
|       |    |                                 |                     |
|       |    | These should be moved to clause |                     |
|       |    | 8.                              |                     |
|       |    |                                 |                     |
|       |    | [Clause 4 "Technical            |                     |
|       |    | requirements                    |                     |
|       |    | \....":]{.underline} **4.18.1** |                     |
|       |    | contains some information on    |                     |
|       |    | tests and "OIML Test Report".   |                     |
|       |    | The information about the tests |                     |
|       |    | should be moved to 8.           |                     |
|       |    |                                 |                     |
|       |    | The last sentence (about the    |                     |
|       |    | OIML Test report) should be     |                     |
|       |    | moved to Annex A.               |                     |
|       |    |                                 |                     |
|       |    | [Clause 5 "Requirements for     |                     |
|       |    | electronic                      |                     |
|       |    | instruments"]{.underline}: in   |                     |
|       |    | **5.3.3** "shall be subjected   |                     |
|       |    | to the span stability test      |                     |
|       |    | \..." and **5.4** "Performance  |                     |
|       |    | and span stability tests" and   |                     |
|       |    | the information about the tests |                     |
|       |    | as well as the documentation    |                     |
|       |    | (5.5.2.1, Table 11) should be   |                     |
|       |    | moved to clause 8.              |                     |
|       |    |                                 |                     |
|       |    | [Clause 6 "Technical            |                     |
|       |    | requirements for a              |                     |
|       |    | non-self-indicating             |                     |
|       |    | instrument":]{.underline} the   |                     |
|       |    | last sentence of **6.1** "The   |                     |
|       |    | sensitivity tests shall be      |                     |
|       |    | \...." should be moved to       |                     |
|       |    | clause 8                        |                     |
|       |    |                                 |                     |
|       |    | > This opinion has also been    |                     |
|       |    | > included in the comments per  |                     |
|       |    | > (sub)clause below.            |                     |
+-------+----+---------------------------------+---------------------+
| Ge    | NL | > In this **draft**, decimal    | P+ Commas have been |
| neral |    | > signs are sometimes given as  | turned into dots in |
|       |    | > a comma, and sometimes as a   | this English        |
|       |    | > dot.                          | version             |
|       |    | >                               |                     |
|       |    | > Please **refer** to the OIML  |                     |
|       |    | > "Directives for the Technical |                     |
|       |    | > Work", Clause 6.6.1:          |                     |
|       |    | >                               |                     |
|       |    | > In English text the decimal   |                     |
|       |    | > sign shall be a dot and in    |                     |
|       |    | > French a comma.               |                     |
+-------+----+---------------------------------+---------------------+
| Ge    | NO | > I think before we introduce   | P+ See 2CD, T.3.4.  |
| neral |    | > the "family" we have to       | We have taken the   |
|       |    | > define a good definition for  | definition from     |
|       |    | > type, then family             | OIML P1 (2003), No  |
|       |    |                                 | 2.6.                |
+-------+----+---------------------------------+---------------------+
| Ge    | UK | > Section 3.3 uses lower case   | P+ "mpe" is now     |
| neral |    | > "mpe", but Section T.5.5 uses | used, see 2CD.      |
|       |    | > upper case "MPE". (there may  |                     |
|       |    | > be other references as well). | P+ Has been checked |
|       |    | > This should be consistent     | and, if necessary,  |
|       |    | > throughout the                | corrected           |
|       |    | > Recommendation.               | throughout the      |
|       |    | >                               | entire document in  |
|       |    | > Need to check for consistency | accordance with the |
|       |    | > in the use of the words       | terminology defined |
|       |    | > "mass" and weight".           | in the new R111 and |
|       |    |                                 | D28, see new Note   |
|       |    |                                 | under T.1.1 in the  |
|       |    |                                 | 2CD.                |
+-------+----+---------------------------------+---------------------+
| Ge    | US | Note: 1. All changes in 1 CD    | OK                  |
| neral |    | against R76-1 (1992) are marked |                     |
|       |    | [red]{.underline}               |                     |
|       |    |                                 |                     |
|       |    | > [2. All changes in 1 CD       |                     |
|       |    | > against Working Draft         |                     |
|       |    | > Revision (2003) are marked    |                     |
|       |    | > with blue background]{.mark}  |                     |
|       |    | >                               |                     |
|       |    | > [3. Language and amendments   |                     |
|       |    | > proposed by the U.S. are      |                     |
|       |    | > marked with yellow            |                     |
|       |    | > background.]{.mark}           |                     |
+-------+----+---------------------------------+---------------------+
| ###   |    | > **Do we need a separate Annex | **Result of the     |
|       |    | > for the digital modules       | vote on B.1:**      |
| #     |    | > "digital data processing      |                     |
| ## Qu |    | > device", "terminal" and       | **10 answers: 7     |
| estio |    | > "digital display" (see Figure | Yes, 3 No (see      |
| n B.1 |    | > 1 under T.2.2) in addition to | below)**            |
|       |    | > the existing Annex C?**       |                     |
|       |    |                                 | Therefore a new     |
|       |    |                                 | Annex D for purely  |
|       |    |                                 | digital devices has |
|       |    |                                 | been added, and the |
|       |    |                                 | former Annexes D to |
|       |    |                                 | F have been         |
|       |    |                                 | renumbered to E to  |
|       |    |                                 | G.                  |
+-------+----+---------------------------------+---------------------+
| A     | CH | > We do not think that a        |                     |
| nswer |    | > separate Annex for the        |                     |
| to    |    | > digital modules "digital data |                     |
| B.1   |    | > processing device",           |                     |
|       |    | > "terminal" and "remote        |                     |
|       |    | > display" is necessary in      |                     |
|       |    | > addition to the existing      |                     |
|       |    | > Annex C                       |                     |
+-------+----+---------------------------------+---------------------+
| A     | DE | > Yes, but [one]{.underline}    |                     |
| nswer |    | > Annex for [all]{.underline}   |                     |
| to    |    | > digital devices mentioned     |                     |
| B.1   |    | > (digital data processing      |                     |
|       |    | > device, terminal, digital     |                     |
|       |    | > display);                     |                     |
+-------+----+---------------------------------+---------------------+
| A     | FR | > Yes, but [one]{.underline}    |                     |
| nswer |    | > Annex for [all]{.underline}   |                     |
| to    |    | > digital devices mentioned     |                     |
| B.1   |    | > (digital data processing      |                     |
|       |    | > device, terminal, digital     |                     |
|       |    | > display);                     |                     |
+-------+----+---------------------------------+---------------------+
| A     | JP | > If specific descriptions for  |                     |
| nswer |    | > each test (descriptions of    |                     |
| to    |    | > necessary tests and           |                     |
| B.1   |    | > unnecessary tests) are        |                     |
|       |    | > provided, there would be no   |                     |
|       |    | > need to have separate         |                     |
|       |    | > Annexes.                      |                     |
+-------+----+---------------------------------+---------------------+
| A     | KR | > I think we need a separate    |                     |
| nswer |    | > Annex for them.               |                     |
| to    |    |                                 |                     |
| B.1   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | NL | > Yes, we are in favor of a     |                     |
| nswer |    | > separate annex for (purely)   |                     |
| to    |    | > digital modules. In this      |                     |
| B.1   |    | > annex it would be (more)      |                     |
|       |    | > clear which tests need to be  |                     |
|       |    | > performed (eg not temperature |                     |
|       |    | > and damp heat).               |                     |
+-------+----+---------------------------------+---------------------+
| A     | RO | > yes                           |                     |
| nswer |    |                                 |                     |
| to    |    |                                 |                     |
| B.1   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | ZA | > Annex C is sufficient as it   |                     |
| nswer |    | > is.                           |                     |
| to    |    |                                 |                     |
| B.1   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | SI | > We support the idea to        |                     |
| nswer |    | > separately define applicable  |                     |
| to    |    | > requirements, principles of   |                     |
| B.1   |    | > testing, tests and guidance's |                     |
|       |    | > for OIML certificate for      |                     |
|       |    | > digital data processing       |                     |
|       |    | > devices, terminals and remote |                     |
|       |    | > displays.                     |                     |
+-------+----+---------------------------------+---------------------+
| A     | US | > The U.S. agrees that criteria |                     |
| nswer |    | > is needed for digital data    |                     |
| to    |    | > processing devices either as  |                     |
| B.1   |    | > a separate Annex or combined  |                     |
|       |    | > with Annex C.                 |                     |
|       |    | >                               |                     |
|       |    | > A combined Annex C could be   |                     |
|       |    | > titled as shown below to      |                     |
|       |    | > clarify that applicable       |                     |
|       |    | > requirements in Annex C,      |                     |
|       |    | > clause C1 are equivalent for  |                     |
|       |    | > both digital and analog data  |                     |
|       |    | > processing devices. This      |                     |
|       |    | > would include interfaces,     |                     |
|       |    | > connectable devices, and      |                     |
|       |    | > descriptive markings and      |                     |
|       |    | > control marks:                |                     |
|       |    | >                               |                     |
|       |    | > ANNEX C                       |                     |
|       |    | >                               |                     |
|       |    | > TESTING AND CERTIFICATION OF  |                     |
|       |    | > INDICATORS**, [DIGITAL DATA   |                     |
|       |    | > PROCESSING                    |                     |
|       |    | > DEVICES,]{.underline}** AND   |                     |
|       |    | > ANALOG PROCESSING DEVICES AS  |                     |
|       |    | > MODULES OF NON-AUTOMATIC      |                     |
|       |    | > WEIGHING INSTRUMENTS          |                     |
+-------+----+---------------------------------+---------------------+
| ###   |    | ####                            | **Result of the     |
|       |    |                                 | vote on B.2:**      |
| #     |    | #### Shou                       |                     |
| ## Qu |    | ld the introductory note propos | **10 answers: 7     |
| estio |    | ed under B.3.3 "Surge" be kept? | Yes, 3 No (see      |
| n B.2 |    |                                 | below)**            |
|       |    |                                 |                     |
|       |    |                                 | Therefore the       |
|       |    |                                 | introductory note   |
|       |    |                                 | will be kept,       |
|       |    |                                 |                     |
|       |    |                                 | see 2CD, B.3.3      |
+-------+----+---------------------------------+---------------------+
| A     | C  | > Industrial customers force    | P- see our response |
| nswer | EC | > the manufacturers of          | under B.3.3 CECIP   |
| to    | IP | > instruments to meet not only  |                     |
| B.2   |    | > the product related standards |                     |
|       |    | > like R76 but also generic IEC |                     |
|       |    | > standards for compliance with |                     |
|       |    | > electromagnetic effects.      |                     |
|       |    | > Therefore OIML should avoid   |                     |
|       |    | > starting to copy any EMC      |                     |
|       |    | > standard existing in the      |                     |
|       |    | > world. That is not possible   |                     |
|       |    | > and useful. As Dutch NMI      |                     |
|       |    | > pointed out a surge testing   |                     |
|       |    | > is not essential for normal   |                     |
|       |    | > industrial applications. In   |                     |
|       |    | > extreme cases the general     |                     |
|       |    | > clause 4.1.1.1 or 5.1.1 comes |                     |
|       |    | > into force.                   |                     |
|       |    | >                               |                     |
|       |    | > Please delete B.3.3           |                     |
|       |    | > completely.                   |                     |
+-------+----+---------------------------------+---------------------+
| A     | CH | > We would agree to keep the    |                     |
| nswer |    | > introductory note in B.3.3    |                     |
| to    |    | > Surge.                        |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | DE | > Yes                           |                     |
| nswer |    |                                 |                     |
| to    |    |                                 |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | FR | > Yes                           |                     |
| nswer |    |                                 |                     |
| to    |    |                                 |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | JP | > There is no need to delete    |                     |
| nswer |    | > the note under B.3.3 "Surge". |                     |
| to    |    | > However, as the module type   |                     |
| B.2   |    | > indicators could be used      |                     |
|       |    | > indoor and outdoor, it seems  |                     |
|       |    | > that there would be necessary |                     |
|       |    | > to add a description such as  |                     |
|       |    | > "Tested for surge" in the     |                     |
|       |    | > descriptive markings under    |                     |
|       |    | > section 7.1                   |                     |
+-------+----+---------------------------------+---------------------+
| A     | NL | > Yes, we want to keep the      |                     |
| nswer |    | > introductory note.            |                     |
| to    |    |                                 |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | RO | > yes                           |                     |
| nswer |    |                                 |                     |
| to    |    |                                 |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | ZA | > We think this test (Surge)    |                     |
| nswer |    | > needs to be compulsory for    |                     |
| to    |    | > all instruments and therefore |                     |
| B.2   |    | > do not agree with the         |                     |
|       |    | > inclusion of the introductory |                     |
|       |    | > note. The risk of significant |                     |
|       |    | > influence of surges or when a |                     |
|       |    | > DC powered instrument is      |                     |
|       |    | > powered from a DC network     |                     |
|       |    | > cannot be predicted           |                     |
|       |    | > (expected) because it is not  |                     |
|       |    | > always known beforehand where |                     |
|       |    | > an instrument will be         |                     |
|       |    | > installed.                    |                     |
+-------+----+---------------------------------+---------------------+
| A     | SI | > We agree to keep the          |                     |
| nswer |    | > introductory note.            |                     |
| to    |    |                                 |                     |
| B.2   |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| A     | US | > The U.S. believes that the    | P- We think that a  |
| nswer |    | > introductory note proposed    | special marking on  |
| to    |    | > under B.3.3 "Surge" ***not*** | the instrument is   |
| B.2   |    | > be kept unless additional     | not adequate for    |
|       |    | > language is developed to      | the surge test, and |
|       |    | > distinguish between           | that the            |
|       |    | > instruments that have and     | information         |
|       |    | > have not been tested for      | provided in the     |
|       |    | > "surge." Similar language has | respective test     |
|       |    | > been included in the humidity | report can be       |
|       |    | > marking requirements in OIML  | considered as       |
|       |    | > R 60.                         | sufficient.         |
|       |    | >                               |                     |
|       |    | > Additionally, attempting to   | However, we have    |
|       |    | > specify conditions where      | added under 8.2.1.2 |
|       |    | > surge testing is needed is    | No 7.3 the length   |
|       |    | > still subject to different    | of signal lines as  |
|       |    | > interpretations. The U.S.     | a necessary         |
|       |    | > suggests that conditions      | information to be   |
|       |    | > where surge testing is not    | provided by the     |
|       |    | > needed, such as battery       | manufacturer.       |
|       |    | > operated device and indoor    |                     |
|       |    | > installations where signal    |                     |
|       |    | > lines are shorter than 30     |                     |
|       |    | > meters.                       |                     |
|       |    | >                               |                     |
|       |    | > The language from D11 sub     |                     |
|       |    | > clause 8.4.5 is similar to    |                     |
|       |    | > other examples of             |                     |
|       |    | > disturbances in D 11 clause   |                     |
|       |    | > 8.4. Severity levels.         |                     |
+-------+----+---------------------------------+---------------------+
| Expl  | UK | > "Repubic of Korea" should be  | P+ Has been         |
| anary |    | > "Republic of Korea".          | corrected.          |
| Note\ |    |                                 |                     |
| on    |    |                                 |                     |
| page  |    |                                 |                     |
| 5     |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| T     | AU | > Add a definition of           | P+ but we suggest a |
| ermin |    | > 'metrologically relevant':    | definition which    |
| ology |    | >                               | cannot be confused  |
|       |    | > **Metrologically relevant:    | with "legally       |
|       |    | > Any aspect of an instrument   | relevant" (see 2CD, |
|       |    | > which is referred to within   | No T.2.9):          |
|       |    | > this document is considered   |                     |
|       |    | > to be metrologically          | "Any device,        |
|       |    | > relevant. Similarly all       | module, part,       |
|       |    | > functions, properties,        | component, function |
|       |    | > qualities, parameters and     | or software of a    |
|       |    | > characteristics referred to   | weighing instrument |
|       |    | > in this document are          | that influences the |
|       |    | > considered to be              | weighing result or  |
|       |    | > 'metrological' unless they    | any other primary   |
|       |    | > are excluded either by        | indication is       |
|       |    | > specific mention, or by the   | considered as       |
|       |    | > context of use of the term.** | metrologically      |
|       |    | >                               | relevant."          |
|       |    | > *Explanation: Throughout this |                     |
|       |    | > recommendation there are many |                     |
|       |    | > places in which there is      |                     |
|       |    | > reference to 'metrologically  |                     |
|       |    | > relevant' aspects (other      |                     |
|       |    | > terms such as 'metrological   |                     |
|       |    | > functions', parameters etc    |                     |
|       |    | > are also used). However       |                     |
|       |    | > nowhere is this defined --    |                     |
|       |    | > one interpretation (in the    |                     |
|       |    | > absence of anything specific  |                     |
|       |    | > this is our interpretation)   |                     |
|       |    | > is that all aspects in this   |                     |
|       |    | > document are relevant to      |                     |
|       |    | > 'legal metrology' and hence   |                     |
|       |    | > anything covered by this      |                     |
|       |    | > document is 'metrologically   |                     |
|       |    | > relevant'. Clause 3.10.4.5    |                     |
|       |    | > includes a listing of         |                     |
|       |    | > metrologically relevant       |                     |
|       |    | > characteristics -- however    |                     |
|       |    | > this is only applicable to    |                     |
|       |    | > testing of a family of        |                     |
|       |    | > instruments or modules, and   |                     |
|       |    | > it clearly does not include   |                     |
|       |    | > aspects which are surely by   |                     |
|       |    | > any definition metrological   |                     |
|       |    | > (e.g. operation of zero and   |                     |
|       |    | > tare devices). Or perhaps     |                     |
|       |    | > metrologically relevant is    |                     |
|       |    | > intended to only apply to     |                     |
|       |    | > aspects mentioned in T.4 to   |                     |
|       |    | > T.4.6 (we believe this would  |                     |
|       |    | > clearly be inadequate).*      |                     |
+-------+----+---------------------------------+---------------------+
| T.1.2 | AT | > We think that the sentence    | P- But we think     |
|       |    | > "The weighing process allows  | that the wording    |
|       |    | > the operator to take an       | has been improved   |
|       |    | > action which influences the   | by the US proposal  |
|       |    | > weighing result in the case   | below.              |
|       |    | > where the weighing result is  |                     |
|       |    | > not acceptable." is critical, |                     |
|       |    | > because "an action which      |                     |
|       |    | > influences the weighing       |                     |
|       |    | > result" could be "regulating  |                     |
|       |    | > the belt speed or adjusting   |                     |
|       |    | > the feeding device. We think  |                     |
|       |    | > the note is clear enough      |                     |
|       |    | > without this sentence.        |                     |
+-------+----+---------------------------------+---------------------+
| T.1.2 | CA | Definition of Non-Automatic     | P- We understand    |
|       |    | Weighing instrument (device) is | your point; it is   |
|       |    | also causing us some concern    | indeed problematic  |
|       |    | within Canada. Concern is that  | to define a NAWI in |
|       |    | both R76 (and our own current   | terms of an         |
|       |    | definition) are based upon      | "operator". The     |
|       |    | device usage as opposed to      | only solution that  |
|       |    | device design. This means that  | would solve the     |
|       |    | a given device could change     | problem would be to |
|       |    | from NAWI to AWI in use. This   | distinguish between |
|       |    | is unacceptable as evaluation   | "static" and        |
|       |    | is different for each           | "dynamic" weighing; |
|       |    | instrument (device) type.       | with all positive   |
|       |    |                                 | consequences        |
|       |    | **Propose that definition be    | (including          |
|       |    | based upon device design.**     | reduction of size   |
|       |    | Unsure of best wording?         | of AWI              |
|       |    |                                 | recommendations and |
|       |    |                                 | test reports) and   |
|       |    |                                 | negative            |
|       |    |                                 | consequences        |
|       |    |                                 | (contradiction to   |
|       |    |                                 | existing AWI        |
|       |    |                                 | recommendations and |
|       |    |                                 | many national       |
|       |    |                                 | laws).              |
|       |    |                                 |                     |
|       |    |                                 | This proposal was,  |
|       |    |                                 | however, proposed   |
|       |    |                                 | and discussed       |
|       |    |                                 | earlier and it was  |
|       |    |                                 | refused by a clear  |
|       |    |                                 | majority vote of    |
|       |    |                                 | the P-members of    |
|       |    |                                 | TC9/SC1, see        |
|       |    |                                 | "Summary of votes"  |
|       |    |                                 | (29 April 2003), No |
|       |    |                                 | 2.1.                |
+-------+----+---------------------------------+---------------------+
| T.1.2 | FR | Last line of the note : Delete  | Settled by new      |
|       |    | "non-automatic"                 | wording (Note 2),   |
|       |    |                                 | see T.1.2 US        |
+-------+----+---------------------------------+---------------------+
| T.1.2 | JP | > The definition of             | See our response to |
|       |    | > non-automatic weighing        | CA                  |
|       |    | > instrument is the instrument  |                     |
|       |    | > that requires the             |                     |
|       |    | > intervention of an operator   |                     |
|       |    | > during weighing process to    |                     |
|       |    | > decide that the result is     |                     |
|       |    | > acceptable. However, there is |                     |
|       |    | > weighing instrument to        |                     |
|       |    | > measure mass by stationary    |                     |
|       |    | > measurement without           |                     |
|       |    | > intervention of an operator   |                     |
|       |    | > to decide that the result is  |                     |
|       |    | > acceptable. Is this type of   |                     |
|       |    | > weighing instrument supposed  |                     |
|       |    | > not to be non-automatic       |                     |
|       |    | > weighing instrument? If so,   |                     |
|       |    | > this definition is against    |                     |
|       |    | > Japanese policy of            |                     |
|       |    | > classification of             |                     |
|       |    | > non-automatic and automatic   |                     |
|       |    | > weighing instruments.         |                     |
+-------+----+---------------------------------+---------------------+
| T.1.2 | ZA | > 1^st^ Par: Add: ...weighing   | P+ see T.1.2 US     |
|       |    | > process to decide that the    |                     |
|       |    | > weighing result ~~it~~ is     |                     |
|       |    | > acceptable.                   |                     |
+-------+----+---------------------------------+---------------------+
| T.1.2 | UK | > Is the word "dynamic" in the  | P+ "dynamic"        |
|       |    | > last new (red) sentence in    | deleted             |
|       |    | > this section appropriate?     |                     |
|       |    | > Dynamic weighing instruments  | P- see US proposal  |
|       |    | > tend to be considered as      | to T.1.2            |
|       |    | > automatic, e.g. a dynamic     |                     |
|       |    | > catchweigher.                 | P- Because of       |
|       |    | >                               | improved wording,   |
|       |    | > "\...weighed load, it also    | see T.1.2 US        |
|       |    | > includes to make\..." should  |                     |
|       |    | > be "\...weighed load. It also |                     |
|       |    | > includes making\..."          |                     |
|       |    | >                               |                     |
|       |    | > The wording of the "Note" to  |                     |
|       |    | > this section is at best       |                     |
|       |    | > ambiguous. It implies that    |                     |
|       |    | > the operator must have the    |                     |
|       |    | > capability of adjusting the   |                     |
|       |    | > weight of the weighed load    |                     |
|       |    | > whilst that load is on the    |                     |
|       |    | > load receptor. This may not   |                     |
|       |    | > always be possible either for |                     |
|       |    | > hygiene or health and safety  |                     |
|       |    | > reasons. If left as it is the |                     |
|       |    | > wording would mean that any   |                     |
|       |    | > "non-automatic" instrument    |                     |
|       |    | > where it is not possible for  |                     |
|       |    | > the operator to adjust the    |                     |
|       |    | > weight of the load whilst it  |                     |
|       |    | > is on the load receptor would |                     |
|       |    | > fall outside the definition   |                     |
|       |    | > of nonautomatic given in this |                     |
|       |    | > Recommendation. What is       |                     |
|       |    | > important is that the         |                     |
|       |    | > operator has to accept the    |                     |
|       |    | > weighing or take some action  |                     |
|       |    | > after the weighing is         |                     |
|       |    | > complete to adjust or correct |                     |
|       |    | > it.                           |                     |
|       |    | >                               |                     |
|       |    | > Reinstate the definition as   |                     |
|       |    | > given in R76-1, Edition 1992  |                     |
+-------+----+---------------------------------+---------------------+
| T.1.2 | US | The U.S. appreciates the        | P+ See also ZA      |
|       |    | earlier clarifications provided | proposal            |
|       |    | by the Secretariat on the       |                     |
|       |    | definition of the additional    | P+ See Note 1 in    |
|       |    | "Note" of the term              | 2CD                 |
|       |    | non-automatic weighing          |                     |
|       |    | instrument. We believe that     | P+ See Note 1 in    |
|       |    | additional clarification is     | 2CD                 |
|       |    | needed regarding the phrase     |                     |
|       |    | "operator intervention during   | P- Instead of this  |
|       |    | the weighing process."          | text, which would   |
|       |    |                                 | probably lead to    |
|       |    | U.S. manufacturers and          | misinterpretations, |
|       |    | regulators have reported that   | we propose a new    |
|       |    | they have difficulty in         | Note 2 relating to  |
|       |    | consistently determining the    | the definition of   |
|       |    | "automatic" or "non-automatic"  | AWIs (see 2CD, No   |
|       |    | status of weighing instruments  | T.1.2)              |
|       |    | that require [operators to      |                     |
|       |    | place objects on the load       |                     |
|       |    | receptor]{.underline} of a      |                     |
|       |    | weighing instrument. After the  |                     |
|       |    | weight has been determined, the |                     |
|       |    | [instrument automatically       |                     |
|       |    | removes]{.underline} the object |                     |
|       |    | from the load receptor to be    |                     |
|       |    | automatically wrapped and       |                     |
|       |    | labelled. The technical experts |                     |
|       |    | in the U.S. are divided as how  |                     |
|       |    | to classify these types of      |                     |
|       |    | instruments (automatic or       |                     |
|       |    | non-automatic).                 |                     |
|       |    |                                 |                     |
|       |    | The U.S. offers the following   |                     |
|       |    | to clarify that the instrument  |                     |
|       |    | in the above example is not an  |                     |
|       |    | automatic weighing instrument:  |                     |
|       |    |                                 |                     |
|       |    | > T.1.2 Non-automatic weighing  |                     |
|       |    | > instrument                    |                     |
|       |    | >                               |                     |
|       |    | > Instrument that requires the  |                     |
|       |    | > intervention of an operator   |                     |
|       |    | > during the weighing process   |                     |
|       |    | > to decide that ~~it~~ the     |                     |
|       |    | > weighing result is            |                     |
|       |    | > acceptable.                   |                     |
|       |    | >                               |                     |
|       |    | > Note: Deciding that the       |                     |
|       |    | > weighing result is acceptable |                     |
|       |    | > includes any intelligent      |                     |
|       |    | > action of the operator that   |                     |
|       |    | > affects the result, such as   |                     |
|       |    | > taking an action when an      |                     |
|       |    | > indication is stable or       |                     |
|       |    | > adjusting the weight of the   |                     |
|       |    | > weighed load, ~~it also       |                     |
|       |    | > includes~~ and to make a      |                     |
|       |    | > decision regarding the        |                     |
|       |    | > acceptance of each weighing   |                     |
|       |    | > result on observing the       |                     |
|       |    | > indication or releasing a     |                     |
|       |    | > print out.                    |                     |
|       |    | >                               |                     |
|       |    | > ~~The~~ A non-automatic       |                     |
|       |    | > weighing process allows the   |                     |
|       |    | > operator to take an action    |                     |
|       |    | > (i.e. adjust the load, adjust |                     |
|       |    | > the unit price, determine     |                     |
|       |    | > that the load is acceptable,  |                     |
|       |    | > etc.) which influences the    |                     |
|       |    | > weighing result in the case   |                     |
|       |    | > where the weighing result is  |                     |
|       |    | > not acceptable.               |                     |
|       |    | >                               |                     |
|       |    | > The necessity to give an      |                     |
|       |    | > instruction to start the      |                     |
|       |    | > weighing process, or release  |                     |
|       |    | > a load, [or place the item to |                     |
|       |    | > be weighed on the load        |                     |
|       |    | > receptor]{.mark}, or to       |                     |
|       |    | > change the function of the    |                     |
|       |    | > instrument (static, dynamic,  |                     |
|       |    | > automatic loading, automatic  |                     |
|       |    | > start of weighing, etc.) are  |                     |
|       |    | > not relevant in deciding the  |                     |
|       |    | > category of a non-automatic   |                     |
|       |    | > weighing instrument.          |                     |
+-------+----+---------------------------------+---------------------+
| T.1   | CA | We still find this section      | No, such a platform |
| .2.11 |    | somewhat ambiguous.             | scale would not be  |
|       |    |                                 | a mobile            |
|       |    | Last part of first paragraph is | instrument, because |
|       |    | rather restrictive in that the  | it were not mounted |
|       |    | vehicle must be equipped with   | on or incorporated  |
|       |    | wheels and somewhat unclear     | in a vehicle.       |
|       |    | what is meant by 'can be moved  |                     |
|       |    | without other tools'. Is a      | P+ But we suggest   |
|       |    | platform scale, equipped with   | not to mention      |
|       |    | wheels a mobile instrument?     | "other mobile       |
|       |    |                                 | equipment" to avoid |
|       |    | Suggest that the 1^st^          | confusion.          |
|       |    | paragraph of this section be    |                     |
|       |    | reworded:                       | We also suggest to  |
|       |    |                                 | improve the "Note"  |
|       |    | > Non Automatic weighing        | as follows:         |
|       |    | > instrument mounted on or      | "Vehicle mounted    |
|       |    | > incorporated into a vehicle   | instrument is a     |
|       |    | > ~~or similar utensil that     | complete weighing   |
|       |    | > enables the instrument to be  | instrument that is  |
|       |    | > moved on wheels without other | firmly mounted on a |
|       |    | > tools~~ *or other mobile      | vehicle, and that   |
|       |    | > equipment*.                   | is designed for     |
|       |    |                                 | that special        |
|       |    | Suggest dropping examples as it | purpose."           |
|       |    | is not readily apparent what    |                     |
|       |    | each of these examples actually | P- We think that    |
|       |    | represents.                     | just the examples   |
|       |    |                                 | help for a better   |
|       |    |                                 | understanding of    |
|       |    |                                 | the definition      |
+-------+----+---------------------------------+---------------------+
| T.1   | FR | > 1^st^ example of the note :   | P- But we suggest   |
| .2.11 |    | > after "Postal scale" add      | to add "(mobile     |
|       |    | > "price computing instrument"  | post office)"       |
+-------+----+---------------------------------+---------------------+
| T.1   | UK | > Not sure that all of the      | P+ We hope that     |
| .2.11 |    | > examples of a vehicle         | your concerns are   |
|       |    | > incorporated or a vehicle     | met by the          |
|       |    | > mounted instrument "enables   | improvements (see   |
|       |    | > the instrument to be moved on | CA).                |
|       |    | > wheels". In some              |                     |
|       |    | > applications, e.g. garbage    |                     |
|       |    | > weighers, the instrument is   |                     |
|       |    | > not incorporated in the       |                     |
|       |    | > vehicle to be "moved on       |                     |
|       |    | > wheels"; this is just a       |                     |
|       |    | > consequence of being on the   |                     |
|       |    | > vehicle. However, this        |                     |
|       |    | > definition is true for some   |                     |
|       |    | > of the examples given. The    |                     |
|       |    | > whole definition of mobile    |                     |
|       |    | > instrument should be reviewed |                     |
|       |    | > accordingly.                  |                     |
+-------+----+---------------------------------+---------------------+
| T.1   | CA | Portable instrument definition  | P- The restriction  |
| .2.12 |    | is limited to cover portable    | to portable         |
|       |    | vehicle scale. Canada still     | [v                  |
|       |    | believes that the definition    | ehicle]{.underline} |
|       |    | should be expanded to cover     | scales was intended |
|       |    | both portable vehicle scales    | by TC9/SC1 members  |
|       |    | [and other portable             | (as far as we       |
|       |    | scales]{.underline}.            | understood the      |
|       |    |                                 | respective          |
|       |    | However, in either case, the    | proposal); this     |
|       |    | definition in R76 remains       | makes sense because |
|       |    | somewhat misleading as even a   | there is a demand   |
|       |    | stationary weighbridge may be   | for special,        |
|       |    | moved with suitable equipment.  | additional          |
|       |    |                                 | requirements only   |
|       |    | Suggested wording:              | for axle or wheel   |
|       |    |                                 | load weighers.      |
|       |    | *Portable Vehicle Weighing      | Other instruments   |
|       |    | instrument -- Self contained,   | that are portable   |
|       |    | Non-automatic weighing          | must meet R76 in    |
|       |    | instrument having a load        | general.            |
|       |    | receptor -- in one or several   |                     |
|       |    | parts -- that determines the    | P+                  |
|       |    | mass of road vehicles, and      |                     |
|       |    | [that is designed to be moved   |                     |
|       |    | to other                        |                     |
|       |    | locations.]{.underline}*        |                     |
|       |    |                                 |                     |
|       |    | Rationale: The differentiation  |                     |
|       |    | should not be can the device be |                     |
|       |    | moved, but rather was it        |                     |
|       |    | [designed]{.underline} to be    |                     |
|       |    | moved.                          |                     |
|       |    |                                 |                     |
|       |    | As previously stated, the note  |                     |
|       |    | in this section regarding multi |                     |
|       |    | draft weighing should be a      |                     |
|       |    | [separate]{.underline}          |                     |
|       |    | definition as it applies to any |                     |
|       |    | weighing activity and not       |                     |
|       |    | simply those weighments         |                     |
|       |    | involving portable instruments. |                     |
+-------+----+---------------------------------+---------------------+
| T.1   | RO | By deleting the text from the   | P+                  |
| .2.12 |    | previous version of the note    |                     |
|       |    | "*This excludes the             |                     |
|       |    | certification of portable       |                     |
|       |    | instruments that calculate the  |                     |
|       |    | total mass by summing up the    |                     |
|       |    | partial axle (or wheel) loads   |                     |
|       |    | determined one after the        |                     |
|       |    | other*" and by using in         |                     |
|       |    | parallel the terms "*parts of   |                     |
|       |    | load receptor*", "*load         |                     |
|       |    | weighers*" and "*load           |                     |
|       |    | platforms*", the impression is  |                     |
|       |    | created that the latter are     |                     |
|       |    | different objects and that the  |                     |
|       |    | axles may be determined one     |                     |
|       |    | after the other provided that   |                     |
|       |    | all the wheels should be        |                     |
|       |    | simultaneously supported by     |                     |
|       |    | appropriate platforms (even if  |                     |
|       |    | these are not parts of the load |                     |
|       |    | receptor). We suggest to        |                     |
|       |    | re-phrase as follows:           |                     |
|       |    |                                 |                     |
|       |    | "*Note: This Recommendation     |                     |
|       |    | covers only weighbridges and    |                     |
|       |    | groups of associated            |                     |
|       |    | non-automatic axle (or wheel)   |                     |
|       |    | load weighers that determine*   |                     |
|       |    | simultaneously *the mass of a   |                     |
|       |    | road vehicle with               |                     |
|       |    | [all]{.underline} axles (or     |                     |
|       |    | wheels) being                   |                     |
|       |    | [simultaneously]{.underline}    |                     |
|       |    | supported by appropriate parts  |                     |
|       |    | of load* receptor."             |                     |
+-------+----+---------------------------------+---------------------+
| T.1   | UK | > The note implies that this    | P+ We hope your     |
| .2.12 |    | > Recommendation only applies   | concerns are        |
|       |    | > to weighbridges and groups of | covered by our      |
|       |    | > associated axle load          | responses to RO and |
|       |    | > weighers. The word            | CA                  |
|       |    | > "platforms" at the end of the |                     |
|       |    | > sentence does not match up    |                     |
|       |    | > with the Terminology. Add "In |                     |
|       |    | > regard to instruments for     |                     |
|       |    | > weighing road vehicles" at    |                     |
|       |    | > the beginning of the sentence |                     |
|       |    | > in the Note. Replace          |                     |
|       |    | > "platforms" with "receptors". |                     |
+-------+----+---------------------------------+---------------------+
| T.1   | CA | > In Canada, the term 'Grading  | P- Term is in line  |
| .2.13 |    | > Instrument' is used for       | with R51 (DR), No   |
|       |    | > instrument (device) which     | 2.2.2.              |
|       |    | > determines 'quality' or       |                     |
|       |    | > 'dockage'. (e.g. grain        |                     |
|       |    | > dockage scale, egg grading    |                     |
|       |    | > scale, etc.) It is not used   |                     |
|       |    | > for determination of a tariff |                     |
|       |    | > or toll. These devices should |                     |
|       |    | > be called 'weight             |                     |
|       |    | > classifiers' or something     |                     |
|       |    | > similar. Prefer to see        |                     |
|       |    | > wording changed as the term   |                     |
|       |    | > 'grading' is clearly not      |                     |
|       |    | > accurate in this case.        |                     |
|       |    | >                               |                     |
|       |    | > See also comment 3.2 below.   |                     |
+-------+----+---------------------------------+---------------------+
| T.1.3 | UK | > The note is ambiguous. It     | P+ is changed to    |
|       |    | > presumably means that the     | read "...includes   |
|       |    | > word "indication" etc. can    | both displaying     |
|       |    | > mean displaying or printing   | and/or printing."   |
|       |    | > or both, but it could         |                     |
|       |    | > alternatively be understood   | P- But we have      |
|       |    | > to mean that that word        | clarified the note  |
|       |    | > "indication" etc. must mean   | by deleting the     |
|       |    | > both displaying and printing. | last part "; see    |
|       |    | >                               | also\..."           |
|       |    | > Also, change "displaying      |                     |
|       |    | > device" to "indicating        |                     |
|       |    | > device".                      |                     |
+-------+----+---------------------------------+---------------------+
| T.2.2 | C  | > A digital data processing     | P+ Has been changed |
|       | EC | > device does not necessarily   | to read: (4) + 5 +  |
|       | IP | > include No. 4. In our         | (6) in Figure 1     |
|       |    | > understanding 5 is defined as |                     |
|       |    | > such as well if it is         |                     |
|       |    | > separate from 4 and has to be |                     |
|       |    | > taken into account.           |                     |
+-------+----+---------------------------------+---------------------+
| T.2.2 | FR | > In the table, we propose to   | P- 1. We have no    |
|       |    | > introduce a line for 3 (ADC)  | experience at all   |
|       |    | > alone.                        | with testing of     |
|       |    |                                 | pure ADCs as        |
|       |    |                                 | modules,            |
|       |    |                                 |                     |
|       |    |                                 | 2\. But w suggest   |
|       |    |                                 | to change the       |
|       |    |                                 | heading of Figure 1 |
|       |    |                                 | to "Definition of   |
|       |    |                                 | [t                  |
|       |    |                                 | ypical]{.underline} |
|       |    |                                 | modules\...(further |
|       |    |                                 | combinations are    |
|       |    |                                 | possible)."; this   |
|       |    |                                 | gives us more       |
|       |    |                                 | flexibility as      |
|       |    |                                 | regards future      |
|       |    |                                 | developments; see   |
|       |    |                                 | also response to US |
|       |    |                                 | comment on T.2.2.   |
+-------+----+---------------------------------+---------------------+
| T.2.2 | JP | > Weighing sensors such as      | P- "Analogue load   |
|       |    | > string sensor, capacitance    | cells" as defined   |
|       |    | > sensor other than analogue    | in R60 are not      |
|       |    | > load cell and digital load    | restricted to       |
|       |    | > cell are not included.        | strain gauge load   |
|       |    | > Doesn't this definition       | cells; string       |
|       |    | > likely impair the development | sensors or          |
|       |    | > of weighing sensors with      | capacitance sensors |
|       |    | > higher accuracy and lower     | are considered as   |
|       |    | > power consumption than load   | analogue or digital |
|       |    | > cells based on technical      | load cells, too,    |
|       |    | > progress in future            | and are included.   |
|       |    |                                 | Please refer also   |
|       |    |                                 | to the response to  |
|       |    |                                 | FR.                 |
+-------+----+---------------------------------+---------------------+
| T.2.2 | SI | > In the table under Figure 1   | P+ Have been        |
|       |    | > there are some wrong          | corrected and       |
|       |    | > references to terminology.    | renumbered          |
|       |    | > Replace T.2.2.5 with T.2.2.6, |                     |
|       |    | > T.2.2.6 with T.2.2.7 and      |                     |
|       |    | > T.2.2.7 with T.2.2.5.         |                     |
+-------+----+---------------------------------+---------------------+
| T.2.2 | UK | > Page 9:\                      | P+                  |
|       |    | > The sentence "For the         |                     |
|       |    | > present\..." should be        |                     |
|       |    | > left-just or fully justified. |                     |
+-------+----+---------------------------------+---------------------+
| T.2.2 | US | The U.S. supports the proposed  | We principally      |
|       |    | amendments to T.2.2 and         | agree that this is  |
|       |    | proposes a new term that        | a possible          |
|       |    | consists of the combination of  | combination, but we |
|       |    | a load cell and the mechanical  | rather suggest to   |
|       |    | and electrical connecting       | introduce a more    |
|       |    | elements be defined include the | general term in the |
|       |    | new term in T.2.2. Figure 1.    | heading of Figure 1 |
|       |    | Note that the combined effects  | (see response to FR |
|       |    | of load cells and connecting    | proposal).          |
|       |    | elements are already            |                     |
|       |    | established in Table 7.         |                     |
|       |    |                                 |                     |
|       |    | T.2.2.8. Weighing element (is   |                     |
|       |    | there a better term?)           |                     |
|       |    |                                 |                     |
|       |    | > The part of a weighing        |                     |
|       |    | > instrument that comprises all |                     |
|       |    | > mechanical devices and load   |                     |
|       |    | > cells (i.e. load receptor,    |                     |
|       |    | > load-transmitting device, and |                     |
|       |    | > analog or digital load        |                     |
|       |    | > cells).                       |                     |
|       |    | >                               |                     |
|       |    | > Figure 1                      |                     |
|       |    | >                               |                     |
|       |    | > Definition of modules         |                     |
|       |    | > according to Terminology      |                     |
|       |    | > T.2.2 and 3.10.2              |                     |
|       |    |                                 |                     |
|       |    | ![](media/image1.jpe            |                     |
|       |    | g){width="3.3354166666666667in" |                     |
|       |    | height="1.7006944444444445in"}  |                     |
|       |    |                                 |                     |
|       |    | > analogue load cell (T.2.2.1)  |                     |
|       |    | > 2                             |                     |
|       |    | >                               |                     |
|       |    | > digital load cell (T.2.2.1)   |                     |
|       |    | > 2 + 3 + (4)\*^)^              |                     |
|       |    | >                               |                     |
|       |    | > Indicator (T.2.2.2) (3) + 4 + |                     |
|       |    | > (5) + (6) + 7                 |                     |
|       |    | >                               |                     |
|       |    | > analogue data processing      |                     |
|       |    | > device (T.2.2.3) 3 + 4 +      |                     |
|       |    | > (5) + (6)                     |                     |
|       |    | >                               |                     |
|       |    | > digital data processing       |                     |
|       |    | > device (T.2.2.4) 4 + (5) +    |                     |
|       |    | > (6)                           |                     |
|       |    | >                               |                     |
|       |    | > Terminal (T.2.2.5) (5) + 6 +  |                     |
|       |    | > 7                             |                     |
|       |    | >                               |                     |
|       |    | > remote display (T.2.2.6) 7    |                     |
|       |    | >                               |                     |
|       |    | > weighing module (T.2.2.7) 1 + |                     |
|       |    | > 2 + 3 + 4 + (5) + (6)         |                     |
|       |    | >                               |                     |
|       |    | > weighing element (?)          |                     |
|       |    | > (T.2.2.8) 1 + 2 + (3)\*^)^    |                     |
|       |    | >                               |                     |
|       |    | > \*^)^ Numbers in brackets     |                     |
|       |    | > indicate options              |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CN | > We suggest the *note* in      | P+ We suggest,      |
| 2.2.1 |    | > T.2.2.1 is explained more     | however, to use     |
|       |    | > clearly according to 2.1.3 of | data processing     |
|       |    | > OIML R60, namely, "Load cells | device instead of   |
|       |    | > equipped with electronics     | "data processor",   |
|       |    | > including amplifier , A/D     | and to leave out    |
|       |    | > converter and data processor  | "etc".              |
|       |    | > (optionally) etc., are called |                     |
|       |    | > digital load cells (see       |                     |
|       |    | > figure 1)."                   |                     |
+-------+----+---------------------------------+---------------------+
| T.    | AT | > "... It may optionally have   | P+                  |
| 2.2.3 |    | > one [or]{.underline} more     |                     |
|       |    | > keys to operate the           |                     |
|       |    | > instrument ..."               |                     |
+-------+----+---------------------------------+---------------------+
| T.    | FR | > The word "key" (T.2.2.3,      | P+ Clarified by     |
| 2.2.3 |    | > T.2.2.4, ...) should be       | adding examples to  |
|       |    | > changed into a more general   | "keys" (or mouse ,  |
|       |    | > one (unless it is confirmed   | touch-screen, etc.) |
|       |    | > by the english speaking       |                     |
|       |    | > colleagues that it covers all |                     |
|       |    | > kinds of means).              |                     |
+-------+----+---------------------------------+---------------------+
| T.    | UK | > "It may optionally have one   | P+ see T.2.2.3 AT   |
| 2.2.3 |    | > more keys to operate the      |                     |
|       |    | > instrument" should be "It may |                     |
|       |    | > optionally have one or more   |                     |
|       |    | > keys to operate the           |                     |
|       |    | > instrument", to match Section |                     |
|       |    | > T.2.2.4.                      |                     |
+-------+----+---------------------------------+---------------------+
| T.    | FR | > The word "key" (T.2.2.3,      | P- We think that it |
| 2.2.4 |    | > T.2.2.4, ...) should be       | is sufficient to    |
|       |    | > changed into a more general   | explain "key" one   |
|       |    | > one (unless it is confirmed   | times in T.2.2.3    |
|       |    | > by the english speaking       |                     |
|       |    | > colleagues that it covers all |                     |
|       |    | > kinds of means).              |                     |
+-------+----+---------------------------------+---------------------+
| T.    | UK | > Need a definition of "data"   | P- Cannot be        |
| 2.2.4 |    | > in the sentence "... that     | misunderstood in    |
|       |    | > further processes the data,   | this context        |
|       |    | > ..."                          |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CN | > In T.2.2.5, We propose to add | P+ Considered in    |
| 2.2.5 |    | > the word - "digital data      | new T.2.2.7         |
|       |    | > processing device" to "...(   | (re-numbered)       |
|       |    | > ie. load receptor,            |                     |
|       |    | > load-transmitting device,     |                     |
|       |    | > load cell, analogue data      |                     |
|       |    | > processing device and         |                     |
|       |    | > *digital data processing      |                     |
|       |    | > device*)...".                 |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CA | > Terminal definition is too    | P+ Has been         |
| 2.2.6 |    | > restrictive. Using a keyboard | clarified in        |
|       |    | > as the differentiating piece  | T.2.2.3 (see        |
|       |    | > of hardware is going to cause | response to FR)     |
|       |    | > problems as touch screens,    |                     |
|       |    | > mouses (mice?) and other      |                     |
|       |    | > alternate human interfaces    |                     |
|       |    | > are developed and exploited.  |                     |
|       |    | > Touch screens are already     |                     |
|       |    | > relatively common.            |                     |
|       |    | >                               |                     |
|       |    | > Canada agrees with            |                     |
|       |    | > clarification as proposed by  |                     |
|       |    | > Secretariat.                  |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CA | Should remote displays be       | P+ [Figure          |
| 2.2.7 |    | considered as a means of        | 1]{.underline} has  |
|       |    | primary indication? Canada      | been changed for    |
|       |    | currently requires an approved  | further             |
|       |    | and inspected primary indicator | clarification,      |
|       |    | but allows non-approved remote  | please refer to our |
|       |    | displays as secondary           | new proposal in     |
|       |    | indicators only. It is not      | Figure 1 and        |
|       |    | clear why remote displays would | T.2.2.6             |
|       |    | be considered as the primary    | (re-numbered)       |
|       |    | indication means.               |                     |
|       |    |                                 | To avoid confusion  |
|       |    | > Prefer term "duplication"     | "remote display"    |
|       |    | > rather than "replication".    | has been exchanged  |
|       |    |                                 | by either "primary  |
|       |    | Canada agrees with              | display", or        |
|       |    | clarification as proposed by    | "secondary          |
|       |    | Secretariat.                    | display", or        |
|       |    |                                 | "digital display"   |
|       |    |                                 | in the entire       |
|       |    |                                 | document (see       |
|       |    |                                 | changed definition  |
|       |    |                                 | under re-numbered   |
|       |    |                                 | T.2.2.6).           |
+-------+----+---------------------------------+---------------------+
| T.    | UK | > Needs to be slightly          | We are not aware of |
| 2.3.6 |    | > reworded.                     | any necessary       |
|       |    |                                 | changes; we expect  |
|       |    |                                 | editorial and       |
|       |    |                                 | linguistic          |
|       |    |                                 | improvements be     |
|       |    |                                 | done by the BIML.   |
+-------+----+---------------------------------+---------------------+
| T.2.4 | UK | > "displaying" be "indicating"? | P- In T.2.4         |
|       |    | > "Displaying" is only used in  | "displaying device" |
|       |    | > the list in 2.4 and nowhere   | is used correctly;  |
|       |    | > else in the document.         | the term cannot be  |
|       |    | >                               | deleted because it  |
|       |    | > In the sentence "Component    | is required in      |
|       |    | > displaying", change to        | several contexts.   |
|       |    | > "Component that displays ..." |                     |
|       |    | > or reinstate the definition   | In the entire       |
|       |    | > as given in R76-1 Edition     | document            |
|       |    | > 1992.                         | "indicating device" |
|       |    |                                 | has been replaced   |
|       |    |                                 | by "displaying      |
|       |    |                                 | device" if the      |
|       |    |                                 | meaning is just     |
|       |    |                                 | "displaying" (and   |
|       |    |                                 | not "printing").    |
|       |    |                                 |                     |
|       |    |                                 | P+ see below        |
+-------+----+---------------------------------+---------------------+
| T.    | UK | > "displaying" be "indicating"? | See T.2.4 UK above  |
| 2.4.1 |    | > "Displaying" is only used in  |                     |
|       |    | > the list in 2.4 and nowhere   | P+                  |
|       |    | > else in the document.         |                     |
|       |    | >                               |                     |
|       |    | > In the sentence "Component    |                     |
|       |    | > displaying", change to        |                     |
|       |    | > "Component that displays ..." |                     |
|       |    | > or reinstate the definition   |                     |
|       |    | > as given in R76-1 Edition     |                     |
|       |    | > 1992.                         |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CA | > Minor editorial change, "A    | P+                  |
| 2.4.2 |    | > line or other mark on         |                     |
|       |    | > [a]{.underline}~~n~~          |                     |
|       |    | > displaying component..."      |                     |
+-------+----+---------------------------------+---------------------+
| T.2.5 | CA | > What is the purpose for this  | The purpose is to   |
|       |    | > section? It may cause issue   | explain the terms   |
|       |    | > as Canada currently uses very | used e.g. in 3.4.   |
|       |    | > different terminology.        |                     |
+-------+----+---------------------------------+---------------------+
| T.2.8 | CA | Canada has many concerns with   | 1\. We refer to our |
|       |    | the entire metrological         | response to your    |
|       |    | software section, including     | proposal under      |
|       |    | terminology and application.    | "General" (D11 and  |
|       |    |                                 | D-SW).              |
|       |    | As software requirements are    |                     |
|       |    | applicable to many instrument   | 2\. We'd like to    |
|       |    | types, not only NAWI's, we      | remind you of the   |
|       |    | wonder why software is included | clear vote of       |
|       |    | in the recommendation and not   | TC9/SC1 members     |
|       |    | kept as a separate document.    | concerning software |
|       |    | D-SW?                           | requirements in R76 |
|       |    |                                 | ("Summary of the    |
|       |    | Suggest replacing phrase        | votes" dated 29     |
|       |    | 'Legally Relevant Software'     | April 2003, No      |
|       |    | with 'Metrological Software'    | 4.3). The proposed  |
|       |    | which is more descriptive.      | requirements and    |
|       |    |                                 | terminology are in  |
|       |    |                                 | line with the       |
|       |    |                                 | pre-draft document  |
|       |    |                                 | OIML D-SW on        |
|       |    |                                 | software (TC5/SC2). |
|       |    |                                 |                     |
|       |    |                                 | 3\. Even if a       |
|       |    |                                 | separate D-SW       |
|       |    |                                 | document were       |
|       |    |                                 | adopted, there      |
|       |    |                                 | would be a need to  |
|       |    |                                 | transfer its        |
|       |    |                                 | software            |
|       |    |                                 | requirements into   |
|       |    |                                 | the respective      |
|       |    |                                 | instrument-specific |
|       |    |                                 | OIML                |
|       |    |                                 | recommendation.     |
|       |    |                                 |                     |
|       |    |                                 | P- Both phrases are |
|       |    |                                 | also used in the    |
|       |    |                                 | pre-draft document  |
|       |    |                                 | OIML D-SW on        |
|       |    |                                 | software (TC5/SC2). |
+-------+----+---------------------------------+---------------------+
| T.2.8 | CN | > The end of the sentences      | P+                  |
| .1/T. |    | > missed out period (".") in    |                     |
| 2.8.3 |    | > T.2.8.1 and T.2.8.3.          |                     |
+-------+----+---------------------------------+---------------------+
| T.    | CN | > In T.2.8.6, what's the        | Simply speaking, a  |
| 2.8.6 |    | > meaning of "checksum"?        | checksum is the     |
|       |    |                                 | result of a         |
|       |    |                                 | calculation,        |
|       |    |                                 | addition or other   |
|       |    |                                 | logical operation   |
|       |    |                                 | of all bits or      |
|       |    |                                 | bytes of the        |
|       |    |                                 | legally relevant    |
|       |    |                                 | software.           |
+-------+----+---------------------------------+---------------------+
| T.    | UK | > delete ", and".               | P+                  |
| 2.8.6 |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| T.    | UK | In the final sentence after the | P+                  |
| 2.8.7 |    | comma, change to ", the whole   |                     |
|       |    | software is to be considered as |                     |
|       |    | legally relevant."              |                     |
+-------+----+---------------------------------+---------------------+
| T.    | AT | > It could lead to confusion to | see our response    |
| 3.2.3 |    | > have the first regulations of | under 3.4 AT        |
|       |    | > the verification scale        |                     |
|       |    | > interval under "Auxiliary     |                     |
|       |    | > indication devices". Maybe we |                     |
|       |    | > should have a supplementary   |                     |
|       |    | > sentence in 3.4.2 saying "e = |                     |
|       |    | > 1 ´ 10k, 2 ´ 10k, or 5 ´ 10k, |                     |
|       |    | > the index k being a positive  |                     |
|       |    | > or negative whole number or   |                     |
|       |    | > zero." or something like that |                     |
+-------+----+---------------------------------+---------------------+
| T.3.4 | CH | > A parenthesis is not closed   | P+                  |
|       |    | > in T.3.4.                     |                     |
+-------+----+---------------------------------+---------------------+
| T.3.4 | JP | > In the 3^rd^ line of the      | See above           |
|       |    | > sentence, "...device-but..."  |                     |
|       |    | > should be "...device) but"... |                     |
+-------+----+---------------------------------+---------------------+
| T.3.4 | UK | > Replace "\...device-but\..."  | See above           |
|       |    | > with "\...device), but\..."   |                     |
|       |    | >                               | P+                  |
|       |    | > last sentence: Replace        |                     |
|       |    | > "\...possibility to list\..." |                     |
|       |    | > with "\...possibility of      |                     |
|       |    | > listing\...".                 |                     |
+-------+----+---------------------------------+---------------------+
| T.4.6 | UK | > Could be reworded as follows: | P+                  |
|       |    | > "The weighing value that is   |                     |
|       |    | > achieved when the instrument  |                     |
|       |    | > is completely at rest and     |                     |
|       |    | > balanced, with no             |                     |
|       |    | > disturbances affecting the    |                     |
|       |    | > indication".                  |                     |
+-------+----+---------------------------------+---------------------+
| T.    | KR | > Proposed change: The          | P+                  |
| 5.5.1 |    | > indication of an instrument   |                     |
|       |    | > minus the (conventional) true |                     |
|       |    | > value of the corresponding    |                     |
|       |    | > mass                          |                     |
+-------+----+---------------------------------+---------------------+
| T.    | KR | > Proposed change: The error of | P+                  |
| 5.5.2 |    | > an instrument, determined     |                     |
|       |    | > under reference conditions    |                     |
+-------+----+---------------------------------+---------------------+
| T.8   | CH | > Consider moving the index of  | P- This chapter has |
|       |    | > terms defined T.8 at the end  | been moved from the |
|       |    | > of the recommendation in      | end to this         |
|       |    | > order to reduce the size of   | position on an      |
|       |    | > the chapter Terminology which | earlier demand; it  |
|       |    | > became really long.           | should therefore    |
|       |    |                                 | not be moved back   |
|       |    |                                 | again.              |
+-------+----+---------------------------------+---------------------+
| T.8   | CN | Redaction erratum in T.8:       | P+ has been         |
|       |    |                                 | corrected and       |
|       |    | Remote display......T2.2.6      | re-numbered         |
|       |    | shall be revised into Remote    |                     |
|       |    | display......T.2.2.7            |                     |
|       |    |                                 |                     |
|       |    | Terminal ..............T2.2.5   |                     |
|       |    | shall be revised into Terminal  |                     |
|       |    | ..............T.2.2.6           |                     |
|       |    |                                 |                     |
|       |    | Weighing module....T2.2.4 shall |                     |
|       |    | be revised into Weighing module |                     |
|       |    | ....T.2.2.5                     |                     |
+-------+----+---------------------------------+---------------------+
| T.8   | JP | > The section number for        | P+ see above        |
|       |    | > "Remote display" T.2.2.6      |                     |
|       |    | > should be T.2.2.7.            |                     |
+-------+----+---------------------------------+---------------------+
| 2.1   | UK | > Uses the spelling "ton", but  | P+                  |
|       |    | > it should be "**tonne**".     |                     |
|       |    | >                               | P+                  |
|       |    | > In the second sentence,       |                     |
|       |    | > modify the wording such that  |                     |
|       |    | > "... may be used as **the**   |                     |
|       |    | > unit of ..."                  |                     |
+-------+----+---------------------------------+---------------------+
| 2.2   | FR | > The sentence "Loads are       | P+ See 2CD          |
|       |    | > regarded as gross or net      |                     |
|       |    | > load" seems to be misleading. |                     |
|       |    | > We propose to clarify it.     |                     |
+-------+----+---------------------------------+---------------------+
| 2.3   | AU | > 2.3 Principles of the         | P+ However we       |
|       |    | > technical requirements        | suggest a slightly  |
|       |    | >                               | shortened version   |
|       |    | > Include a note:               | added to the second |
|       |    | >                               | para in 2CD, No     |
|       |    | > Note: 'Technical progress'    | 2.3:                |
|       |    | > implies improvement, not all  |                     |
|       |    | > changes should be considered  | "..., and if        |
|       |    | > to be technical progress. The | suitability for use |
|       |    | > intention to allow additional | and appropriate     |
|       |    | > functions and not impede      | metrological        |
|       |    | > technical progress shall      | control is          |
|       |    | > always be subservient to the  | ensured."           |
|       |    | > need to comply with these     |                     |
|       |    | > requirements, ensure          |                     |
|       |    | > suitability for use and       |                     |
|       |    | > satisfactory performance, and |                     |
|       |    | > the need to maintain          |                     |
|       |    | > appropriate legal             |                     |
|       |    | > metrological control.         |                     |
|       |    | >                               |                     |
|       |    | > *Explanation:We feel that     |                     |
|       |    | > this clause is being used to  |                     |
|       |    | > justify the approval of       |                     |
|       |    | > equipment which does not meet |                     |
|       |    | > basic requirements of         |                     |
|       |    | > suitability of use, and is    |                     |
|       |    | > underpinning a reluctance to  |                     |
|       |    | > fail equipment which has      |                     |
|       |    | > implemented undesirable       |                     |
|       |    | > technical changes either      |                     |
|       |    | > without consideration of such |                     |
|       |    | > basic principles, or on the   |                     |
|       |    | > basis of other considerations |                     |
|       |    | > (cost, time) which are not    |                     |
|       |    | > related to 'technical         |                     |
|       |    | > progress', but which instead  |                     |
|       |    | > represent technical           |                     |
|       |    | > regression .*                 |                     |
+-------+----+---------------------------------+---------------------+
| 2.3   | UK | > In the first sentence replace | P+                  |
|       |    | > "completed" with              |                     |
|       |    | > "supplemented".               |                     |
+-------+----+---------------------------------+---------------------+
| 3.2   | CA | Classification of Instruments   | P+ See new wording  |
|       |    |                                 | in 2CD              |
|       |    | Canada still has concern with   |                     |
|       |    | the terminology used in this    | See our response    |
|       |    | section.                        | under T.1.2.13      |
|       |    |                                 |                     |
|       |    | The minimum capacity is reduced | P+ We understand    |
|       |    | to 5e for instruments in        | that your concern   |
|       |    |                                 | has been addressed  |
|       |    | -   class II and III *used      | by changing the     |
|       |    |     strictly for* determining a | wording to          |
|       |    |     transport tariff and        | "weighing waste     |
|       |    |                                 | material"; in       |
|       |    | -   class III and IIII for      | addition we'd like  |
|       |    |     ~~garbage weighers~~        | to remind you that  |
|       |    |     *weighing waste material.*  | each member country |
|       |    |                                 | has the freedom to  |
|       |    | New concern with 'grading       | define for special  |
|       |    | instrument' see T.1.2.13 above. | applications        |
|       |    |                                 | special national    |
|       |    | Further suggest that the        | regulations         |
|       |    | wording on the note be amended  | deviating from R76. |
|       |    | as shown. This would allow for  |                     |
|       |    | all types of waste, whether     |                     |
|       |    | residential garbage or          |                     |
|       |    | commercial waste. Does this     |                     |
|       |    | include recyclables? Canadian   |                     |
|       |    | requirements include            |                     |
|       |    | recyclables, except             |                     |
|       |    | differentiate between ferrous   |                     |
|       |    | and non-ferrous metals.         |                     |
|       |    | Non-ferrous have higher minimum |                     |
|       |    | capacity (weighment) than       |                     |
|       |    | general waste due to their      |                     |
|       |    | higher value.                   |                     |
|       |    |                                 |                     |
|       |    | > General Comment -- the        |                     |
|       |    | > minimum capacities expressed  |                     |
|       |    | > in R76 are much smaller than  |                     |
|       |    | > Canadian requirements         |                     |
|       |    | > (Canadian are stricter). We   |                     |
|       |    | > like the R76 approach, but    |                     |
|       |    | > question how to ensure a      |                     |
|       |    | > correct class of device is    |                     |
|       |    | > used for a given application? |                     |
|       |    | >                               |                     |
|       |    | > See also T.1.2.13 above       |                     |
+-------+----+---------------------------------+---------------------+
| 3.2   | JP | > What is the reason for the    | There must be some  |
|       |    | > specification that the        | good metrological   |
|       |    | > minimum capacity could be     | reasons for         |
|       |    | > reduced to 5e for grading     | reducing Min for    |
|       |    | > instruments? There could be   | grading             |
|       |    | > some corresponding cases with | instruments,        |
|       |    | > other types of instruments.   | because this        |
|       |    | > Is it allow to decide         | exception has also  |
|       |    | > flexibly the capacity in      | been put into the   |
|       |    | > accordance with specific      | new (revised) OIML  |
|       |    | > applications of instruments?  | R51. The wording in |
|       |    |                                 | 3.2 is in line with |
|       |    |                                 | the latest draft    |
|       |    |                                 | revision R51-1 (No  |
|       |    |                                 | 2.2.2).             |
+-------+----+---------------------------------+---------------------+
| 3.2   | UK | > Is the sentence beginning     | Yes, it does.       |
|       |    | > with "The minimum capacity is |                     |
|       |    | > reduced to 5 e ..."           |                     |
|       |    | > applicable to all accuracy    |                     |
|       |    | > classes?                      |                     |
+-------+----+---------------------------------+---------------------+
| 3.3.3 | C  | > The direction of the signs of | P+ New example:     |
|       | EC | > table 4 are wrong and have to |                     |
|       | IP | > be modified. (the smaller     | P+ for m = 0 g to   |
|       |    | > sign has to be a larger sign) | 500 g mpe = 0,5     |
|       |    | >                               | e~1~ = 0,5 g\       |
|       |    | > The new example should also   | for m [\>           |
|       |    | > define any mpe for the        | 500]{.mark} g to    |
|       |    | > transition regions. Now there | 2000 g mpe = 1 e~1~ |
|       |    | > seem to be not any mpe for    | = 1 g\              |
|       |    | > load between 2000g to 2002g,  | for m [\>           |
|       |    | > 5000g to 5010g and so on.     | 2000]{.mark} g to   |
|       |    |                                 | 4000 g mpe = 1 e~2~ |
|       |    |                                 | = 2 g\              |
|       |    |                                 | for m [\>           |
|       |    |                                 | 4000]{.mark} g to   |
|       |    |                                 | 5000 g mpe = 1,5    |
|       |    |                                 | e~2~ = 3 g\         |
|       |    |                                 | for m [\>           |
|       |    |                                 | 5000]{.mark} g to   |
|       |    |                                 | 15000 g mpe = 1     |
|       |    |                                 | e~3~ = 10 g         |
+-------+----+---------------------------------+---------------------+
| 3.3.3 | CH | > In order to shorten the       | P- For two reasons  |
|       |    | > recommendation, consider      | we think that this  |
|       |    | > moving examples (like in      | will not find the   |
|       |    | > 3.3.3, 4.6.12) or remarks to  | support of a        |
|       |    | > the selection (like in        | majority of TC9/SC1 |
|       |    | > 3.10.4.5) into an Appendix or | members:\           |
|       |    | > into a separated guide. They  | 1. The              |
|       |    | > are neither metrological nor  | recommendation      |
|       |    | > technical requirements.       | would be shortened  |
|       |    |                                 | only "virtually",   |
|       |    |                                 | 2. the relation of  |
|       |    |                                 | the examples to     |
|       |    |                                 | their context would |
|       |    |                                 | get.                |
+-------+----+---------------------------------+---------------------+
| 3.3.3 | CN | Issue on English abbreviations: | P+ It is made       |
|       |    |                                 | consistent          |
|       |    | > mpe shall be revised into     | throughout R76, but |
|       |    | > MPE. There are 5 places on    | in OIML             |
|       |    | > Page 27, 2 places on Page     | recommendations     |
|       |    | > 113, 3 places on Page 126 and | "mpe" in lower case |
|       |    | > 3 places on Page 128.         | letters is the      |
|       |    |                                 | preferred version.  |
|       |    | Table 4                         |                     |
|       |    |                                 | P+                  |
|       |    | > Class                         |                     |
|       |    | > ![](me                        |                     |
|       |    | dia/image2.jpeg){width="0.35in" |                     |
|       |    | > height="0.2in"}               |                     |
|       |    | > ![](media/image3.jpe          |                     |
|       |    | g){width="0.3798611111111111in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | > ![](m                         |                     |
|       |    | edia/image4.jpeg){width="0.3in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | > ![](me                        |                     |
|       |    | dia/image5.jpeg){width="0.35in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | >                               |                     |
|       |    | > Max~i~/e~i+1~ 50 000 5 000    |                     |
|       |    | > 500 50                        |                     |
|       |    |                                 |                     |
|       |    | Change into                     |                     |
|       |    |                                 |                     |
|       |    | Table 4                         |                     |
|       |    |                                 |                     |
|       |    | > Class                         |                     |
|       |    | > ![](me                        |                     |
|       |    | dia/image2.jpeg){width="0.35in" |                     |
|       |    | > height="0.2in"}               |                     |
|       |    | > ![](media/image3.jpe          |                     |
|       |    | g){width="0.3798611111111111in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | > ![](m                         |                     |
|       |    | edia/image4.jpeg){width="0.3in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | > ![](me                        |                     |
|       |    | dia/image5.jpeg){width="0.35in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.2298611111111111in"} |                     |
|       |    | >                               |                     |
|       |    | > Max~i~/e~i+1~ **≥**50 000     |                     |
|       |    | > **≥** 5 000 **≥** 500 **≥**50 |                     |
+-------+----+---------------------------------+---------------------+
| 3.3.3 | FR | > In table 4, the marks ""      | P+                  |
|       |    | > shall be changed into "".     |                     |
+-------+----+---------------------------------+---------------------+
| 3.3.3 | SI | > (example for a multi-interval | P+                  |
|       |    | > instrument) Change the        |                     |
|       |    | > sentence "The maximum         |                     |
|       |    | > permissible errors on initial |                     |
|       |    | > verification (mpe) (see       |                     |
|       |    | > 3.5.1) for some examples of   |                     |
|       |    | > load are:" to "The maximum    |                     |
|       |    | > permissible errors on initial |                     |
|       |    | > verification (mpe) (see       |                     |
|       |    | > 3.5.1) are:", because the     |                     |
|       |    | > maximum permissible errors    |                     |
|       |    | > for a complete weighing range |                     |
|       |    | > are presented in the example. |                     |
+-------+----+---------------------------------+---------------------+
| 3.4   | AT | > It could lead to confusion to | (see also T.3.2.3   |
|       |    | > have the first regulations of | AT)                 |
|       |    | > the verification scale        |                     |
|       |    | > interval under "Auxiliary     | P+ But we propose a |
|       |    | > indication devices". Maybe we | slightly different  |
|       |    | > should have a supplementary   | addition (see       |
|       |    | > sentence in 3.4.2 saying "e = | reference added to  |
|       |    | > 1 ´ 10k, 2 ´ 10k, or 5 ´ 10k, | 4.2.2.1 in 3.4.2).  |
|       |    | > the index k being a positive  |                     |
|       |    | > or negative whole number or   |                     |
|       |    | > zero." or something like      |                     |
|       |    | > that.                         |                     |
+-------+----+---------------------------------+---------------------+
| 3.4.2 | US | The U.S. requests that language | P+                  |
|       |    | be added that clarifies **which |                     |
|       |    | part of the requirement does    | P+ But reference to |
|       |    | not apply to a Class I          | "tables 5a and 5b"  |
|       |    | instrument with d \< 1 mg,      | (see below)         |
|       |    | where e = 1 mg.** The following |                     |
|       |    | amendment to 3.4.2 represents   | P+                  |
|       |    | the U.S. position about the     |                     |
|       |    | exception language.             | P+ In addition we   |
|       |    |                                 | suggest to add      |
|       |    | 3.4.2 Verification scale        | another column to   |
|       |    | interval                        | table 5b:           |
|       |    |                                 |                     |
|       |    | > The verification scale        | d = \< 0.01 mg / e  |
|       |    | > interval e is determined by   | = 1 mg / e \> 100 d |
|       |    | > the expression:               |                     |
|       |    | >                               |                     |
|       |    | > d \< e ≤ 10 d (see table 5)   |                     |
|       |    | >                               |                     |
|       |    | > e = 10^k^ kg                  |                     |
|       |    | >                               |                     |
|       |    | > k being a positive or         |                     |
|       |    | > negative whole number, or     |                     |
|       |    | > zero.                         |                     |
|       |    | >                               |                     |
|       |    | > Table 5: The values of e,     |                     |
|       |    | > calculated following this     |                     |
|       |    | > rule, are, for example:       |                     |
|       |    | >                               |                     |
|       |    | > d = 0.1 g 0.2 g 0.5 g         |                     |
|       |    | >                               |                     |
|       |    | > e = 1 g 1 g 1 g               |                     |
|       |    | >                               |                     |
|       |    | > e = 10 d 5 d 2 d              |                     |
|       |    | >                               |                     |
|       |    | > This requirement does not     |                     |
|       |    | > apply to an instrument of     |                     |
|       |    | > class                         |                     |
|       |    | > ![](media/image6.jpeg         |                     |
|       |    | ){width="0.34791666666666665in" |                     |
|       |    | >                               |                     |
|       |    | height="0.19444444444444445in"} |                     |
|       |    | > with\                         |                     |
|       |    | > d \< 1 mg, where e = 1 mg,    |                     |
|       |    | > for example:                  |                     |
|       |    | >                               |                     |
|       |    | > d = 0.01 mg 0.02 mg 0.05 mg   |                     |
|       |    | >                               |                     |
|       |    | > e = 1 mg 1 mg 1 mg            |                     |
|       |    | >                               |                     |
|       |    | > e = 100 d 50 d 20 d           |                     |
+-------+----+---------------------------------+---------------------+
| 3.5.1 | UK | Note below table:               | P+                  |
|       |    |                                 |                     |
|       |    | > In this note (and elsewhere   |                     |
|       |    | > in the new additions), the    |                     |
|       |    | > comma has been used as the    |                     |
|       |    | > decimal separator, whereas in |                     |
|       |    | > the existing text the         |                     |
|       |    | > full-stop has been used. This |                     |
|       |    | > should be consistent.         |                     |
+-------+----+---------------------------------+---------------------+
| 3.5.3 | CA | > Unclear as to what this       | It is a basic rule  |
| .2/3. |    | > means?                        | in metrology that   |
| 5.3.3 |    |                                 | the digital         |
|       |    |                                 | rounding error of   |
|       |    |                                 | 0,5e has to be      |
|       |    |                                 | taken into account; |
|       |    |                                 | only if the digital |
|       |    |                                 | rounding error is   |
|       |    |                                 | smaller or equal    |
|       |    |                                 | 0,2e it can be      |
|       |    |                                 | neglected..         |
+-------+----+---------------------------------+---------------------+
| 3.    | CA | > It is not readily apparent    | P- We can still not |
| 6.2.2 |    | > that this test is not         | agree, because of   |
|       |    | > suitable for vehicle scales.  | the note to 3.6.2:  |
|       |    | > It is suggested that the      | It says that if the |
|       |    | > paragraph be prefaced with    | instrument can be   |
|       |    | > the phrase *'subject to       | used in             |
|       |    | > 3.6.2.4'* to clearly indicate | [dif                |
|       |    | > that vehicle scales are       | ferent]{.underline} |
|       |    | > subject to the heavier        | ways, it may be     |
|       |    | > loading pattern.              | appropriate to      |
|       |    | >                               | apply more than one |
|       |    | > P- comment: with the wording  | test. Only for      |
|       |    | > as in the CD1, it would be    | railway scales one  |
|       |    | > expected that both 3.6.2.2    | test acc. to        |
|       |    | > AND 3.6.2.4 would be          | 3.6.2.4 is          |
|       |    | > performed on a vehicle scale. | sufficient.         |
|       |    | > This seems to be excessive?   |                     |
|       |    | > By changing the wording as    |                     |
|       |    | > suggested, it is clear that   |                     |
|       |    | > only 3.6.2.4 need be          |                     |
|       |    | > performed.                    |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | CA | Shows a loading example using   | OK                  |
| 6.2.3 |    | the words "one-tenth". Similar  |                     |
|       |    | sections show fractions using   |                     |
|       |    | numeric form "1/10". This       |                     |
|       |    | should be standardized and      |                     |
|       |    | "1/10" is preferred.            |                     |
|       |    | Consideration should be made to |                     |
|       |    | using decimal form whenever     |                     |
|       |    | possible "0.1".                 |                     |
|       |    |                                 |                     |
|       |    | Canada agrees with Secretariats |                     |
|       |    | response**.**                   |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | FR | > 2^nd^ line : read : "... a    | P+                  |
| 6.2.4 |    | > ~~rolling~~ test load         |                     |
|       |    | > corresponding ...".           |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | CA | We must restate our concern     | We are sure that    |
| 6.2.4 |    | with this section. This load    | there is a          |
|       |    | pattern could be too extreme.   | misunderstanding:   |
|       |    | Canada uses a loading pattern   |                     |
|       |    | for eccentricity testing on     | 3.6.2.4 clearly     |
|       |    | vehicle scales that places the  | supports your       |
|       |    | load across a 'section' (pair   | viewpoint, because  |
|       |    | of load cells on each side of   | it states that "a   |
|       |    | the scale). The maximum loading | test load           |
|       |    | for each section is 75% Max for | corresponding to    |
|       |    | a 2 section scale (4 load       | the usual rolling   |
|       |    | cells) and 50% Max for a scale  | load" shall be      |
|       |    | with 3 or more sections.        | applied! Just in    |
|       |    |                                 | order to avoid      |
|       |    | Consider a 6 section vehicle    | excessive testing   |
|       |    | scale rated at 100 tonnes.      | it also states that |
|       |    | Would it be realistic to assume | this test load      |
|       |    | that each section should be     | [should not         |
|       |    | rated for 80 tonnes, even       | exceed]{.underline} |
|       |    | though the loading in use would | 80% of Max, i.e. it |
|       |    | never approach 80 tonnes for a  | is usually less     |
|       |    | given section? In Canada we     | than 80% of Max, if |
|       |    | would require each section be   | appropriate.        |
|       |    | rated at 50 tonnes minimum. 80  |                     |
|       |    | tonne loading on each section   |                     |
|       |    | of this scale would be          |                     |
|       |    | considered extreme. In          |                     |
|       |    | addition, there is little       |                     |
|       |    | detail as to what 'applied at   |                     |
|       |    | different points on the load    |                     |
|       |    | receptor' actually means. Does  |                     |
|       |    | this mean you could concentrate |                     |
|       |    | 80 tonnes on an end? Prefer to  |                     |
|       |    | have the load applied over      |                     |
|       |    | 'sections -- each group of 2    |                     |
|       |    | load cells)'.                   |                     |
|       |    |                                 |                     |
|       |    | (see also A.4.7.4)              |                     |
|       |    |                                 |                     |
|       |    | > Canadian manufacturers have   |                     |
|       |    | > also indicated concern with   |                     |
|       |    | > this section. 80% loading on  |                     |
|       |    | > a vehicle scale, with no      |                     |
|       |    | > constraints regarding loading |                     |
|       |    | > patterns advising that it     |                     |
|       |    | > could cause immediate and or  |                     |
|       |    | > premature device damage.      |                     |
+-------+----+---------------------------------+---------------------+
| 3.6.3 | UK | > At the end of the sentence,   | P+                  |
|       |    | > use of the word "or" seems to |                     |
|       |    | > imply that indicating and     |                     |
|       |    | > printing devices could be     |                     |
|       |    | > different.                    |                     |
+-------+----+---------------------------------+---------------------+
| 3.7   | NL | > These requirements for the    | See our response    |
|       |    | > [tests standards]{.underline} | under "General"     |
|       |    | > are not a "Metrological       |                     |
|       |    | > requirement" for the          |                     |
|       |    | > [weighing                     |                     |
|       |    | > instrument]{.underline}. So   |                     |
|       |    | > this should be moved to       |                     |
|       |    | > clause 8.                     |                     |
+-------+----+---------------------------------+---------------------+
| 3.7.1 | C  | > For better understanding      | P.  "Tolerance"     |
|       | EC | > please change the wording:    |     would not bring |
|       | IP | >                               |     further         |
|       |    | > "The standard weights or      |     clarification,  |
|       |    | > standard masses used for the  |     because "error" |
|       |    | > type examination or           |     is even used in |
|       |    | > verification of an instrument |     R111.           |
|       |    | > shall principally meet the    |                     |
|       |    | > metrological requirements of  | The relationship    |
|       |    | > OIML R111. They shall not     | between "error" and |
|       |    | > have an ~~error~~ tolerance   | "uncertainty" will  |
|       |    | > greater than 1/3 of the       | certainly be        |
|       |    | > maximum permissible error of  | considered at the   |
|       |    | > the instrument for the        | next but one        |
|       |    | > applied load. If class E2     | revision of R76,    |
|       |    | > equivalent weights or better  | after publication   |
|       |    | > are used as standard weights  | of the new          |
|       |    | > it is allowed that their      | respective OIML     |
|       |    | > uncertainty rather than their | document elaborated |
|       |    | > ~~error~~ tolerance is not    | by TC3/SC5.         |
|       |    | > greater than 1/3 of the       |                     |
|       |    | > maximum permissible error of  |                     |
|       |    | > the instrument for the        |                     |
|       |    | > applied load, provided that   |                     |
|       |    | > the ~~error~~ actual weight   |                     |
|       |    | > value and the estimated       |                     |
|       |    | > long-term stability is taken  |                     |
|       |    | > into account."                |                     |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | AT | > So it is possible to test any | Yes, you are right, |
|       |    | > kind of instrument using this | and we see no       |
|       |    | > procedure? Each accuracy      | problem with this.\ |
|       |    | > class with every capacity?    | Why shouldn't it be |
|       |    | > Even if fraudulent use is     | possible to test    |
|       |    | > quite unlikely, we would      | also low capacity   |
|       |    | > prefer not to have special    | instruments in this |
|       |    | > and high class instruments    | way, when the       |
|       |    | > tested not using standard     | requirements are    |
|       |    | > weights                       | fulfilled? But      |
|       |    |                                 | normally nobody     |
|       |    |                                 | will do this,       |
|       |    |                                 | because it takes    |
|       |    |                                 | too much time.      |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | CA | Substitution of standard        | P+ We hope that     |
|       |    | weights at verification.        | this is clarified   |
|       |    |                                 | by adding the word  |
|       |    | We are still confused by the    | "(application)"     |
|       |    | phrase '... *[the place of      | after "place of     |
|       |    | use']{.underline}* . What is    | use".               |
|       |    | place of use'? Does this        |                     |
|       |    | section apply to instruments    | It applies to both  |
|       |    | tested within a factory or      | types of            |
|       |    | dealers premises? Why           | verification,       |
|       |    | differentiate as to where it is | therefore the       |
|       |    | tested? If it only applies to   | heading is correct. |
|       |    | testing at the traders premise, |                     |
|       |    | then what happens when testing  | P- When drafting    |
|       |    | at the factory?                 | the 1CD we had      |
|       |    |                                 | changed that point  |
|       |    | It is not readily apparent if   | according to a      |
|       |    | this section applies to initial | large number of     |
|       |    | verification, subsequent        | comments opposing   |
|       |    | verification or both?           | our previous        |
|       |    |                                 | proposal in the WD  |
|       |    | > The new wording has           | that was going in   |
|       |    | > eliminated some previous      | your direction. We  |
|       |    | > concerns, but unfortunately   | are convinced that  |
|       |    | > has created some new ones.    | most TC9/SC1        |
|       |    |                                 | members can now     |
|       |    | There is no longer a            | live with 3.7.3 as  |
|       |    | stipulation that 100% standards | it stands, and that |
|       |    | are required for devices up to  | we should accept    |
|       |    | a given size. Using the new     | living with some    |
|       |    | wording, even a small device    | remaining           |
|       |    | could be tested with 50%        | uncertainties.      |
|       |    | standards. Is this what was     |                     |
|       |    | desired? We suggest that 100%   |                     |
|       |    | standards be required for all   |                     |
|       |    | devices up to 1 000 kg.         |                     |
|       |    |                                 |                     |
|       |    | > Canada still has an issue     |                     |
|       |    | > with the potentially large    |                     |
|       |    | > number of standards that      |                     |
|       |    | > could be required to test     |                     |
|       |    | > large scale installations.    |                     |
|       |    | > Scales of 100 000 kg and      |                     |
|       |    | > larger are common throughout  |                     |
|       |    | > North America. Requiring even |                     |
|       |    | > 20 000 kg (20% Max) is a      |                     |
|       |    | > substantial load and may be   |                     |
|       |    | > considered unreasonable. A    |                     |
|       |    | > conventional test truck in    |                     |
|       |    | > North America will carry 10   |                     |
|       |    | > 000 kg of known standards.    |                     |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | FR | 2^nd^ paragraph : read : "...   | P+                  |
|       |    | reduced to 33 % of Max."        |                     |
|       |    |                                 | P- concerning the   |
|       |    | According to our experience     | second part of the  |
|       |    | there is no significant         | proposal (see our   |
|       |    | variation of repeatability at   | response to 3.7.3   |
|       |    | different loads. So we suggest  | CA)                 |
|       |    | a simplification :              |                     |
|       |    | repeatability is to be tested   | P+                  |
|       |    | at only one value between 1/3   |                     |
|       |    | Max and 2/3 Max.                |                     |
|       |    |                                 |                     |
|       |    | > Concerning the quantity of    |                     |
|       |    | > standard mass we prefer 1/3   |                     |
|       |    | > Max instead of 35 %.          |                     |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | PL | We would like to obtain answers | At verification it  |
|       |    | for the following questions:    | is sometimes not    |
|       |    |                                 | possible and/or     |
|       |    | Why only 'at verification' ?    | very expensive to   |
|       |    |                                 | have 100 t or more  |
|       |    | What about type evaluation ?.   | standard weights,   |
|       |    |                                 | therefore this      |
|       |    | Does the same concern loads     | substitution method |
|       |    | below 1 tonne ?                 | is permitted.       |
|       |    |                                 |                     |
|       |    | > Such radical change           | If additional small |
|       |    | > concerning the previous       | deviations occur,   |
|       |    | > version of this draft should  | it will be no       |
|       |    | > be explained.                 | problem, because    |
|       |    |                                 | after the           |
|       |    |                                 | verification the    |
|       |    |                                 | error limits are    |
|       |    |                                 | twice to those on   |
|       |    |                                 | initial             |
|       |    |                                 | verification.       |
|       |    |                                 |                     |
|       |    |                                 | On type evaluation  |
|       |    |                                 | no additional small |
|       |    |                                 | deviations can be   |
|       |    |                                 | accepted, therefore |
|       |    |                                 | this method is not  |
|       |    |                                 | permitted. For      |
|       |    |                                 | clarification we    |
|       |    |                                 | have added a        |
|       |    |                                 | crossreference to   |
|       |    |                                 | 3.7.1 in 8.2.2,     |
|       |    |                                 | 3^rd^ para, and     |
|       |    |                                 | have added a        |
|       |    |                                 | reference to 3.7 in |
|       |    |                                 | 8.3.3 after para    |
|       |    |                                 | "The authority...   |
|       |    |                                 | the tests."         |
|       |    |                                 |                     |
|       |    |                                 | Yes, it is possible |
|       |    |                                 | to test also low    |
|       |    |                                 | capacity            |
|       |    |                                 | instruments in this |
|       |    |                                 | way, when the       |
|       |    |                                 | requirements are    |
|       |    |                                 | fulfilled. But      |
|       |    |                                 | nobody will do      |
|       |    |                                 | this, because it    |
|       |    |                                 | takes too much      |
|       |    |                                 | time.               |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | RO | > The quotation marks should be | P+                  |
|       |    | > deleted in the first          |                     |
|       |    | > paragraph.                    |                     |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | SI | > Is there any special reason   | At verification it  |
|       |    | > to limit the use of the       | is sometimes not    |
|       |    | > substitution load only to the | possible and/or     |
|       |    | > place of use of the           | very expensive to   |
|       |    | > instrument?                   | have 100 t or more  |
|       |    |                                 | standard weights,   |
|       |    |                                 | therefore this      |
|       |    |                                 | substitution method |
|       |    |                                 | is permitted.       |
|       |    |                                 |                     |
|       |    |                                 | If additional small |
|       |    |                                 | deviations occur,   |
|       |    |                                 | it will be no       |
|       |    |                                 | problem, because    |
|       |    |                                 | after the           |
|       |    |                                 | verification the    |
|       |    |                                 | error limits are    |
|       |    |                                 | twice to those on   |
|       |    |                                 | initial             |
|       |    |                                 | verification.       |
+-------+----+---------------------------------+---------------------+
| 3.7.3 | UK | > Delete the inverted commas at | P+                  |
|       |    | > the end of the first sentence |                     |
|       |    | >                               | P+ We propose:\     |
|       |    | > Re-word the last sentence to  | The repeatability   |
|       |    | > improve the meaning and to    | error has to be     |
|       |    | > clarify that standard weights | determined with a   |
|       |    | > do not need to be used, i.e.  | load (weights or    |
|       |    | > it can be any load, as long   | any other load) of  |
|       |    | > as the same load is used for  | about the value     |
|       |    | > each of the three weighings.  | where the           |
|       |    |                                 | substitution is     |
|       |    |                                 | made, by placing it |
|       |    |                                 | 3 times on the load |
|       |    |                                 | receptor.           |
+-------+----+---------------------------------+---------------------+
| 3.8   | FR | Adding values 1 mg and 5 mg     | P- The reason for   |
|       |    | seems to us unjustified. Why    | this exception is   |
|       |    | NAWIs with a high resolution    | that very unusual   |
|       |    | should not comply with the      | or very small       |
|       |    | general requirements ?          | weights (i.e. 1,4   |
|       |    | Manufacturers who claim they    | mg, 0,01 mg) would  |
|       |    | can obtain such a resolution    | be required which   |
|       |    | shall provide instruments in    | is not practical.   |
|       |    | accordance with same quality of | We have to accept   |
|       |    | others. We propose to delete    | the fact that such  |
|       |    | "but not less than 1 mg" in     | test weights are    |
|       |    | paragraphs 3.8.1 and 3.8.2.1    | neither available   |
|       |    | and the last sentence "This     | nor usable, be this |
|       |    | applies only to instruments     | unjustified or not. |
|       |    | with d 5 mg".                   | See also response   |
|       |    |                                 | to 3.8.2.2 JP       |
+-------+----+---------------------------------+---------------------+
| 3.8.1 | CA | Non self-indicating instruments | P+ "displacement"   |
|       |    |                                 | is OK; consequently |
|       |    | Suggest that wording be changed | it is changed in    |
|       |    | to "....shall produce a visible | 4.3.2, too          |
|       |    | ~~movement~~ *displacement* of  |                     |
|       |    | the indicating element."        |                     |
|       |    |                                 |                     |
|       |    | Canada agrees with the          |                     |
|       |    | Secretariat's response. See     |                     |
|       |    | also 4.3.2                      |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | JP | > For the proposed instruments  | P.  We are sure     |
| 8.2.2 |    | > with 5 mg ≥ d, 0.5 mg weight  |     that there is a |
|       |    | > would be necessary to obtain  |                     |
|       |    | > the changing point of         |    misunderstanding |
|       |    | > indications. In the present   |     concerning      |
|       |    | > situation that R111 does not  |     3.8.2.2 where   |
|       |    | > recommend weight less than 1  |     it is           |
|       |    | > mg, 10 mg ≥ d would be a      |     written:"... d  |
|       |    | > technically consistent        |     ≥ 5 mg ...".    |
|       |    | > inequality.                   |                     |
|       |    |                                 | The reason is that  |
|       |    |                                 | the additional load |
|       |    |                                 | must be 1.4 times   |
|       |    |                                 | of the actual scale |
|       |    |                                 | interval. At d = 5  |
|       |    |                                 | mg the additional   |
|       |    |                                 | load is 1.4 x 5 mg  |
|       |    |                                 | = 7 mg. This can be |
|       |    |                                 | realized with 1 mg  |
|       |    |                                 | weights. But if d   |
|       |    |                                 | is smaller than 5   |
|       |    |                                 | mg, the additional  |
|       |    |                                 | load is 2.8 mg and  |
|       |    |                                 | cannot be realized  |
|       |    |                                 | with 1 mg weights   |
|       |    |                                 | (1.4 x 2 mg = 2.8   |
|       |    |                                 | mg).                |
+-------+----+---------------------------------+---------------------+
| 3.    | ZA | > The result of the requirement | P+ But because also |
| 8.2.2 |    | > shall not only "change the    | a change of 2d is   |
|       |    | > indication" but we believe    | possible, we        |
|       |    | > the indication shall respond  | suggest to change   |
|       |    | > in a specific way therefore   | to "... at          |
|       |    | > we suggest:-Insert: ...at     | equilibrium shall   |
|       |    | > equilibrium shall cause an    | change the          |
|       |    | > unambiguous change in the     | indication          |
|       |    | > indication to the next higher | unambiguously."     |
|       |    | > or lower verification scale   |                     |
|       |    | > interval. ~~the indication.~~ |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | CA | Instruments liable to be        | P+ Has been         |
| 9.1.1 |    | tilted.                         | changed, see also   |
|       |    |                                 | 4.18.1              |
|       |    | The last sentence in section    |                     |
|       |    | (b) reads in part:              |                     |
|       |    |                                 |                     |
|       |    | "(b)...if the limiting value of |                     |
|       |    | tilting has been ~~reached or~~ |                     |
|       |    | exceeded." The *words reached   |                     |
|       |    | or* should be struck out and    |                     |
|       |    | only *exceeded* left in. If a   |                     |
|       |    | manufacturer specifies a        |                     |
|       |    | limiting value of tilting, this |                     |
|       |    | would seem to indicate that the |                     |
|       |    | device is capable of working at |                     |
|       |    | this point (reached), but not   |                     |
|       |    | beyond (exceeded).              |                     |
|       |    |                                 |                     |
|       |    | **Canada agrees with            |                     |
|       |    | Secretariat's response. Similar |                     |
|       |    | change also required in         |                     |
|       |    | 4.18.1**                        |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | FR | > **Paragraph a), note :***.*   | P+                  |
| 9.1.1 |    | > We propose to modify the      |                     |
|       |    | > whole note as follows : "If   | P- We think the     |
|       |    | > technical reasons forbid the  | present wording is  |
|       |    | > level indicator to be fixed   | sufficient.         |
|       |    | > in a visible place, it can be |                     |
|       |    | > accepted to install it below  |                     |
|       |    | > the load receptor in a place  |                     |
|       |    | > representative for the tilt   |                     |
|       |    | > sensitive part".              |                     |
|       |    | >                               |                     |
|       |    | > **Paragraph b) :**            |                     |
|       |    |                                 |                     |
|       |    | The compensation by the         |                     |
|       |    | automatic tilt sensor shall be  |                     |
|       |    | possible only if actually       |                     |
|       |    | related to the tilting.         |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | NL | > 1^st^ paragraph: "*the        | P- We cannot        |
| 9.1.1 |    | > influence of tilting shall be | understand why this |
|       |    | > determined*" (**type test     | should not be a     |
|       |    | > and/or verification?**) is    | requirement. It     |
|       |    | > not a requirement, so this    | must therefore      |
|       |    | > should be moved to clause 8.  | remain in Chapter 3 |
|       |    | >                               | "Metrological       |
|       |    | > 3.9.1.1 a): Delete the Note:  | Requirements". Also |
|       |    | > *"If technical ... "*         | your proposal to    |
|       |    |                                 | add "(type test     |
|       |    | Our previous comment is still   | and/or              |
|       |    | valid: This is not necessary    | verification)"      |
|       |    | and is likely to be misused. In | cannot be accepted  |
|       |    | our experience of type-approval | because the tilt    |
|       |    | testing we have always found it | test has never been |
|       |    | is technically possible to make | included in the     |
|       |    | the level indicator visible.    | list of tests under |
|       |    |                                 | 8.3.3.              |
|       |    | > And this requirement should   |                     |
|       |    | > be taken into account by the  | P- This item has    |
|       |    | > manufacturer in the design    | been introduced on  |
|       |    | > stage.                        | demand of many      |
|       |    |                                 | TC9/SC1 members.    |
+-------+----+---------------------------------+---------------------+
| 3.    | SI | > a): It is not clear for us,   | P+ Proposal to a):  |
| 9.1.1 |    | > when the limiting value of    |                     |
|       |    | > the level indicator is        | "... the limiting   |
|       |    | > reached: when the edge of the | value of tilting is |
|       |    | > bubble touches the ring, when | defined by a        |
|       |    | > the centre of the bubble      | marking (e.g. a     |
|       |    | > reaches the ring or when the  | ring) on the level  |
|       |    | > bubble is more or less        | indicator which     |
|       |    | > outside the ring. An          | shows that the      |
|       |    | > additional clarification in   | maximum permissible |
|       |    | > the text can be helpful.      | tilt has been       |
|       |    |                                 | [~~reached          |
|       |    |                                 | or~~]{.mark}        |
|       |    |                                 | exceeded when the   |
|       |    |                                 | bubble is displaced |
|       |    |                                 | from a central      |
|       |    |                                 | position [and the   |
|       |    |                                 | edge touches the    |
|       |    |                                 | marking]{.mark}.    |
|       |    |                                 | The limiting value  |
|       |    |                                 | of the level        |
|       |    |                                 | indicator shall be  |
|       |    |                                 | obvious, so that    |
|       |    |                                 | tilting is easily   |
|       |    |                                 | noticed."           |
+-------+----+---------------------------------+---------------------+
| 3.    | UK | > In the first sentence change  | P+                  |
| 9.1.1 |    | > the phrase "a. through d." to |                     |
|       |    | > "Sections a. to d."           | P+                  |
|       |    | >                               |                     |
|       |    | > d\) The phrase "In case       |                     |
|       |    | > of\..." appears twice in the  |                     |
|       |    | > last sentence. It might be    |                     |
|       |    | > better as "In the case        |                     |
|       |    | > of\..." or just "If\..."      |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | CA | Suggested editorial change in   | P+                  |
| 9.1.2 |    | the first item -- Class I       |                     |
|       |    | instruments must be fitted with | P+                  |
|       |    | a leveling device and a level   |                     |
|       |    | indicator, but these need not   |                     |
|       |    | be tested. ~~, because these    |                     |
|       |    | instruments require special     |                     |
|       |    | environmental and installation  |                     |
|       |    | conditions and skilled          |                     |
|       |    | operating staff anyway.~~       |                     |
|       |    |                                 |                     |
|       |    | The additional information is   |                     |
|       |    | speculative and not required.   |                     |
|       |    |                                 |                     |
|       |    | Add the word 'these' to the     |                     |
|       |    | sentence to ensure it is clear  |                     |
|       |    | that only the levelling         |                     |
|       |    | equipment need not be tested.   |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | US | Delete "anyway" as follows:     | P+                  |
| 9.1.2 |    |                                 |                     |
|       |    | > Class                         |                     |
|       |    | > ![](media/image6.jpeg         |                     |
|       |    | ){width="0.34791666666666665in" |                     |
|       |    | >                               |                     |
|       |    | height="0.19444444444444445in"} |                     |
|       |    | > instruments must be fitted    |                     |
|       |    | > with a levelling device and a |                     |
|       |    | > level indicator but need not  |                     |
|       |    | > be tested, because these      |                     |
|       |    | > instruments require special   |                     |
|       |    | > environmental and             |                     |
|       |    | > installation conditions and   |                     |
|       |    | > skilled operating staff       |                     |
|       |    | > ~~anyway~~.                   |                     |
+-------+----+---------------------------------+---------------------+
| 3.9.3 | NL | > This is not in line with D11  | See also A.5.4.2 NL |
|       |    | > for battery operated          |                     |
|       |    | > instruments                   | P+ see 2CD, new     |
|       |    | >                               | differentiation     |
|       |    | > For the normal (disposable)   | between "disposable |
|       |    | > batteries, we do not see any  | batteries" and      |
|       |    | > justification for requiring   | "rechargeable       |
|       |    | > 1,2 *U* for battery supply.   | batteries"          |
|       |    |                                 | according to D11    |
+-------+----+---------------------------------+---------------------+
| 3.9.3 | ZA | 3.9.3 refers to "between the    | P+ You are right,   |
|       |    | lower and upper limit of the    | "no marking" does   |
|       |    | nominal voltage **marked** on   | not automatically   |
|       |    | the instrument (U)....."        | mean "no testing",  |
|       |    |                                 | therefore we agree  |
|       |    | In clause 7 there is not a      | with your           |
|       |    | requirement for the nominal     | suggestion a).      |
|       |    | voltage to be marked.           |                     |
|       |    |                                 |                     |
|       |    | Does this mean you don't have   |                     |
|       |    | to do the test if it is not     |                     |
|       |    | marked?                         |                     |
|       |    |                                 |                     |
|       |    | Suggestion:                     |                     |
|       |    |                                 |                     |
|       |    | a\) ....and upper limit of the  |                     |
|       |    | nominal voltage ~~marked on~~   |                     |
|       |    | of the instrument (U)....       |                     |
|       |    |                                 |                     |
|       |    | or                              |                     |
|       |    |                                 |                     |
|       |    | b\) In clause 7 make it         |                     |
|       |    | compulsory if applicable for    |                     |
|       |    | the nominal voltage (U) to be   |                     |
|       |    | marked on the instrument.       |                     |
+-------+----+---------------------------------+---------------------+
| 3.9.3 | UK | > Modify this Section in line   | P+ see 2CD          |
|       |    | > with Section A.5.4.1 to       |                     |
|       |    | > clarify what happens when a   |                     |
|       |    | > voltage range is specified.   |                     |
+-------+----+---------------------------------+---------------------+
| 3.    | KR | > Put a full stop after 0.5     | P+                  |
| 9.4.2 |    | > e~i~ :                        |                     |
|       |    | >                               | P+                  |
|       |    | > ...the deviation on returning |                     |
|       |    | > to zero from Max~i~ shall not |                     |
|       |    | > exceed 0.5 e~i~. Furthermore, |                     |
|       |    | > ...                           |                     |
+-------+----+---------------------------------+---------------------+
| 3.9.5 | CA | Other influence quantities and  | []{.mark}           |
|       |    | restraints.                     |                     |
|       |    |                                 | P+ Editorial:\      |
|       |    | The example at the end of this  | "Clause" is         |
|       |    | section references clauses 3    | replaced by the     |
|       |    | and 4 although these clauses do | more appropriate    |
|       |    | not appear to exist. Is there   | term "Chapter" in   |
|       |    | an issue with numbering in this | the entire          |
|       |    | section?                        | document. (Here     |
|       |    |                                 | Chapters 3 and 4    |
|       |    | Canada agrees with              | are meant)          |
|       |    | Secretariat's response --       |                     |
|       |    | 'Chapter 3 and 4' is better     | P+ We think the     |
|       |    | than 'Clause 3 and 4'.          | note is very        |
|       |    |                                 | important. 10000e   |
|       |    | > Although we agree with adding | and e=10 kg are     |
|       |    | > *'In general'* to the         | extremely critical  |
|       |    | > paragraph, we would prefer to | for unprotected     |
|       |    | > see reference to 3000d        | outdoor             |
|       |    | > removed from final version of | weighbridges,       |
|       |    | > recommendation. Let device    | because external    |
|       |    | > performance be the            | influences such as  |
|       |    | > determining factor.           | wind and rain may   |
|       |    | > Specifying 3000d is           | have a big          |
|       |    | > contradictory to the Device   | influence on the    |
|       |    | > Class Table 3.                | weighing result.    |
|       |    |                                 | Therefore we        |
|       |    |                                 | suggest to change   |
|       |    |                                 | the wording (refer  |
|       |    |                                 | to the 2CD).        |
+-------+----+---------------------------------+---------------------+
| 3.9.5 | UK | Note at end:                    | P+ Has been         |
|       |    |                                 | clarified, see our  |
|       |    | > Clarify that "clauses 3 and   | response to 3.9.5   |
|       |    | > 4" are "Section 3             | CA                  |
|       |    | > Metrological requirements"    |                     |
|       |    | > and "Section 4 Technical      |                     |
|       |    | > requirements ..."             |                     |
+-------+----+---------------------------------+---------------------+
| 3.9.5 | US | 2^nd^ paragraph "Note."         | P+ See our response |
|       |    |                                 | to 3.9.5 CA         |
|       |    | The U.S. agrees with the NL     |                     |
|       |    | comments that the paragraph     |                     |
|       |    | could be confused as a strict   |                     |
|       |    | requirement. Since all          |                     |
|       |    | instruments shall comply with   |                     |
|       |    | clauses 3 and 4 installed in    |                     |
|       |    | customary and suitable          |                     |
|       |    | locations, the U.S. recommends  |                     |
|       |    | deleting the examples from the  |                     |
|       |    | note as follows:                |                     |
|       |    |                                 |                     |
|       |    | > Note: Instruments installed   |                     |
|       |    | > outdoors without suitable     |                     |
|       |    | > protection against            |                     |
|       |    | > atmospheric conditions may    |                     |
|       |    | > normally not comply with the  |                     |
|       |    | > requirements of clauses 3 and |                     |
|       |    | > 4 if the number of            |                     |
|       |    | > verification scale intervals  |                     |
|       |    | > n is relatively great. (I~~n  |                     |
|       |    | > general, a value of n = 3 000 |                     |
|       |    | > should not be exceeded.       |                     |
|       |    | > Furthermore for road or rail  |                     |
|       |    | > weighbridges the verification |                     |
|       |    | > scale interval should not be  |                     |
|       |    | > less than 10 kg).~~ These     |                     |
|       |    | > requirements ~~limits~~       |                     |
|       |    | > should also apply to each     |                     |
|       |    | > weighing range of             |                     |
|       |    | > combinations of instruments   |                     |
|       |    | > or of multiple range          |                     |
|       |    | > instruments or to each        |                     |
|       |    | > partial weighing range of     |                     |
|       |    | > multi-interval instruments.   |                     |
+-------+----+---------------------------------+---------------------+
| 3.10  | NL | > These "Type evaluation tests  | Please refer to our |
|       |    | > and examinations" are no      | response under      |
|       |    | > "Metrological requirements"   | "General" NL        |
|       |    | > for the weighing instrument.  |                     |
|       |    | >                               |                     |
|       |    | > So this should be moved to    |                     |
|       |    | > clause 8                      |                     |
+-------+----+---------------------------------+---------------------+
| 3     | SI | > While C.4.2 defines the       | P- We think that    |
| .10.1 |    | > content of the test report    | this is a           |
|       |    | > for indicators and D.4.2 the  | misunderstanding:\  |
|       |    | > content of the report for     | Complete            |
|       |    | > weighing modules, there are   | instruments are     |
|       |    | > no requirements defined for   | state of the art    |
|       |    | > the content of OIML           | since 1993 and      |
|       |    | > certificate for complete      | normally the entire |
|       |    | > instrument. Required relevant | R76-2 applies to    |
|       |    | > information can be defined in | complete            |
|       |    | > 3.10.1.                       | instruments. The    |
|       |    |                                 | reason for defining |
|       |    |                                 | the content for     |
|       |    |                                 | modules is that R76 |
|       |    |                                 | should provide      |
|       |    |                                 | clear rules which   |
|       |    |                                 | requirements should |
|       |    |                                 | be selected and     |
|       |    |                                 | which need not be   |
|       |    |                                 | considered.         |
+-------+----+---------------------------------+---------------------+
| 3     | UK | > "Upon type evaluation \..."   | P+                  |
| .10.1 |    | > would be better as "For type  |                     |
|       |    | > evaluation\..."               |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | CN | Issue on creep influence (Table | P- Considering the  |
| 0.2.1 |    | 7)                              | serious             |
|       |    |                                 | consequences of     |
|       |    | Load receptor is one of three   | such a change we    |
|       |    | main parts same as load cell    | very much recommend |
|       |    | and indicator. Load receptor is | to keep the         |
|       |    | mainly made of metal material.  | regulation as it    |
|       |    | Any structural member made of   | is. This is         |
|       |    | metal material has creep        | supported by the    |
|       |    | problem. Creep not only         | fact that no        |
|       |    | influences load cell, but also  | [s                  |
|       |    | influences metal structure. In  | erious]{.underline} |
|       |    | most instances, influence       | problems are known  |
|       |    | degree on metal structure is    | with the present    |
|       |    | larger than that on load cell.  | regulation which is |
|       |    |                                 | state of the art    |
|       |    | And 2.3 3.10.2.1 mentions that: | since many years.   |
|       |    | for mechanical structures such  |                     |
|       |    | as weighbridges, load           | P- We fully         |
|       |    | transmitting devices and        | understand your     |
|       |    | mechanical or electrical        | point but we think  |
|       |    | connecting elements evidently   | that at type        |
|       |    | designed and manufactured       | approval it is not  |
|       |    | according to sound engineering  | necessary to        |
|       |    | practice, an overall fraction   | introduce such a    |
|       |    | p~i~ = 0.5 may be applied       | special test,       |
|       |    | without any test.               | because at initial  |
|       |    |                                 | verification each   |
|       |    | > It is recommended that when   | [co                 |
|       |    | > considering the distribution  | mplete]{.underline} |
|       |    | > of creep factor p~i~ of       | individual          |
|       |    | > weighing instrument with      | instrument is       |
|       |    | > typical modules, p~i~ = 0.8   | tested - among      |
|       |    | > for load cell p~i~ = 0.5 for  | others - for        |
|       |    | > connecting part.              | weighing            |
|       |    | >                               | performance and     |
|       |    | > For electronic weighing       | eccentric loading   |
|       |    | > instruments with several load | (see No 8.3.3). We  |
|       |    | > cells (more than one), it is  | should not forbid   |
|       |    | > required that load cells have | additional          |
|       |    | > basically equal linear error. | linearization of    |
|       |    | > In the type approval test,    | the complete        |
|       |    | > the test about linearity of   | instrument by the   |
|       |    | > each load cell should be      | software of the     |
|       |    | > added for them. In electronic | indicator under the |
|       |    | > weighing instruments with     | modular concept.    |
|       |    | > several load cells, the       |                     |
|       |    | > consistence of linearity of   |                     |
|       |    | > each load cell can make the   |                     |
|       |    | > error of weighing instruments |                     |
|       |    | > be linearly corrected or      |                     |
|       |    | > calibrated by the display of  |                     |
|       |    | > weighing instruments, or else |                     |
|       |    | > it is hard to do it. For the  |                     |
|       |    | > producer of load cells, it is |                     |
|       |    | > required that each load cell  |                     |
|       |    | > have the data of their linear |                     |
|       |    | > error to select correctly     |                     |
|       |    | > them in the process of fit of |                     |
|       |    | > weighing instruments.         |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | NL | > *"OIML* certificates *for     | We fully agree, and |
| 0.2.4 |    | > modules must be clearly       | we hope to receive  |
|       |    | > distinguishable from OIML     | support by the BIML |
|       |    | > certificates for complete     | (see 1CD, page 4,   |
|       |    | > instruments."*                | question 3).        |
|       |    | >                               |                     |
|       |    | > Please indicate how (with an  |                     |
|       |    | > example or definition of      |                     |
|       |    | > titles)                       |                     |
|       |    | >                               |                     |
|       |    | > And as this is not a          |                     |
|       |    | > requirement for the           |                     |
|       |    | > instrument (module), this     |                     |
|       |    | > should be moved to 8 or to a  |                     |
|       |    | > new annex with format(s) for  |                     |
|       |    | > the OIML Certificate(s).      |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | UK | > Add comma after third bullet  | P+                  |
| 0.2.4 |    | > point (first and second       |                     |
|       |    | > bullet points have commas,    |                     |
|       |    | > and fourth does not need      |                     |
|       |    | > one.)                         |                     |
+-------+----+---------------------------------+---------------------+
| 3     | UK | second paragraph:               | P+                  |
| .10.3 |    |                                 |                     |
|       |    | > "They need neither be         |                     |
|       |    | > tested\..." should be "They   |                     |
|       |    | > need not be tested\...", to   |                     |
|       |    | > be the same as in Section     |                     |
|       |    | > 3.10.2.2.                     |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | KR | > Proposed change: ....see      | P+ yes, but "of     |
| 0.4.1 |    | > example in acceptable         | 3.10.4.5"           |
|       |    | > solution of 3.10.2.1          |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | UK | > Use of the term "highest      | P+                  |
| 0.4.1 |    | > metrological characteristics" |                     |
|       |    | > can be mis-leading. May be    |                     |
|       |    | > better to use the term "most  |                     |
|       |    | > sensitive"?                   |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | NO | -   The ratio between the       | This proposal is    |
| 0.4.2 |    |     tested capacities [shall    | oriented at OIML    |
|       |    |     not]{.mark} exceed 10.      | R60. The reasoning  |
|       |    |                                 | is:\                |
|       |    | Why do you choose 10? Could you | If the ratio is ≤10 |
|       |    | comment it?                     | it is possible to   |
|       |    |                                 | interpolate to the  |
|       |    | > Their capacities (Max) [are   | variants in         |
|       |    | > not]{.mark} more than 5 times | between. If the     |
|       |    | > above the largest capacity    | ratio is \>10 the   |
|       |    | > tested. Where did you get 5   | [interpo            |
|       |    | > from and why? Could you       | lation]{.underline} |
|       |    | > comment it?                   | is becoming         |
|       |    |                                 | critical because    |
|       |    |                                 | the mechanical      |
|       |    |                                 | dimensions would    |
|       |    |                                 | change too much.    |
|       |    |                                 |                     |
|       |    |                                 | [Extrapo            |
|       |    |                                 | lation]{.underline} |
|       |    |                                 | is considered more  |
|       |    |                                 | critical, therefore |
|       |    |                                 | only a factor up to |
|       |    |                                 | 5 is acceptable,    |
|       |    |                                 | but not more.       |
+-------+----+---------------------------------+---------------------+
| 3.1   | ZA | > Last sentence: "If the        | It means, for       |
| 0.4.2 |    | > metrological characteristics  | instance, that if   |
|       |    | > are lower this factor may be  | an EUT has been     |
|       |    | > higher" We have problems to   | tested with n =     |
|       |    | > understand or interpret this  | 6000 and the        |
|       |    | > sentence. What does this      | variants have only  |
|       |    | > mean?                         | n = 3000, the Max   |
|       |    |                                 | values of these     |
|       |    |                                 | variants may exceed |
|       |    |                                 | the factor 5, i.e.  |
|       |    |                                 | the factor may then |
|       |    |                                 | be 10.              |
+-------+----+---------------------------------+---------------------+
| 3.1   | UK | > The final sentence of the     | P+ Please refer to  |
| 0.4.2 |    | > final bullet point needs to   | the 2CD.            |
|       |    | > clarified, i.e. what is lower |                     |
|       |    | > and what is higher. At        |                     |
|       |    | > present it is too ambiguous.  |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | NL | > This sub-clauses describes    | See our response    |
| 0.4.4 |    | > requirements for tests        | under "General" NL  |
|       |    | > (**type tests or              |                     |
|       |    | > verification?**); not for the |                     |
|       |    | > instruments. So this should   |                     |
|       |    | > be moved to clause 8          |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | US | The paragraphs should be        | P+ see 2CD          |
| 0.4.4 |    | formatted to list the examples  |                     |
|       |    | of other metrologically         |                     |
|       |    | relevant and non-relevant       |                     |
|       |    | features similar to 3.10.4.5    |                     |
|       |    | Summary of Metrological         |                     |
|       |    | Characteristics.                |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | CH | > In order to shorten the       | P- See our response |
| 0.4.5 |    | > recommendation, consider      | under 3.3.3 and     |
|       |    | > moving examples (like in      | 4.6.12 CH           |
|       |    | > 3.3.3, 4.6.12) or remarks to  |                     |
|       |    | > the selection (like in        |                     |
|       |    | > 3.10.4.5) into an Appendix or |                     |
|       |    | > into a separated guide. They  |                     |
|       |    | > are neither metrological nor  |                     |
|       |    | > technical requirements.       |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | CN | Issue on class symbol:          | P+ changed in the   |
| 0.4.5 |    |                                 | whole 2CD           |
|       |    | > II and III shall be revised   |                     |
|       |    | > into                          |                     |
|       |    | > ![](medi                      |                     |
|       |    | a/image3.jpeg){width="0.3125in" |                     |
|       |    | >                               |                     |
|       |    |  height="0.1909722222222222in"} |                     |
|       |    | > and                           |                     |
|       |    | > ![](media/image4.jpeg         |                     |
|       |    | ){width="0.24930555555555556in" |                     |
|       |    | >                               |                     |
|       |    | height="0.1909722222222222in"}. |                     |
|       |    | > There are 1 place in Table 8  |                     |
|       |    | > on Page 37, 1 place in Table  |                     |
|       |    | > 9 on Page 38, 2 places on     |                     |
|       |    | > Page 48, 3 places on Page 49, |                     |
|       |    | > 1 place on Page 50, 2 places  |                     |
|       |    | > on Page 126, 2 places on Page |                     |
|       |    | > 127, 2 places on Page 128 and |                     |
|       |    | > 2 places on Page 129.         |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | CN | > Column "Family 1"and"Family   | P+                  |
| 0.4.5 |    | > 2" in table 8 of 3.10.4.5 can |                     |
|       |    | > be changed as follows:        |                     |
|       |    |                                 |                     |
|       |    | <table style="width:100%;">     |                     |
|       |    | <colgroup>                      |                     |
|       |    | <col style="width: 25%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 10%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | </colgroup>                     |                     |
|       |    | <tbody>                         |                     |
|       |    | <tr class="odd">                |                     |
|       |    | <td><strong>Family              |                     |
|       |    | 1</strong></td>                 |                     |
|       |    | <td>Variant</td>                |                     |
|       |    | <td>Max</td>                    |                     |
|       |    | <td>e</td>                      |                     |
|       |    | <td>d</td>                      |                     |
|       |    | <td>n</td>                      |                     |
|       |    | <td>EUT</td>                    |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="even">               |                     |
|       |    | <td rowspan="3"><p>Accuracy     |                     |
|       |    | class II</p>                    |                     |
|       |    | <p>Temperature range:</p>       |                     |
|       |    | <p>10° / 30° C</p></td>         |                     |
|       |    | <td>1.1</td>                    |                     |
|       |    | <td>200 g</td>                  |                     |
|       |    | <td>0,01 g</td>                 |                     |
|       |    | <td>0,001 g</td>                |                     |
|       |    | <td>20000</td>                  |                     |
|       |    | <td></td>                       |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="odd">                |                     |
|       |    | <td>1.2</td>                    |                     |
|       |    | <td>400 g</td>                  |                     |
|       |    | <td>0,01 g</td>                 |                     |
|       |    | <td>0,001 g</td>                |                     |
|       |    | <td>40000</td>                  |                     |
|       |    | <td>X</td>                      |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="even">               |                     |
|       |    | <td>1.3</td>                    |                     |
|       |    | <td>2000 g</td>                 |                     |
|       |    | <td>0,05 g</td>                 |                     |
|       |    | <td>0,05 g</td>                 |                     |
|       |    | <td>40000</td>                  |                     |
|       |    | <td></td>                       |                     |
|       |    | </tr>                           |                     |
|       |    | </tbody>                        |                     |
|       |    | </table>                        |                     |
|       |    |                                 |                     |
|       |    | <table style="width:100%;">     |                     |
|       |    | <colgroup>                      |                     |
|       |    | <col style="width: 25%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | <col style="width: 10%" />      |                     |
|       |    | <col style="width: 12%" />      |                     |
|       |    | </colgroup>                     |                     |
|       |    | <tbody>                         |                     |
|       |    | <tr class="odd">                |                     |
|       |    | <td><strong>Family              |                     |
|       |    | 2</strong></td>                 |                     |
|       |    | <td>2.1</td>                    |                     |
|       |    | <td>1,5 kg</td>                 |                     |
|       |    | <td>0,5 g</td>                  |                     |
|       |    | <td>0,5 g</td>                  |                     |
|       |    | <td>3000</td>                   |                     |
|       |    | <td>X</td>                      |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="even">               |                     |
|       |    | <td rowspan="4"><p>Accuracy     |                     |
|       |    | class III</p>                   |                     |
|       |    | <p>Temperature range:</p>       |                     |
|       |    | <p>-10° / 40°C</p></td>         |                     |
|       |    | <td>2.2</td>                    |                     |
|       |    | <td>3 kg</td>                   |                     |
|       |    | <td>1 g</td>                    |                     |
|       |    | <td>1 g</td>                    |                     |
|       |    | <td>3000</td>                   |                     |
|       |    | <td></td>                       |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="odd">                |                     |
|       |    | <td>2.3</td>                    |                     |
|       |    | <td>5 kg</td>                   |                     |
|       |    | <td>2 g</td>                    |                     |
|       |    | <td>2 g</td>                    |                     |
|       |    | <td>2500</td>                   |                     |
|       |    | <td></td>                       |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="even">               |                     |
|       |    | <td>2.4</td>                    |                     |
|       |    | <td>15 kg</td>                  |                     |
|       |    | <td>5 g</td>                    |                     |
|       |    | <td>5 g</td>                    |                     |
|       |    | <td>3000</td>                   |                     |
|       |    | <td>X</td>                      |                     |
|       |    | </tr>                           |                     |
|       |    | <tr class="odd">                |                     |
|       |    | <td>2.5</td>                    |                     |
|       |    | <td>60 kg</td>                  |                     |
|       |    | <td>20 g</td>                   |                     |
|       |    | <td>20 g</td>                   |                     |
|       |    | <td>3000</td>                   |                     |
|       |    | <td></td>                       |                     |
|       |    | </tr>                           |                     |
|       |    | </tbody>                        |                     |
|       |    | </table>                        |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | FR | In Table 9, the Max values 1 g  | This seems to be a  |
| 0.4.5 |    | (family 1) and 50 g (family 2)  | misunderstanding.   |
|       |    | are not specified in the        | We hope it is       |
|       |    | initial application (table 8) : | resolved with our   |
|       |    | These values shall be changed   | additional          |
|       |    | respectively into 200 g and 1,5 | explanation in the  |
|       |    | kg.                             | note under Table 9. |
+-------+----+---------------------------------+---------------------+
| 3.1   | KR | Change table 8 as proposed:     | P+ See 3.10.4.5 CN  |
| 0.4.5 |    |                                 |                     |
|       |    | +-------+----------+--------+   |                     |
|       |    | | F     | Accuracy | 2.1    |   |                     |
|       |    | | amily | class    |        |   |                     |
|       |    | | 2     | III      |        |   |                     |
|       |    | |       |          |        |   |                     |
|       |    | |       | Tem      |        |   |                     |
|       |    | |       | perature |        |   |                     |
|       |    | |       | range:   |        |   |                     |
|       |    | |       |          |        |   |                     |
|       |    | |       | -10°/    |        |   |                     |
|       |    | |       | 40℃      |        |   |                     |
|       |    | +-------+----------+--------+   |                     |
|       |    | |       |          | 2.2    |   |                     |
|       |    | +-------+----------+--------+   |                     |
|       |    | |       |          | 2.3    |   |                     |
|       |    | +-------+----------+--------+   |                     |
|       |    | |       |          | 2.4    |   |                     |
|       |    | +-------+----------+--------+   |                     |
|       |    | |       |          | 2.5    |   |                     |
|       |    | +-------+----------+--------+   |                     |
+-------+----+---------------------------------+---------------------+
| 3.1   | UK | The third bullet point says     | P+ - lowest input   |
| 0.4.5 |    | "for strain gauge load cells    | signal V/e (only    |
|       |    | only", but is it a load cell or | for indicators when |
|       |    | the indicator that is actually  | connecting strain   |
|       |    | being referred to?              | gauge load cells)   |
+-------+----+---------------------------------+---------------------+
| 4     | AU | > 4\. Technical requirements    | P+ as regards the   |
|       |    | > for a self- or                | first part of the   |
|       |    | > semi-self-indicating          | first sentence of   |
|       |    | > instrument                    | clause 4; we        |
|       |    | >                               | suggest, however, a |
|       |    | > Change this to say:           | slightly changed    |
|       |    | >                               | wording: \"The      |
|       |    | > **The following requirements  | following           |
|       |    | > relate to the design and the  | requirements relate |
|       |    | > construction of instruments,  | to the design and   |
|       |    | > and are intended to ensure    | the construction of |
|       |    | > that instruments give correct | instruments, and    |
|       |    | > and unambiguous weighing      | are intended to     |
|       |    | > results (weighing results     | ensure that         |
|       |    | > including all primary         | instruments give    |
|       |    | > indications), under normal    | correct and         |
|       |    | > conditions of use. It may be  | unambiguous         |
|       |    | > expected that instrument      | weighing results    |
|       |    | > users are trained in the      | and other primary   |
|       |    | > proper handling of the        | indicatons, under   |
|       |    | > instrument (with the          | normal conditions   |
|       |    | > exception of self-service     | of use and proper   |
|       |    | > instruments), however the     | handling by         |
|       |    | > equipment shall not           | unskilled users.\"  |
|       |    | > incorporate features which    |                     |
|       |    | > facilitate deliberate fraud,  | P- as regards the   |
|       |    | > or which introduce            | assumption of       |
|       |    | > substantial risk of           | \"unskilled users\" |
|       |    | > inadvertent provision of      | and other proposed  |
|       |    | > incorrect or ambiguous        | changes: In the     |
|       |    | > results.**                    | "old" (1992)        |
|       |    | >                               | version it was      |
|       |    | > **Note: The situation of      | certainly not       |
|       |    | > instruments which are used or | unintentionally     |
|       |    | > intended to be used for       | written "proper     |
|       |    | > trading direct with the       | handling by         |
|       |    | > public are a particularly     | unskilled users".   |
|       |    | > critical category, in which   | We cannot expect    |
|       |    | > the requirement for           | instrument users to |
|       |    | > unambiguous results is to be  | be trained in       |
|       |    | > judged using the criteria of  | proper handling,    |
|       |    | > "would a typical member of    | especially in case  |
|       |    | > the public encountering a     | of class III and    |
|       |    | > transaction using the         | IIII instruments.   |
|       |    | > instrument, consider that the | In addition, clause |
|       |    | > primary indications presented | 4 emphasizes the    |
|       |    | > are clear, unambiguous and of | intention           |
|       |    | > a size suitable for reading   | [not]{.underline}   |
|       |    | > at a typical distance".**     | to prescribe        |
|       |    | >                               | special solutions   |
|       |    | > **It is not intended to       | (except for         |
|       |    | > prescribe solutions, but to   | examples of         |
|       |    | > define appropriate            | \"acceptable        |
|       |    | > functioning and design        | solutions\") but to |
|       |    | > criteria for the              | provide             |
|       |    | > instrument.**                 | requirements for an |
|       |    | >                               | appropriate         |
|       |    | > Certain solutions that have   | [funct              |
|       |    | > been tried over a long period | ioning]{.underline} |
|       |    | > have become accepted; these   | of NAWIs. We doubt  |
|       |    | > solutions are marked          | whether a majority  |
|       |    | > "acceptable solution"; while  | of TC9/SC1 members  |
|       |    | > it is not necessary to adopt  | would agree to a    |
|       |    | > them, they are considered to  | change of clause 4  |
|       |    | > comply with the requirements  | towards the         |
|       |    | > of the applicable provision.  | direction proposed. |
|       |    | >                               | Concerning          |
|       |    | > *Explanation: It is very      | instruments for     |
|       |    | > evident that the requirement  | direct sales to the |
|       |    | > for "unambiguous weighing     | public we fully     |
|       |    | > results under normal          | agree that these    |
|       |    | > conditions of use and proper  | are a critical      |
|       |    | > handling by unskilled users"  | category of         |
|       |    | > is being given insufficient   | instruments, but    |
|       |    | > attention by approval         | this needs not be   |
|       |    | > authorities. We do feel that  | specially addressed |
|       |    | > the requirement implies that  | in clause 4,        |
|       |    | > equipment is designed to be   | because it is       |
|       |    | > able to be used properly by   | obvious by the      |
|       |    | > an unskilled user and feel    | additional chapters |
|       |    | > that this is unrealistic for  | 4.13 and 4.14       |
|       |    | > many types of instrument --   | especially devoted  |
|       |    | > hence we have altered this    | to direct sales     |
|       |    | > aspect. In addition we have   | instruments.        |
|       |    | > included specific mention of  |                     |
|       |    | > the situation of instruments  |                     |
|       |    | > used for trading direct with  |                     |
|       |    | > the public where we are most  |                     |
|       |    | > concerned at the inadequacy   |                     |
|       |    | > (ambiguity and lack of        |                     |
|       |    | > clarity) of the instruments   |                     |
|       |    | > recently being presented for  |                     |
|       |    | > approval. The possibilities   |                     |
|       |    | > presented by technology and   |                     |
|       |    | > allowed by R76 should ensure  |                     |
|       |    | > that the readability and      |                     |
|       |    | > presentation of primary       |                     |
|       |    | > indications is enhanced -- in |                     |
|       |    | > reality the opposite appears  |                     |
|       |    | > to be happening in a          |                     |
|       |    | > substantial number of case.*  |                     |
+-------+----+---------------------------------+---------------------+
| 4     | CN | > We consider that "Hanging     | P- We do not agree, |
|       |    | > (Crane) Instrument " is one   | because             |
|       |    | > of the non-automatic weighing |                     |
|       |    | > instruments. It would be      | 1\. there are       |
|       |    | > specially added in the item   | already special     |
|       |    | > of "Hanging ( Crane )         | precautions for     |
|       |    | > Instrument " in this          | freely suspended    |
|       |    | > recommendation, because of    | instruments (see No |
|       |    | > its testing methods (e.g. EMC | 3.9.1.2 last        |
|       |    | > etc.) differ from general     | hyphen), 2. except  |
|       |    | > non-automatic weighing        | for some tests      |
|       |    | > instruments.                  | (eccentricity and   |
|       |    |                                 | tilting) the same   |
|       |    |                                 | tests are required  |
|       |    |                                 | for them.           |
+-------+----+---------------------------------+---------------------+
| 4.    | AU | > 4.1.1.1. Suitability for      | P+ We propose,      |
| 1.1.1 |    | > application                   | however, a slightly |
|       |    | >                               | shortened "Note" as |
|       |    | > Add a note to this, to say:   | follows:            |
|       |    | >                               |                     |
|       |    | > An instrument shall be        | 'Intended purpose'  |
|       |    | > designed to suit its intended | includes aspects    |
|       |    | > purpose of use.               | such as the nature  |
|       |    | >                               | and needs of the    |
|       |    | > Note: All elements of         | application and     |
|       |    | > 'intended purpose' should be  | environment. Where  |
|       |    | > considered, this should       | the intended        |
|       |    | > include aspects such as the   | purpose needs to be |
|       |    | > nature and needs of the user  | restricted, a       |
|       |    | > (and customer), environment   | marking stating     |
|       |    | > (e.g. an instrument with a    | such restriction    |
|       |    | > temperature range of 10°C to  | may be required     |
|       |    | > 40°C would not be suitable if | according to        |
|       |    | > its intended purpose was meat | national            |
|       |    | > packaging). Where the         | regulation.         |
|       |    | > intended purpose needs to be  |                     |
|       |    | > restricted, a marking stating |                     |
|       |    | > such restriction may be       |                     |
|       |    | > required according to         |                     |
|       |    | > national regulation.          |                     |
|       |    | >                               |                     |
|       |    | > *Explanation: It is evident   |                     |
|       |    | > that consideration of         |                     |
|       |    | > suitability of use is being   |                     |
|       |    | > given insufficient attention  |                     |
|       |    | > by approval authorities.      |                     |
|       |    | > Emphasis needs to be given to |                     |
|       |    | > this requirement.*            |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | US | There is a missing period in    | P+                  |
| 1.1.3 |    | the next to the last paragraph. |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | CA | "National legislation may       | P+                  |
| 1.2.4 |    | specify the ~~sealing~~         |                     |
|       |    | securing that is required."     |                     |
|       |    |                                 |                     |
|       |    | The word sealing should now be  |                     |
|       |    | replaced by securing to remain  |                     |
|       |    | consistent with the other       |                     |
|       |    | sections.                       |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | NO | Acceptable technical solution:  | P- Could lead to    |
| 1.2.4 |    |                                 | the                 |
|       |    | The actual counter number can   | misunderstanding    |
|       |    | be [displayed]{.mark} for       | that the actual     |
|       |    | comparison with the reference   | counter number      |
|       |    | number by a procedure described | needs not be        |
|       |    | in the manual [and in the OIML  | indicated at all.   |
|       |    | certificate with test           |                     |
|       |    | report]{.mark}.                 |                     |
|       |    |                                 |                     |
|       |    | > Please change "can be         |                     |
|       |    | > displayed" with "should be    |                     |
|       |    | > displayed".                   |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | SI | > In the second paragraph       | P+ add "(or span)"  |
| 1.2.4 |    | > replace "devices to adjust    |                     |
|       |    | > sensitivity" with "devices to | P+ Changed to       |
|       |    | > perform external span         | "Evaluation report" |
|       |    | > adjustment".                  | in the entire       |
|       |    | >                               | document. However   |
|       |    | > a): The term "Test Report" is | BIML will be asked  |
|       |    | > used (as well as in Contents, | to take a final     |
|       |    | > 4.18.1, 7.2, 8.2.1.2, A.4.13, | decision, see 2CD,  |
|       |    | > C.3, C.4.2, D.3, D.4.2, F4),  | page 4, question 4. |
|       |    | > while in some other clauses   |                     |
|       |    | > (2.3, A.3.1, A.3.1, A.3.3.,   |                     |
|       |    | > A.4.1.6, A.4.1.7, A.4.7,      |                     |
|       |    | > C.2.5, D.2.2) the term        |                     |
|       |    | > "Evaluation Report" is used.  |                     |
|       |    | > It is necessary to use        |                     |
|       |    | > uniform terminology.          |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | UK | b)  "resp." should be worded in | P+                  |
| 1.2.4 |    |     full.                       |                     |
|       |    |                                 | P+ We refer to our  |
|       |    | c\) Note:                       | proposal in the 2CD |
|       |    |                                 |                     |
|       |    | The note states that the        | Further             |
|       |    | instrument "shall not longer be | improvements by     |
|       |    | used under legal control" from  | native English      |
|       |    | this note, this is a matter for | speakers are, of    |
|       |    | national legislation. if the    | course, welcome.    |
|       |    | displayed and fixed reference   |                     |
|       |    | numbers do not correspond.      | P+                  |
|       |    | Firstly this statement appears  |                     |
|       |    | to be badly worded. Our         |                     |
|       |    | interpretation is that the      |                     |
|       |    | authors are trying to say that  |                     |
|       |    | the instrument should not be    |                     |
|       |    | used for a legally controlled   |                     |
|       |    | purpose. Secondly, this goes    |                     |
|       |    | against current UK legislation  |                     |
|       |    | for both non-automatic and      |                     |
|       |    | automatic weighing instruments  |                     |
|       |    | which allows adjustment,        |                     |
|       |    | alteration etc without the need |                     |
|       |    | for mandatory re-verification   |                     |
|       |    | if the local Chief inspector of |                     |
|       |    | Weights and Measures has been   |                     |
|       |    | advised in writing. Similar     |                     |
|       |    | provisions exist in other OIML  |                     |
|       |    | Member States. Delete the       |                     |
|       |    | second sentence                 |                     |
|       |    |                                 |                     |
|       |    | c): In the last paragraph, the  |                     |
|       |    | phrase "\...firmly mounted to   |                     |
|       |    | the instrument\..." could be    |                     |
|       |    | better worded.                  |                     |
|       |    |                                 |                     |
|       |    | In addition, in the Note under  |                     |
|       |    | c), the final words should read |                     |
|       |    | "the instrument shall no longer |                     |
|       |    | be used ..."                    |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | US | "National legislation may       | P+ yes, see 4.1.2.4 |
| 1.2.4 |    | specify the ~~sealing~~         | CA above            |
|       |    | securing that is required."     |                     |
|       |    |                                 |                     |
|       |    | The word sealing should now be  |                     |
|       |    | replaced by securing to remain  |                     |
|       |    | consistent with the other       |                     |
|       |    | sections.                       |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.1 | AU | > 4.2.1. Quality of reading     | P+ We propose,      |
|       |    | >                               | however, a slightly |
|       |    | > Change this to the following: | modified text:      |
|       |    | >                               | "Reading of the     |
|       |    | > Reading of the ~~results~~    | primary indications |
|       |    | > **primary indications         | (see T.1.3.1),\..." |
|       |    | > (including weighing           |                     |
|       |    | > results)** shall be reliable, | P+                  |
|       |    | > easy and unambiguous under    |                     |
|       |    | > conditions of normal use:     |                     |
|       |    | >                               |                     |
|       |    | > \- the overall inaccuracy of  |                     |
|       |    | > reading of an analogue        |                     |
|       |    | > indicating device shall not   |                     |
|       |    | > exceed 0.2 e,                 |                     |
|       |    | >                               |                     |
|       |    | > \- the figures, **units and   |                     |
|       |    | > designations** forming the    |                     |
|       |    | > ~~results~~ **primary         |                     |
|       |    | > indications** shall be of a   |                     |
|       |    | > size, shape and clarity for   |                     |
|       |    | > reading to be easy.           |                     |
|       |    | >                               |                     |
|       |    | > The scales, numbering and     |                     |
|       |    | > printing shall permit the     |                     |
|       |    | > figures which form the        |                     |
|       |    | > results to be read by simple  |                     |
|       |    | > juxtaposition.                |                     |
|       |    | >                               |                     |
|       |    | > *Explanation: It is evident   |                     |
|       |    | > that consideration of the     |                     |
|       |    | > quality of reading is being   |                     |
|       |    | > given insufficient attention  |                     |
|       |    | > by approval authorities.      |                     |
|       |    | > Examples are occurring of     |                     |
|       |    | > instruments presenting        |                     |
|       |    | > results without including     |                     |
|       |    | > units for primary indications |                     |
|       |    | > such as tare, others where    |                     |
|       |    | > the size of units given is    |                     |
|       |    | > very substantially smaller    |                     |
|       |    | > than the numbers comprising   |                     |
|       |    | > the indication, yet others    |                     |
|       |    | > where 'pictograms' are used   |                     |
|       |    | > to indicate various elements  |                     |
|       |    | > of an indication creating     |                     |
|       |    | > substantial ambiguity (such   |                     |
|       |    | > pictograms are                |                     |
|       |    | > un-standardised and largely   |                     |
|       |    | > incomprehensible to untrained |                     |
|       |    | > users or customers). There    |                     |
|       |    | > are also examples where when  |                     |
|       |    | > taken individually elements   |                     |
|       |    | > of the display may be         |                     |
|       |    | > acceptable, but when combined |                     |
|       |    | > the spatial location and      |                     |
|       |    | > proximity results in          |                     |
|       |    | > ambiguity. Regrettably we     |                     |
|       |    | > feel that tighter             |                     |
|       |    | > requirements now need to be   |                     |
|       |    | > provided, as the existing     |                     |
|       |    | > requirements are apparently   |                     |
|       |    | > not sufficient to advise      |                     |
|       |    | > manufacturers of acceptable   |                     |
|       |    | > practices, not sufficient to  |                     |
|       |    | > ensure that approval          |                     |
|       |    | > authorities do not approve    |                     |
|       |    | > clearly unacceptable          |                     |
|       |    | > designs..*                    |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.2 | AU | > 4.2.2. Form of the indication | P+ We suggest,      |
|       |    | >                               | however, a slightly |
|       |    | > Change this to the following: | changed wording,    |
|       |    | >                               | because "primary    |
|       |    | > 4.2.2 Form of the indication  | indications"        |
|       |    | >                               | according to        |
|       |    | > **4.2.2.1 Each primary        | T.1.3.1 comprise    |
|       |    | > indication (including         | much more symbols,  |
|       |    | > weighing results) shall       | indications, etc.   |
|       |    | > contain the names or symbols  | (see 2CD)           |
|       |    | > of the units in which they    |                     |
|       |    | > are expressed.**              | P- We think that    |
|       |    | >                               | this problem has    |
|       |    | > *This is necessary to ensure  | been sufficiently   |
|       |    | > an adequate form for prices   | addressed by your   |
|       |    | > and unit prices as well as    | own proposal under  |
|       |    | > gross, net and tare values.*  | 4.2.1 (new wording: |
|       |    | >                               | "\...the figures,   |
|       |    | > **The size of the names or    | units and           |
|       |    | > symbols of units comprising   | designations        |
|       |    | > primary indications shall not | forming the primary |
|       |    | > be less than 75% of the size  | indications [shall  |
|       |    | > of the figures.**             | be of a size, shape |
|       |    | >                               | and clarity for     |
|       |    | > *This is necessary to ensure  | reading to be       |
|       |    | > units are not provided in a   | easy)]{.underline}. |
|       |    | > size which is inadequate,     |                     |
|       |    | > hence resulting in ambiguity  | P- We think that    |
|       |    | > and potentially in            | this requirement    |
|       |    | > facilitation of fraud.*       | would be too strict |
|       |    | >                               | (if you think,      |
|       |    | > **The display elements which  | e.g., of PC         |
|       |    | > are legally or metrologically | monitors); in       |
|       |    | > relevant shall whenever       | addition we think   |
|       |    | > presented, be presented in    | that obvious        |
|       |    | > the same locations in the     | ambiguity can be    |
|       |    | > display.**                    | rejected by         |
|       |    | >                               | applying 4.2.1      |
|       |    | > *This is necessary to prevent | (revised wording).  |
|       |    | > situations in which primary   |                     |
|       |    | > indications and weighing      | P- We understand    |
|       |    | > results change size and       | your point, but     |
|       |    | > location according to         | again, we think     |
|       |    | > particular operational modes  | that the proposed   |
|       |    | > of the instrument -- hence    | wording is too      |
|       |    | > resulting in ambiguity.*      | strict, because it  |
|       |    | >                               | may exclude even    |
|       |    | > **Where a number of display   | reasonable          |
|       |    | > elements are of a similar     | technical           |
|       |    | > nature (e.g. actually or      | solutions.          |
|       |    | > apparently with the same      |                     |
|       |    | > units), provision shall be    | We see, e.g., no    |
|       |    | > made to remove any potential  | problem to reject a |
|       |    | > for confusion or ambiguity by | confusing technical |
|       |    | > including appropriate         | solution (as you    |
|       |    | > designations for the display  | explained) by       |
|       |    | > elements. Such provision      | applying 4.2.1      |
|       |    | > shall be in a size,           | (revised wording).  |
|       |    | > prominence and location       |                     |
|       |    | > suitable to remove the        |                     |
|       |    | > potential confusion or        |                     |
|       |    | > ambiguity.**                  |                     |
|       |    | >                               |                     |
|       |    | > *This is necessary to prevent |                     |
|       |    | > potential confusion such as   |                     |
|       |    | > between two kg values, one    |                     |
|       |    | > representing the net weight   |                     |
|       |    | > and one representing the      |                     |
|       |    | > tare. Similarly we have       |                     |
|       |    | > encountered a situation where |                     |
|       |    | > two price values expressed as |                     |
|       |    | > \$ (one qualified by a small  |                     |
|       |    | > and remote arrow indicating   |                     |
|       |    | > '/kg') are easily confused.*  |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | CN | > Change"...1 x 10k, 2 x 10^k^  | P+                  |
| 2.2.1 |    | > or 5 x 10^k^..."in 4.2.2.1    |                     |
|       |    | > into "...1 x 10**^k^**, 2 x   |                     |
|       |    | > 10^k^ or 5 x 10^k^...".       |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | NL | > Non-significant zero:         | We do not agree,    |
| 2.2.2 |    |                                 | because the 1CD in  |
|       |    | When dealing with               | 4.2.2.2, last       |
|       |    | multi-interval/-range           | sentence, says that |
|       |    | instruments the current         | the requirements of |
|       |    | proposal will lead to a         | the 5^th^ para      |
|       |    | misunderstanding in the reading | apply only to the   |
|       |    | the weight from the display     | smallest (partial)  |
|       |    | when switching to a greater     | weighing range, not |
|       |    | (partial) range.                | to the greater      |
|       |    |                                 | ranges. Therefore,  |
|       |    | The current proposal mentioned  | xxx,100 is          |
|       |    | in the draft is as follows:     | permitted for       |
|       |    |                                 | multi-interval      |
|       |    | -   Only for the lowest         | instruments and     |
|       |    |     (partial) range the         | multiple range      |
|       |    |     non-significant zero        | instruments with    |
|       |    |     requirement applies.        | automatic change    |
|       |    |                                 | over. We suggest,   |
|       |    | -   For the greater range this  | however, to add two |
|       |    |     requirement does not apply. | examples in 4.2.2.2 |
|       |    |                                 | in order to avoid   |
|       |    | -   For the user/operator it is | misunderstandings   |
|       |    |     not immediately clear       | (see 2CD).          |
|       |    |     (despite several markers,   |                     |
|       |    |     indicating that the         | P- We hope that the |
|       |    |     instrument has changed to   | explanation and the |
|       |    |     another (partial) range)    | examples solve your |
|       |    |                                 | concerns            |
|       |    | The following is                |                     |
|       |    | done/interpreted by NMi:        |                     |
|       |    |                                 |                     |
|       |    | ## Example                      |                     |
|       |    |                                 |                     |
|       |    | Range 1: e1 = 50 g and Max1 =   |                     |
|       |    | 150 kg                          |                     |
|       |    |                                 |                     |
|       |    | Range 2: e2 = 100 g and Max2 =  |                     |
|       |    | 300 kg                          |                     |
|       |    |                                 |                     |
|       |    | Indication of weight in         |                     |
|       |    | display: xxx,xxx kg             |                     |
|       |    |                                 |                     |
|       |    | When operating in range 1,      |                     |
|       |    | there is only one               |                     |
|       |    | non-significant zero present.   |                     |
|       |    | The display shows               |                     |
|       |    | xxx,05[0]{.underline}.          |                     |
|       |    |                                 |                     |
|       |    | When switching to a greater     |                     |
|       |    | range there are now 2           |                     |
|       |    | non-significant zeros. The      |                     |
|       |    | display shows                   |                     |
|       |    | xxx,1[00]{.underline}. This is  |                     |
|       |    | not allowed according Article   |                     |
|       |    | 4.2.2.2.                        |                     |
|       |    |                                 |                     |
|       |    | This has been solved as         |                     |
|       |    | follows:                        |                     |
|       |    |                                 |                     |
|       |    | -   The decimal marker has a    |                     |
|       |    |     [fixed]{.underline}         |                     |
|       |    |     position. When switching to |                     |
|       |    |     another (partial) range the |                     |
|       |    |     decimal stays in the        |                     |
|       |    |     position when the           |                     |
|       |    |     instrument was turned on.   |                     |
|       |    |                                 |                     |
|       |    | -   When switching to a greater |                     |
|       |    |     (partial) range the last    |                     |
|       |    |     two digits are turned off   |                     |
|       |    |     and not used until          |                     |
|       |    |     switching to the lower      |                     |
|       |    |     (partial) range. The        |                     |
|       |    |     display now shows xxx,1.    |                     |
|       |    |                                 |                     |
|       |    | We propose to maintain the      |                     |
|       |    | procedure mentioned in the      |                     |
|       |    | above mentioned example,        |                     |
|       |    | because:                        |                     |
|       |    |                                 |                     |
|       |    | -   For a user/operator it is   |                     |
|       |    |     (extra) clear that the      |                     |
|       |    |     instrument has changed to   |                     |
|       |    |     another (partial) range.    |                     |
|       |    |     The indication on the       |                     |
|       |    |     display change from xxx,050 |                     |
|       |    |     to xxx,1.                   |                     |
|       |    |                                 |                     |
|       |    | -   For the greater (partial)   |                     |
|       |    |     ranges the requirement of   |                     |
|       |    |     the non-significant zero    |                     |
|       |    |     does not apply, since there |                     |
|       |    |     are no non-significant      |                     |
|       |    |     zeros present.              |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | UK | > Do we need to specify that    | P- This was         |
| 2.2.2 |    | > the decimal sign should be on | included on request |
|       |    | > one line with the bottom of   | of a TC9/SC1 member |
|       |    | > the figures, especially if a  |                     |
|       |    | > decimal point is used instead |                     |
|       |    | > of a comma?                   |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.3 | JP | > Does the last sentence        | Yes. Please refer   |
|       |    | > "Indications below zero in    | also to 4.2.3 ZA    |
|       |    | > the order of - Min are not    | and 4.2.3 DK        |
|       |    | > permitted unless a tare       |                     |
|       |    | > device is in operation" mean  |                     |
|       |    | > the values less than zero and |                     |
|       |    | > Min at minus side?            |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.3 | DK | > Paragraph 4.2.3 states that   | This has been       |
|       |    | > on a multiple range           | discussed           |
|       |    | > instrument there shall be no  | intensively, and    |
|       |    | > indication using e~i~ above   | the new wording as  |
|       |    | > Max~i~ = n~i~ x e~i~ for the  | it stands in the    |
|       |    | > lower partial weighing        | 1CD has obviously   |
|       |    | > range(s) i, for automatic     | been accepted by a  |
|       |    | > change over.                  | majority of TC9/SC1 |
|       |    | >                               | members.            |
|       |    | > We find this inconsistent.    |                     |
|       |    | > Indication up to Max~i~ +     | see also 4.2.3 UK   |
|       |    | > 9e~i~ for each weighing range | and ZA              |
|       |    | > is generally allowed, and it  |                     |
|       |    | > must be concluded that the    | The reason is that  |
|       |    | > authors of the standard have  | one TC9/SC1 member  |
|       |    | > found this to be beneficial   | country requested a |
|       |    | > for the owner/operator. Anong | requirement for     |
|       |    | > other things, it allows the   | indications below   |
|       |    | > owner of the instrument to    | zero for            |
|       |    | > determine the error of the    | instruments with a  |
|       |    | > instrument at Max~i~, without | digital display.    |
|       |    | > having acces to a number of   | Normally (and       |
|       |    | > small weights. This could be  | unless a tare       |
|       |    | > an issue for the owners       | function is in      |
|       |    | > operating a quality system.   | operation)          |
|       |    | >                               | indications below   |
|       |    | > Automatic range change over   | zero cannot be      |
|       |    | > occurs only once during a     | allowed because     |
|       |    | > weighing operation. The       | there is no error   |
|       |    | > change over operation,        | regime defined. But |
|       |    | > automatic or not, should not  | for practical       |
|       |    | > be compared with that of a    | reasons an          |
|       |    | > multi-interval instrument. It | instrument must be  |
|       |    | > is obviously confusing if a   | allowed to make use |
|       |    | > multi-interval instrument is  | of a small part of  |
|       |    | > changing resolution back and  | the negative        |
|       |    | > forth at Max~i~ + 9e~i~.      | weighing range in   |
|       |    | > There is no such confusion    | order to find       |
|       |    | > when operating a multiple     | stable equilibrium. |
|       |    | > range instrument. There is    | It is now arbitrary |
|       |    | > obviously no metrological     | to define a proper  |
|       |    | > reason, either, for having    | criterion. We       |
|       |    | > automatic change over limited | thought that "in    |
|       |    | > to Max~i~, since operation up | the order of ‑Min"  |
|       |    | > to Max~i~ +9e~i~ is otherwise | would help, but     |
|       |    | > generally allowed.            | because of some     |
|       |    | >                               | comments we now     |
|       |    | > Paragraph 4.2.3 also states   | suggest "-20d" and  |
|       |    | > that indications below zero   | the new wording in  |
|       |    | > in the order of --Min are not | the 2CD.            |
|       |    | > permitted unless a tare       |                     |
|       |    | > device is in operation.       |                     |
|       |    | >                               |                     |
|       |    | > Is there any metrological     |                     |
|       |    | > reason for this new           |                     |
|       |    | > requirement? A requirement    |                     |
|       |    | > like this should not be left  |                     |
|       |    | > open for interpretation. "In  |                     |
|       |    | > the order of --Min" is not    |                     |
|       |    | > precise. If such a limit on   |                     |
|       |    | > indication below zero is      |                     |
|       |    | > required, then it should be   |                     |
|       |    | > unambiguously definded.       |                     |
|       |    | > Otherwise inspectors may      |                     |
|       |    | > fault an instrument based on  |                     |
|       |    | > a whim.                       |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.3 | UK | > Says that for a multiple      | Yes, you are right. |
|       |    | > range instrument with         |                     |
|       |    | > automatic changeover it is    | We hope that this   |
|       |    | > not allowed for a range to    | has been clarified  |
|       |    | > change to the next highest at | by the new wording  |
|       |    | > Max~i~+9e~i~. WELMEC 2 guide  | in the 2CD (see     |
|       |    | > Section 3.1.36 accepts that   | also 4.2.3 DK and   |
|       |    | > it may be done, although      | ZA)                 |
|       |    | > prefers it not to be done.    |                     |
|       |    | >                               |                     |
|       |    | > What does the sentence        |                     |
|       |    | > "Indications below zero in    |                     |
|       |    | > the order of -Min are not     |                     |
|       |    | > permitted unless a tare       |                     |
|       |    | > device is in operation."      |                     |
|       |    | > mean? It seems to imply that  |                     |
|       |    | > indication below zero, not    |                     |
|       |    | > "in the order of -Min", is    |                     |
|       |    | > allowed.                      |                     |
+-------+----+---------------------------------+---------------------+
| 4.2.3 | ZA | > 3^rd^ Par: Delete "not":      | P+ But we suggest a |
|       |    | > Indications below zero in the | slightly different  |
|       |    | > order of --Min are ~~not~~    | wording:            |
|       |    | > permitted unless a tare       |                     |
|       |    | > device is in operation.       | "Indications below  |
|       |    |                                 | zero are not        |
|       |    |                                 | permitted unless a  |
|       |    |                                 | tare device is in   |
|       |    |                                 | operation.", and to |
|       |    |                                 | add the "Note:      |
|       |    |                                 | Nevertheless, a     |
|       |    |                                 | temporary           |
|       |    |                                 | indication of       |
|       |    |                                 | negative numbers    |
|       |    |                                 | down to --20d is    |
|       |    |                                 | accepted."          |
+-------+----+---------------------------------+---------------------+
| 4.2.4 | C  | > Please include definition of  | P- This is a        |
|       | EC | > "approximate indication       | supplementary       |
|       | IP | > device" in terminology.       | indication device   |
|       |    |                                 | providing only      |
|       |    |                                 | secondary           |
|       |    |                                 | indications, and    |
|       |    |                                 | thus not being      |
|       |    |                                 | subject to          |
|       |    |                                 | requirements of     |
|       |    |                                 | this                |
|       |    |                                 | recommendation,     |
|       |    |                                 | except No 4.2.4.    |
|       |    |                                 | Not to be mixed up  |
|       |    |                                 | with bar graphs.    |
+-------+----+---------------------------------+---------------------+
| 4.3.2 | CA | "- on an instrument of Class I  | P+, see also 3.8.1  |
|       |    | or II:                          |                     |
|       |    |                                 |                     |
|       |    | .....in this case i~0~ is the   |                     |
|       |    | relative ~~movement~~           |                     |
|       |    | displacement between..."        |                     |
|       |    |                                 |                     |
|       |    | > The word 'movement' should be |                     |
|       |    | > replaced by 'displacement'.   |                     |
|       |    | > It is not movement that is    |                     |
|       |    | > desired but rather            |                     |
|       |    | > displacement of the           |                     |
|       |    | > indicating component.         |                     |
+-------+----+---------------------------------+---------------------+
| 4.4.1 | CA | **Change of Indication**        | P- It is obvious    |
|       |    |                                 | that changes \>     |
|       |    | After a change in load, the     | 1,4d                |
|       |    | previous indication shall not   | (discrimination     |
|       |    | persist for longer than 1       | test) are meant.    |
|       |    | second.                         | For these changes   |
|       |    |                                 | the present wording |
|       |    | Suggested wording change        | is correct and      |
|       |    |                                 | should not be       |
|       |    | After a change in load, *of a   | supplemented.       |
|       |    | magnitude sufficient to         |                     |
|       |    | overcome the threshold of       |                     |
|       |    | sensitivity of the instrument*, |                     |
|       |    | the previous indication shall   |                     |
|       |    | not persist for longer than 1   |                     |
|       |    | second.                         |                     |
|       |    |                                 |                     |
|       |    | Rationale                       |                     |
|       |    |                                 |                     |
|       |    | Placing a load, too small to be |                     |
|       |    | detected, on the instrument     |                     |
|       |    | would cause an issue with this  |                     |
|       |    | section in its current wording. |                     |
|       |    |                                 |                     |
|       |    | **Canada would prefer to see    |                     |
|       |    | clarification.**                |                     |
+-------+----+---------------------------------+---------------------+
| 4.4.2 | UK | > The first sentence of this    | P- The first        |
|       |    | > section is imprecise; what is | sentence is a kind  |
|       |    | > meant by "sufficiently close  | of introduction.    |
|       |    | > to"? The final sentence is    | The following       |
|       |    | > also imprecise, does this     | sentence and bullet |
|       |    | > mean that an instrument must  | points clearly      |
|       |    | > store or print a weighing     | define what is      |
|       |    | > value within 1e of the final  | meant.              |
|       |    | > weighing value even while     |                     |
|       |    | > there is continuous or        | P+ In order to      |
|       |    | > temporary disturbance? Our    | avoid possible      |
|       |    | > view is that this is not what | misunderstandings   |
|       |    | > is meant. Delete the first    | we suggest to       |
|       |    | > sentence. Replace the word    | change the wording  |
|       |    | > "under" with "after".         | of the final        |
|       |    |                                 | sentence (see 2CD). |
|       |    | If the change) above is not     |                     |
|       |    | accepted:                       |                     |
|       |    |                                 |                     |
|       |    | > For both bullet points, would |                     |
|       |    | > it be better to put "In the   |                     |
|       |    | > case of\..." rather than "In  |                     |
|       |    | > case of\...", as the latter   |                     |
|       |    | > has a rather different        |                     |
|       |    | > meaning. In the final         |                     |
|       |    | > sentence, if there is         |                     |
|       |    | > continuous disturbance then   |                     |
|       |    | > the two conditions can not be |                     |
|       |    | > met. Under continuous         |                     |
|       |    | > disturbance the instrument    |                     |
|       |    | > should not print/store data,  |                     |
|       |    | > nor should it be able to set  |                     |
|       |    | > zero or tare.                 |                     |
+-------+----+---------------------------------+---------------------+
| 4.4.3 | CA | **Extended Indicating Device**  | P+                  |
|       |    |                                 |                     |
|       |    | The last sentence in this       |                     |
|       |    | section should be amended as    |                     |
|       |    | follows:                        |                     |
|       |    |                                 |                     |
|       |    | In any case printing shall not  |                     |
|       |    | be possible *while the extended |                     |
|       |    | indicating device is in         |                     |
|       |    | operation.*                     |                     |
|       |    |                                 |                     |
|       |    | > Rationale: The current        |                     |
|       |    | > wording is too broad.\        |                     |
|       |    | > Canada agrees with            |                     |
|       |    | > Secretariat's response.       |                     |
+-------+----+---------------------------------+---------------------+
| 4.4.4 | AU | > 4.4.4 Multiple use of         | P+                  |
|       |    | > indicating devices            |                     |
|       |    | >                               | P+                  |
|       |    | > Change this to say:           |                     |
|       |    | >                               | P- this could lead  |
|       |    | > Indications other than        | to problems;        |
|       |    | > primary indications may be    | "clearly            |
|       |    | > displayed in the same         | identified" is      |
|       |    | > indicating device, provided   | sufficient.         |
|       |    | > that:                         |                     |
|       |    |                                 | P+ However, we      |
|       |    | -   **any additional            | suggest a new       |
|       |    |     indications do not lead to  | wording that is     |
|       |    |     any ambiguity in regard to  | closer to the       |
|       |    |     the primary indications.**  | previous wording    |
|       |    |                                 | (see 2CD, last      |
|       |    | -   quantities other than       | sentence under      |
|       |    |     weight values are           | 4.4.4):             |
|       |    |     identified by the           |                     |
|       |    |     appropriate unit of         | "No restrictions    |
|       |    |     measurement, or symbol      | apply if the        |
|       |    |     thereof, or a special sign  | weighing mode is    |
|       |    |     **or designation,**         | made inoperative    |
|       |    |                                 | and this is clear   |
|       |    | -   weight values that are not  | and unambiguous     |
|       |    |     weighing results (T.5.2.1   | (including the      |
|       |    |     through T.5.2.3) shall      | customers in case   |
|       |    |     **also carry the            | of direct sales)."  |
|       |    |     appropriate unit of         |                     |
|       |    |     measurement, or symbol      |                     |
|       |    |     thereof and shall** be      |                     |
|       |    |     clearly identified, or they |                     |
|       |    |     may be displayed only       |                     |
|       |    |     temporarily on manual       |                     |
|       |    |     command and shall not be    |                     |
|       |    |     printed.                    |                     |
|       |    |                                 |                     |
|       |    | > **If the instrument is set    |                     |
|       |    | > into a mode in which weighing |                     |
|       |    | > is clearly and unambiguously  |                     |
|       |    | > not taking place (in the case |                     |
|       |    | > of instruments intended for   |                     |
|       |    | > trading direct with the       |                     |
|       |    | > public this shall also be     |                     |
|       |    | > clear and unambiguous to the  |                     |
|       |    | > member of the public), the    |                     |
|       |    | > above restrictions do not     |                     |
|       |    | > apply.**                      |                     |
|       |    |                                 |                     |
|       |    | *Explanation: There is          |                     |
|       |    | potential for this requirement  |                     |
|       |    | (in its previous form) to be    |                     |
|       |    | used to justify display         |                     |
|       |    | arrangements and indications    |                     |
|       |    | which are ambiguous or          |                     |
|       |    | potentially fraudulent. It is   |                     |
|       |    | was not clear what constitutes  |                     |
|       |    | a 'special command' and in what |                     |
|       |    | way this differs from any other |                     |
|       |    | command.*                       |                     |
+-------+----+---------------------------------+---------------------+
| 4.5.1 | UK | > The Note, about Class IIII,   | P+ The note applies |
|       |    | > has been put into the body of | only to the 2^nd^   |
|       |    | > the text, whereas it used to  | para. This has been |
|       |    | > be a footnote. That footnote  | reflected in the    |
|       |    | > made it clear that it only    | 2CD.                |
|       |    | > applied to the sentence "The  |                     |
|       |    | > overall effect\..." as it     |                     |
|       |    | > referred to "This             |                     |
|       |    | > provision\...". This Note now |                     |
|       |    | > seems to apply to both        |                     |
|       |    | > sentences above the Note.     |                     |
|       |    | > Also, does the Note now apply |                     |
|       |    | > to the sentence below it?     |                     |
+-------+----+---------------------------------+---------------------+
| 4.5.2 | ZA | > Add: ...shall be not more     | P- 1. There was a   |
|       |    | > than 0.25e, however on an     | respective demand   |
|       |    | > instrument with auxiliary     | to define a         |
|       |    | > indicating devices this       | requirement in      |
|       |    | > effect shall be not more than | terms of e only; 2. |
|       |    | > 0.5d.                         | There is really no  |
|       |    |                                 | need to have a more |
|       |    |                                 | stringent           |
|       |    |                                 | requirement for     |
|       |    |                                 | instruments with    |
|       |    |                                 | digital displays    |
|       |    |                                 | having e\>d.        |
+-------+----+---------------------------------+---------------------+
| 4.6.3 | ZA | > Add: ±0,5 d for mechanical    | P- see above        |
|       |    | > instruments with digital      |                     |
|       |    | > indication and instruments    |                     |
|       |    | > with auxiliary indicating     |                     |
|       |    | > devices.                      |                     |
+-------+----+---------------------------------+---------------------+
| 4.6.5 | AU | 4.6.5. Visibility of operation  | P- This would be a  |
|       |    | (of a tare device)              | rather important    |
|       |    |                                 | change. As there    |
|       |    | Add the following:              | was no such vote at |
|       |    |                                 | the beginning of    |
|       |    | Where the tare value (or preset | the revision, the   |
|       |    | tare value) is displayed other  | acceptance by a     |
|       |    | than temporarily, the value     | majority of TC9/SC1 |
|       |    | shall include the appropriate   | members is          |
|       |    | units (or symbol), and shall be | unlikely.           |
|       |    | designated TARE (an alternative |                     |
|       |    | word according to the           |                     |
|       |    | appropriate national language   |                     |
|       |    | may be used). The location and  |                     |
|       |    | arrangement of the value, units |                     |
|       |    | and designation shall be such   |                     |
|       |    | as to remove any possibility of |                     |
|       |    | confusion with the (NET)        |                     |
|       |    | weighing result.                |                     |
|       |    |                                 |                     |
|       |    | Where the instrument is not to  |                     |
|       |    | be used for trading direct with |                     |
|       |    | the public, the symbols T or PT |                     |
|       |    | (in the case of tare and preset |                     |
|       |    | tare respectively) may be used  |                     |
|       |    | instead of TARE.                |                     |
|       |    |                                 |                     |
|       |    | *Explanation: We have recently  |                     |
|       |    | seen an instrument intended for |                     |
|       |    | trading direct with the public  |                     |
|       |    | in which the tare display       |                     |
|       |    | (designated PT although not     |                     |
|       |    | only preset tares were          |                     |
|       |    | displayed) was presented in     |                     |
|       |    | exactly the same manner as the  |                     |
|       |    | net weight value clearly        |                     |
|       |    | causing confusion and           |                     |
|       |    | ambiguity. Symbols such as PT   |                     |
|       |    | or T are not known to the       |                     |
|       |    | general public, and therefore   |                     |
|       |    | should not be used on           |                     |
|       |    | instruments intended for        |                     |
|       |    | trading direct with the         |                     |
|       |    | public.*                        |                     |
+-------+----+---------------------------------+---------------------+
| 4     | C  | > It would be helpful to give a | P+ The heading in   |
| .6.11 | EC | > hint to the regulation        | 4.6.12.5 has been   |
|       | IP | > concerning preset tare in 4.7 | supplemented: "...  |
|       |    | > already in 4.6.11. When not   | with a preset tare  |
|       |    | > having read 4.7 already the   | device (4.7)"       |
|       |    | > example 4.6.12.5 is a bit     |                     |
|       |    | > confusing.                    |                     |
+-------+----+---------------------------------+---------------------+
| 4     | CH | > In order to shorten the       | P- See our response |
| .6.12 |    | > recommendation, consider      | under 3.3.3 and     |
|       |    | > moving examples (like in      | 3.10.4.5 CH         |
|       |    | > 3.3.3, 4.6.12) or remarks to  |                     |
|       |    | > the selection (like in        |                     |
|       |    | > 3.10.4.5) into an Appendix or |                     |
|       |    | > into a separated guide. They  |                     |
|       |    | > are neither metrological nor  |                     |
|       |    | > technical requirements.       |                     |
+-------+----+---------------------------------+---------------------+
| 4     | UK | > Footnote 3: "\...in in\...".  | P+                  |
| .6.12 |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| 4     | US | The U.S. recommends that an     | P- We think the     |
| .6.12 |    | example should be included for  | example in 4.6.12.3 |
|       |    | a multiple range instrument     | is sufficient.      |
|       |    | with tare weighing or preset    |                     |
|       |    | tare where e~1~would be rounded | No, in any case the |
|       |    | to zero in e~2~ or e~3~ to      | rounding shall be   |
|       |    | comply with 4.7.1. and proposed | correct.\           |
|       |    | footnote 3 below. Lack of       | For example: If e = |
|       |    | clarification as to the proper  | 10 g, an internal   |
|       |    | rounding of tare has resulted   | value of 0,444 kg   |
|       |    | in conflicting opinions         | shall be rounded to |
|       |    | regarding rounding tare to      | 0,440 kg and        |
|       |    | zero. Are these instruments     | internal value of   |
|       |    | required to round up to the     | 0,445 kg shall be   |
|       |    | nearest e to avoid sales by     | rounded to 0,450    |
|       |    | gross weight?                   | kg.                 |
|       |    |                                 |                     |
|       |    | > ***Possible example:***       | (Your example is    |
|       |    | >                               | printed in correct  |
|       |    | > 4.6.12.X Multiple range       | format at the last  |
|       |    | > instrument with a             | page of this        |
|       |    | > tare-weighing device          | summary)            |
|       |    | >                               |                     |
|       |    | > Specifications of the         | Your proposal       |
|       |    | > instrument: Class III, Max~1~ | corresponds with    |
|       |    | > = 60 kg, e~1~ = 10 g Max~2~ = | ours in 4.6.12.3,   |
|       |    | > 300 kg e~2~ = 100 g           | but in our example  |
|       |    | >                               | the tare value is   |
|       |    | > Max~3~ = 500 kg e~3~ = 500 g  | not close to zero.  |
|       |    | >                               | However, the way of |
|       |    | > Unloaded instrument,indicated | rounding in your    |
|       |    | > value in weighing range (WR)  | proposal shall be   |
|       |    | > 1 = WR1 0,000 kg              | the same as in      |
|       |    | >                               | 4.6.12.3.           |
|       |    | > Loading with tare load,       |                     |
|       |    | > internal value = 0,448 kg,    | The indicated tare  |
|       |    | > rounded and indicated value = | value in WR1 =      |
|       |    | > WR1 0,450 kg ^1^)             | 0,450 kg shall be   |
|       |    | >                               | rounded correctly   |
|       |    | > After releasing               | to WR3 = 0,500 kg   |
|       |    | > tare-balancing, indicated net | -- not to 0,000 kg. |
|       |    | > value = WR1 0,000 kg Net      |                     |
|       |    | >                               | But if WR1 = 0,240  |
|       |    | > Loading with net load,        | kg then the         |
|       |    | > internal value = 312,753 kg,  | rounding shall be   |
|       |    | > rounded and indicated net     | WR3 = 0,000 kg.     |
|       |    | > value = WR3313,000 kgNet      |                     |
|       |    | > ^1^)^2^)                      | Your example would  |
|       |    | >                               | not be correct in   |
|       |    | > *with automatic change over   | the sense of R76.   |
|       |    | > to weighing range 2, the      | The correct values  |
|       |    | > tare-weighing value shall be  | would be:           |
|       |    | > rounded to the actual e of    |                     |
|       |    | > weighing range 3,* rounded    | Tare load = 0,448   |
|       |    | > tare-weighing value = WR3     | kg indication WR1   |
|       |    | > 0,000g ^2^)^3^)               | 0,450kg             |
|       |    | >                               |                     |
|       |    | > Total loading, internal value | Tare balancing      |
|       |    | > = 313,201 kg rounded and      | indication WR1      |
|       |    | > indicated (if possible) gross | 0,000kg             |
|       |    | > value = WR2 213,000 kg        |                     |
|       |    | > ^1^)^2^)                      | Net load = 312,753  |
|       |    | >                               | kg, indication WR3  |
|       |    | > Possible printouts acc. to    | 313,000kg Net       |
|       |    | > 4.6.11: a) 313,000 kg B (or   |                     |
|       |    | > G)313,000 kg N 0,000 kg T     | Total load =        |
|       |    | > ^2^)^4^) b) 313,000 kg        | 313,201kg           |
|       |    | > 313,000 kg N 0,000 kg T       |                     |
|       |    | > ^2^)^4^) c) 313,000 kg N      | Gross (if           |
|       |    | > 0,000 kg T ^2^) d) 313,000 kg | displayable)        |
|       |    | > N ^2^) e) 313,000 kg ^2^)     | indication WR3      |
|       |    |                                 | 313,000kg           |
|       |    | **(*Note:* A 0.15 percent       |                     |
|       |    | overregistration of the net     | Printouts:          |
|       |    | weight**                        |                     |
|       |    |                                 | a\) 313,000kg B (or |
|       |    | **is introduced if tare is      | G) N 313,000kg N    |
|       |    | permitted to round to zero)**   | 0,500kg T           |
|       |    |                                 |                     |
|       |    | > ***An example of the same     | This seems to be a  |
|       |    | > instrument with a required    | mathematical        |
|       |    | > minimum tare of 1 e (tare is  | contradiction, but  |
|       |    | > prohibited from rounding to   | all three weighing  |
|       |    | > zero)***                      | values (tare, net   |
|       |    | >                               | and gross) are      |
|       |    | > Loading with tare load,       | correct rounded and |
|       |    | > internal value = 0,448 kg,    | within their mpe. A |
|       |    | > rounded and indicated value = | way out may be to   |
|       |    | > WR1 0,450 kg ^1^)             | distinguish one     |
|       |    | >                               | value as calculated |
|       |    | > After releasing               | value, e.g. "C      |
|       |    | > tare-balancing, indicated net | 312,500kg B"        |
|       |    | > value = WR1 0,000 kg Net      |                     |
|       |    | >                               | Conclusion: No      |
|       |    | > Loading with net load,        | change because the  |
|       |    | > internal value = 312,753 kg,  | example in 4.6.2.3  |
|       |    | > rounded and indicated net     | is sufficient and   |
|       |    | > value = WR3312,500 kgNet      | further examples    |
|       |    | > ^1^)^2^)                      | will enlarge the    |
|       |    | >                               | R76 too much.       |
|       |    | > *with automatic change over   |                     |
|       |    | > to weighing range 2, the      | P+                  |
|       |    | > tare-weighing value shall be  |                     |
|       |    | > rounded to the actual e of    |                     |
|       |    | > weighing range 3,* rounded    |                     |
|       |    | > tare-weighing value = WR3     |                     |
|       |    | > 0,500g ^2^)^3^)               |                     |
|       |    | >                               |                     |
|       |    | > Total loading, internal value |                     |
|       |    | > = 313,201 kg rounded and      |                     |
|       |    | > indicated (if possible) gross |                     |
|       |    | > value = WR2 212,500 kg        |                     |
|       |    | > ^1^)^2^)                      |                     |
|       |    | >                               |                     |
|       |    | > Possible printouts acc. to    |                     |
|       |    | > 4.6.11:a)313,000 kg B (or     |                     |
|       |    | > G)312,500 kg N0,500kg T       |                     |
|       |    | > ^2^)^4^)b) 313,000 kg 312,500 |                     |
|       |    | > kg N 0,500 kg T ^2^)^4^) c)   |                     |
|       |    | > 312,500 kg N 0,500 kg T ^2^)  |                     |
|       |    | > d) 312,500 kg N ^2^) e)       |                     |
|       |    | > 312,500 kg ^2^)               |                     |
|       |    |                                 |                     |
|       |    | **(*Note:* A 0.08 percent       |                     |
|       |    | underregistration of the net    |                     |
|       |    | weight is introduced if**       |                     |
|       |    |                                 |                     |
|       |    | **a minimum of 1 e tare is      |                     |
|       |    | required to comply with net     |                     |
|       |    | weight laws and regulations)**  |                     |
|       |    |                                 |                     |
|       |    | Footnote 3: There is an extra   |                     |
|       |    | "in" ***(. . . which is in      |                     |
|       |    | ~~in~~ operation.)***           |                     |
+-------+----+---------------------------------+---------------------+
| 4.6   | US | > This example does not appear  | P+ See new example  |
| .12.6 |    | > to correspond with the        | in 2CD              |
|       |    | > definition of the term        |                     |
|       |    | > T.5.3.2 Calculated weight     |                     |
|       |    | > value since the tare value in |                     |
|       |    | > the example is not identified |                     |
|       |    | > as a preset tare as a         |                     |
|       |    | > possible printout.            |                     |
+-------+----+---------------------------------+---------------------+
| 4.7   | CA | **Preset Tare Device**          | P- Although we know |
|       |    |                                 | the problem we      |
|       |    | Measurement Canada suggests     | think that this     |
|       |    | that wording be included in     | cannot be tested on |
|       |    | this section (or as             | type evaluation; it |
|       |    | appropriate) to prevent the use | is rather a matter  |
|       |    | of long term stored tares in    | of honesty (or      |
|       |    | situations where their use is   | legal control) of   |
|       |    | likely to result in incorrect   | the user and/or     |
|       |    | measurement.                    | other person        |
|       |    |                                 | responsible for a   |
|       |    | For example, storing tare       | correct weighing.   |
|       |    | values for road vehicles, which |                     |
|       |    | are subject to weight changes   | P- The scope of     |
|       |    | from fuel consumption,          | this recommendation |
|       |    | different loading, different    | does not make       |
|       |    | trailer combinations, mud &     | proposals           |
|       |    | snow, etc. is likely to cause   | concerning users    |
|       |    | large measurement errors.       | surveillance. See   |
|       |    |                                 | Chapter 1.          |
|       |    | Suggested Wording: 4.x.x -      |                     |
|       |    | Preset tare shall only be used  |                     |
|       |    | in cases where the tare value   |                     |
|       |    | is stable, well known and       |                     |
|       |    | unlikely to change over time.   |                     |
|       |    | In all other cases, the actual  |                     |
|       |    | tare weight must be determined  |                     |
|       |    | for each transaction.           |                     |
|       |    |                                 |                     |
|       |    | Rationale                       |                     |
|       |    |                                 |                     |
|       |    | > Measurement Canada has        |                     |
|       |    | > conducted a study of those    |                     |
|       |    | > vehicle scale installations   |                     |
|       |    | > where stored tares are        |                     |
|       |    | > commonly being used. The      |                     |
|       |    | > stored tare values were often |                     |
|       |    | > very far from the actual      |                     |
|       |    | > measured tare weights of the  |                     |
|       |    | > vehicle. Measurement Canada   |                     |
|       |    | > is currently considering a    |                     |
|       |    | > legislative change to address |                     |
|       |    | > this issue and feels that it  |                     |
|       |    | > is likely an issue elsewhere  |                     |
|       |    | > as well.                      |                     |
|       |    | >                               |                     |
|       |    | > **The 'Scope' of the          |                     |
|       |    | > Recommendation does not seem  |                     |
|       |    | > to indicate that it is        |                     |
|       |    | > applicable to 'type           |                     |
|       |    | > evaluation' only. The         |                     |
|       |    | > recommendation will be used   |                     |
|       |    | > as the basis for all          |                     |
|       |    | > evaluations if adopted in     |                     |
|       |    | > Canada.**                     |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.1 | FR | > We suggest to make it         | P+ Has been made    |
|       |    | > coherent with revision of R   | coherent to R51 (DR |
|       |    | > 51.                           | 2005) by the        |
|       |    |                                 | amendment "..., and |
|       |    |                                 | the maximum preset  |
|       |    |                                 | tare value shall    |
|       |    |                                 | not be greater than |
|       |    |                                 | Max1".              |
+-------+----+---------------------------------+---------------------+
| 4.7.1 | US | U.S. manufacturers have         | P- We think that    |
|       |    | recently reported that rounding | there is as a       |
|       |    | of tare weighing results are    | misunderstanding of |
|       |    | inconsistently applied when a   | the preset tare     |
|       |    | tare weighing result is stored  | function; therefore |
|       |    | into a temporary memory while   | we tried to improve |
|       |    | the operator is working with    | the terminology in  |
|       |    | more than one customer at a     | T.5.3.1, and we     |
|       |    | time (e.g. vehicle weighing     | hope that this      |
|       |    | applications).                  | solves the problem. |
|       |    |                                 |                     |
|       |    | One issuing authority stated    | We cannot, however, |
|       |    | that the tare weighing result   | agree with the      |
|       |    | became a preset tare since it   | suggested amendment |
|       |    | was stored into a temporary     | of 4.14.4.3 /       |
|       |    | memory location while the       | renumbering into    |
|       |    | vehicle was being loaded and    | 4.20, because for   |
|       |    | therefore rounded to the        | such a significant  |
|       |    | nearest scale division. During  | change the support  |
|       |    | the time the vehicle is loaded, | of TC9/SC1 members  |
|       |    | the operator can weigh other    | is unlikely.        |
|       |    | vehicles (this is called a      |                     |
|       |    | weigh-in/weigh-out procedure in |                     |
|       |    | the U.S.). A different issuing  |                     |
|       |    | authority stated that the tare  |                     |
|       |    | value should remain stored to   |                     |
|       |    | the internal resolution of the  |                     |
|       |    | instrument since tare was       |                     |
|       |    | determined on a tare weighing   |                     |
|       |    | device.                         |                     |
|       |    |                                 |                     |
|       |    | The U.S. agrees that a          |                     |
|       |    | predetermined tare introduced   |                     |
|       |    | into an instrument by means     |                     |
|       |    | such as keystroke, code, and    |                     |
|       |    | stored in memory for multiple   |                     |
|       |    | transactions should be          |                     |
|       |    | considered a preset tare value  |                     |
|       |    | and rounded to the value of the |                     |
|       |    | scale division. The U.S. also   |                     |
|       |    | agrees that a net weight can be |                     |
|       |    | calculated as the difference    |                     |
|       |    | the gross and tare weights      |                     |
|       |    | taken to the internal           |                     |
|       |    | resolution of the instrument.   |                     |
|       |    | However, we do not understand   |                     |
|       |    | the reason for the rounding of  |                     |
|       |    | tare weighing results that are  |                     |
|       |    | automatically entered into a    |                     |
|       |    | temporary memory, along with    |                     |
|       |    | other customer and transaction  |                     |
|       |    | information, when no rounding   |                     |
|       |    | is required for price computing |                     |
|       |    | instruments.                    |                     |
|       |    |                                 |                     |
|       |    | The U.S. recommends that tare   |                     |
|       |    | weighing values automatically   |                     |
|       |    | entered into a memory device    |                     |
|       |    | should not be considered as     |                     |
|       |    | preset tare values and requests |                     |
|       |    | that the Secretariat and the    |                     |
|       |    | members of TC9/SC1 consider     |                     |
|       |    | renumbering and amending sub    |                     |
|       |    | clause 4.14.4.3 as follows:     |                     |
|       |    |                                 |                     |
|       |    | > ~~4.14.4.3~~                  |                     |
|       |    | > [4.20]{.underline}            |                     |
|       |    | > Multi-vendor or multiple      |                     |
|       |    | > customer operation            |                     |
|       |    | > [\*)]{.underline}             |                     |
|       |    | >                               |                     |
|       |    | > An instrument may be designed |                     |
|       |    | > to be used by more than one   |                     |
|       |    | > vendor or to serve more than  |                     |
|       |    | > one customer at the same      |                     |
|       |    | > time, provided that the       |                     |
|       |    | > connection between the        |                     |
|       |    | > transactions and the relevant |                     |
|       |    | > vendor or customer is         |                     |
|       |    | > appropriately identified.     |                     |
|       |    | >                               |                     |
|       |    | > An instrument may perform     |                     |
|       |    | > this additional function only |                     |
|       |    | > if all transactions performed |                     |
|       |    | > by the instrument or by       |                     |
|       |    | > connected peripherals are     |                     |
|       |    | > printed on a ticket or label  |                     |
|       |    | > intended for the customer.    |                     |
|       |    | > This function shall not lead  |                     |
|       |    | > to confusion about the        |                     |
|       |    | > results of weighing and       |                     |
|       |    | > transaction. *(Note:          |                     |
|       |    | > Paraphrased from 4.14.4       |                     |
|       |    | > Special applications of a     |                     |
|       |    | > price computing instrument)*  |                     |
|       |    | > [\*) 4.7.1 does not apply to  |                     |
|       |    | > tare weighing values in these |                     |
|       |    | > instruments.]{.underline}     |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.2 | CN | > Change"... automatically onhy | P+                  |
|       |    | > if the preset..."in 4.7.2     |                     |
|       |    | > into"... automatically only   |                     |
|       |    | > if the preset...".            |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.2 | ZA | > Last Par:...may operate       | P+                  |
|       |    | > automatically only ~~onhy~~   |                     |
|       |    | > if the preset tare value....  |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.2 | UK | > "onhy" should be "only".      | P+                  |
+-------+----+---------------------------------+---------------------+
| 4.7.2 | US | > Typographical error in the    | P+                  |
|       |    | > last sentence. Preset tare    |                     |
|       |    | > devices may operate           |                     |
|       |    | > automatically ~~onhy~~        |                     |
|       |    | > [only]{.underline} if the . . |                     |
|       |    | > .                             |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.2 | CA | > Spelling mistake "Preset      | P+                  |
|       |    | > devices may operate           |                     |
|       |    | > automatically ~~onhy~~        |                     |
|       |    | > [only]{.underline} if the     |                     |
|       |    | > preset tare..."               |                     |
+-------+----+---------------------------------+---------------------+
| 4.7.3 | UK | > Refers to the 4^th^ paragraph | P+ see changes in   |
|       |    | > of Section 4.6.5 not being    | 2CD                 |
|       |    | > required (for preset tare),   |                     |
|       |    | > but it should probably refer  |                     |
|       |    | > to the 2^nd^ paragraph of     |                     |
|       |    | > Section 4.6.5, as the Notes   |                     |
|       |    | > should not be classed as      |                     |
|       |    | > paragraphs.                   |                     |
+-------+----+---------------------------------+---------------------+
| 4.10  | CN | In 4.10, we suggest adding the  | P+                  |
|       |    | word "equivalent to gross zero" |                     |
|       |    | at the back of "...a negative   | P+                  |
|       |    | net value", i.e.                |                     |
|       |    |                                 |                     |
|       |    | "- from a greater to a smaller  |                     |
|       |    | weighing range, when there is   |                     |
|       |    | no load on the load receptor,   |                     |
|       |    | and the indication is zero or   |                     |
|       |    | at a negative net value         |                     |
|       |    | equivalent to gross zero; the   |                     |
|       |    | tare operation shall be         |                     |
|       |    | cancelled, and zero shall be    |                     |
|       |    | set to ± 0.25 e~1~, both        |                     |
|       |    | automatically."                 |                     |
|       |    |                                 |                     |
|       |    | > "- only from a greater to the |                     |
|       |    | > smallest weighing range when  |                     |
|       |    | > there is no load on the load  |                     |
|       |    | > receptor, and the indication  |                     |
|       |    | > is zero or at a negative net  |                     |
|       |    | > value equivalent to gross     |                     |
|       |    | > zero; the tare operation      |                     |
|       |    | > shall be cancelled and zero   |                     |
|       |    | > shall be set to ± 0.25 e~1~,  |                     |
|       |    | > both automatically."          |                     |
+-------+----+---------------------------------+---------------------+
| 4     | JP | > As for the last sentence "... | The meaning is: If  |
| .11.5 |    | > but only if the correct zero  | the instrument (or  |
|       |    | > position has been             | the display) is in  |
|       |    | > automatically checked         | the switched-off    |
|       |    | > before", what does this mean? | mode and is then    |
|       |    | > Example of this case is       | loaded, the         |
|       |    | > requested to give.            | instrument will     |
|       |    |                                 | normally switch-on  |
|       |    |                                 | automatically and   |
|       |    |                                 | display the actual  |
|       |    |                                 | weight value. This  |
|       |    |                                 | cannot be permitted |
|       |    |                                 | unless the operator |
|       |    |                                 | or user of the      |
|       |    |                                 | instrument has      |
|       |    |                                 | checked the         |
|       |    |                                 | instrument for the  |
|       |    |                                 | correct zero        |
|       |    |                                 | position before     |
|       |    |                                 | loading. An         |
|       |    |                                 | alternative to zero |
|       |    |                                 | checking by the     |
|       |    |                                 | operator is that    |
|       |    |                                 | the instrument      |
|       |    |                                 | itself checks       |
|       |    |                                 | itself              |
|       |    |                                 | automatically for   |
|       |    |                                 | the correct zero    |
|       |    |                                 | position in the     |
|       |    |                                 | switch-off mode and |
|       |    |                                 | prevents the        |
|       |    |                                 | display of weight   |
|       |    |                                 | values if the zero  |
|       |    |                                 | position was not    |
|       |    |                                 | correct.            |
+-------+----+---------------------------------+---------------------+
| 4     | UK | > Delete the sentence "In any   | P- We think this    |
| .11.5 |    | > mode and at any time it shall | hint is important.  |
|       |    | > be possible to switch back to |                     |
|       |    | > the normal weighing mode" as  |                     |
|       |    | > this is a basic requirement   |                     |
|       |    | > of the instrument.            |                     |
+-------+----+---------------------------------+---------------------+
| 4     | CA | **Preset Tare Device**          | P+ We agree but     |
| .13.4 |    |                                 | suggest, however,   |
|       |    | The last sentence of this       | to use "should"     |
|       |    | section should be amended as    | instead of "must",  |
|       |    | follows:                        | because there were  |
|       |    |                                 | no serious problems |
|       |    | Where a preset tare is          | in the past, and    |
|       |    | associated with a price look up | "must" would        |
|       |    | (PLU) the preset tare value     | probably not be     |
|       |    | ~~may~~ must be cancelled at    | supported by a      |
|       |    | the same time as the PLU is     | majority of TC9/SC1 |
|       |    | cancelled.                      | members.            |
|       |    |                                 |                     |
|       |    | Rationale If a PLU is cancelled | Exceptions should   |
|       |    | and there was a tare associated | be possible,        |
|       |    | with that PLU, then you would   | because one can     |
|       |    | expect the tare to be cancelled | think of special    |
|       |    | as well. Failure to do so will  | cases where the PLU |
|       |    | ensure that the wrong tare      | is changed while    |
|       |    | value remains in the machine,   | the preset tare     |
|       |    | leading to potential incorrect  | value remains.      |
|       |    | measurement on subsequent       |                     |
|       |    | transactions.                   |                     |
|       |    |                                 |                     |
|       |    | > **Agree with Secretariat's    |                     |
|       |    | > response, however, if the     |                     |
|       |    | > preset tare is acssociated    |                     |
|       |    | > with the PLU, what rationale  |                     |
|       |    | > could there possibly be for   |                     |
|       |    | > keeping it after the PLU is   |                     |
|       |    | > cancelled?**                  |                     |
+-------+----+---------------------------------+---------------------+
| 4     | AU | > 4.13.6 Visibility             | P+ But slightly     |
| .13.6 |    | >                               | changed because all |
|       |    | > Change to the following:      | applicable          |
|       |    | >                               | requirements of     |
|       |    | > All primary indications shall | chapter 4 have to   |
|       |    | > be indicated clearly and      | be observed (see    |
|       |    | > simultaneously to both the    | also 4.13.6 ZA).    |
|       |    | > vendor and the customer.      |                     |
|       |    | > Refer also to 4, 4.2.1,       | P- 4.2.1 is also    |
|       |    | > 4.2.2, 4.6.5 and 4.4.4 which  | valid for this      |
|       |    | > stress the need to avoid      | chapter: The        |
|       |    | > ambiguity in regard to the    | primary indications |
|       |    | > indications provided.         | [shall be of a      |
|       |    | >                               | size, shape and     |
|       |    | > On digital devices that       | clarity for reading |
|       |    | > display primary indications,  | to be               |
|       |    | > the numerical figures         | easy]{.underline},  |
|       |    | > displayed to the customer     | see our response to |
|       |    | > shall be at least 9.5 mm      | 4.2.1.              |
|       |    | > high, except in the case of   |                     |
|       |    | > any displayed tare or preset  |                     |
|       |    | > tare value which shall be at  |                     |
|       |    | > least 6.5 mm high. The        |                     |
|       |    | > reduced size allowance for    |                     |
|       |    | > the tare or preset tare value |                     |
|       |    | > is intended to provide        |                     |
|       |    | > additional possibilities for  |                     |
|       |    | > distinguishing the tare or    |                     |
|       |    | > preset tare value from the    |                     |
|       |    | > net weight, to reduce         |                     |
|       |    | > ambiguity.                    |                     |
|       |    | >                               |                     |
|       |    | > The size of designations such |                     |
|       |    | > as TARE, NET and the size of  |                     |
|       |    | > any zero indication device    |                     |
|       |    | > shall be at least 4 mm high.  |                     |
|       |    | >                               |                     |
|       |    | > These sizes are intended as   |                     |
|       |    | > an absolute minimum --        |                     |
|       |    | > manufacturers are strongly    |                     |
|       |    | > advised to design to achieve  |                     |
|       |    | > larger sizes than this.       |                     |
|       |    | >                               |                     |
|       |    | > On an instrument to be used   |                     |
|       |    | > with weights **it shall be    |                     |
|       |    | > possible to distinguish the   |                     |
|       |    | > value of the weights.**       |                     |
|       |    |                                 |                     |
|       |    | *Explanation: Currently there   |                     |
|       |    | is no specification regarding   |                     |
|       |    | size of such designations so    |                     |
|       |    | that manufacturers do not have  |                     |
|       |    | a clear understanding of what   |                     |
|       |    | is acceptable, and approval     |                     |
|       |    | authorities do not have         |                     |
|       |    | objective criteria for          |                     |
|       |    | rejecting instruments where the |                     |
|       |    | size of such designations has   |                     |
|       |    | been reduced to be 'too small'. |                     |
|       |    | The readability of displays is  |                     |
|       |    | suffering as a result and this  |                     |
|       |    | needs to be remedied. In regard |                     |
|       |    | to the size of the indication   |                     |
|       |    | of a tare value, whilst we      |                     |
|       |    | would prefer that all           |                     |
|       |    | indications be at least 9.5 mm, |                     |
|       |    | we feel that the need to ensure |                     |
|       |    | a clear distinction from the    |                     |
|       |    | net weight value is of greater  |                     |
|       |    | importance, and hence have      |                     |
|       |    | proposed allowing a small size  |                     |
|       |    | for the tare value. Note that   |                     |
|       |    | this problem has arisen as      |                     |
|       |    | instruments are increasingly    |                     |
|       |    | incorporating preset tare       |                     |
|       |    | devices, so that the value must |                     |
|       |    | be displayed in accordance with |                     |
|       |    | 4.13.4.*                        |                     |
+-------+----+---------------------------------+---------------------+
| 4     | ZA | In terms of this clause an      | You are right,      |
| .13.6 |    | instrument with only one set of | sorry for           |
|       |    | primary indications will be     | confusion.          |
|       |    | acceptable if both the vendor   |                     |
|       |    | and the customer are on the     | P+ We suggest,      |
|       |    | same side of the instrument,    | however, a          |
|       |    | our interpretation.             | shortened text with |
|       |    |                                 | references to       |
|       |    | According to the secretariat's  | 4.13.1 and 4.14.1,  |
|       |    | response on previous WD "Two    | see 2CD.            |
|       |    | sets are necessary"             |                     |
|       |    |                                 |                     |
|       |    | We propose the following to     |                     |
|       |    | clear any confusion:            |                     |
|       |    |                                 |                     |
|       |    | All primary indications shall   |                     |
|       |    | be indicated clearly to both    |                     |
|       |    | the vendor and the customer,    |                     |
|       |    | and in instances where the      |                     |
|       |    | vendor and customer are on      |                     |
|       |    | opposite sides of the           |                     |
|       |    | instrument when the measurement |                     |
|       |    | takes place, primary            |                     |
|       |    | indications on both sides shall |                     |
|       |    | be provided.                    |                     |
+-------+----+---------------------------------+---------------------+
| 4.    | AU | > 4.13.11 Self-service          | P- No need to spell |
| 13.11 |    | > instrument                    | out what is really  |
|       |    | >                               | obvious and what    |
|       |    | > Add the following:            | the market          |
|       |    | >                               | regulates by        |
|       |    | > A self-service instrument     | itself.             |
|       |    | > (when in normal use) shall    |                     |
|       |    | > have a limited set of         |                     |
|       |    | > functionality and shall be    |                     |
|       |    | > designed such that it can be  |                     |
|       |    | > used easily by an unskilled   |                     |
|       |    | > operator. Potential for       |                     |
|       |    | > incorrect operation resulting |                     |
|       |    | > in incorrect weighing shall   |                     |
|       |    | > be minimised.                 |                     |
|       |    |                                 |                     |
|       |    | *Explanation: It seems          |                     |
|       |    | self-evident, however it is     |                     |
|       |    | becoming apparent that          |                     |
|       |    | sometimes the obvious does need |                     |
|       |    | to be spelt out.*               |                     |
+-------+----+---------------------------------+---------------------+
| 4.1   | AU | > 4.14.4.1 Non-weighed articles | P+ We suggest,      |
| 4.4.1 |    | >                               | however, to         |
|       |    | > Add an acceptable solution:   | restrict the        |
|       |    | >                               | acceptable solution |
|       |    | > Acceptable solution: A number | to the number of    |
|       |    | > of articles shown on the      | articles only (see  |
|       |    | > weight display may be         | new acceptable      |
|       |    | > distinguished from a weight   | solution in         |
|       |    | > by including a designation    | 4.14.4.1, 2CD).     |
|       |    | > such as PC or PCS (indicating |                     |
|       |    | > piece or pieces). The price   |                     |
|       |    | > for one article on the unit   |                     |
|       |    | > price display may include a   |                     |
|       |    | > designation such as EA        |                     |
|       |    | > (indicating each).            |                     |
|       |    |                                 |                     |
|       |    | *Explanation: The use of a      |                     |
|       |    | number in the weight display    |                     |
|       |    | (for an unweighed item) has     |                     |
|       |    | been seen. This is not entirely |                     |
|       |    | unambiguous and could possibly  |                     |
|       |    | be taken for a weight.          |                     |
|       |    | Manufacturers should be guided  |                     |
|       |    | to options such as PC which     |                     |
|       |    | cannot be confused with a       |                     |
|       |    | weight value.*                  |                     |
+-------+----+---------------------------------+---------------------+
| 4.1   | US | U.S. manufacturers have         | P- See our response |
| 4.4.3 |    | recently reported that rounding | to 4.7.1 US         |
|       |    | of tare weighing results are    |                     |
|       |    | inconsistently applied when a   | P+ Instead of       |
|       |    | tare weighing result is stored  | paraphrasing 4.14.4 |
|       |    | into a temporary memory while   | we think, however,  |
|       |    | the operator is working with    | a simple reference  |
|       |    | more than one customer at a     | to 4.14.4 could be  |
|       |    | time (e.g. vehicle weighing     | sufficient, see     |
|       |    | applications).                  | 2CD.                |
|       |    |                                 |                     |
|       |    | One issuing authority stated    |                     |
|       |    | that the tare weighing result   |                     |
|       |    | became a preset tare since it   |                     |
|       |    | was stored into a temporary     |                     |
|       |    | memory location while the       |                     |
|       |    | vehicle was being loaded and    |                     |
|       |    | therefore rounded to the        |                     |
|       |    | nearest scale division. During  |                     |
|       |    | the time the vehicle is loaded, |                     |
|       |    | the operator can weigh other    |                     |
|       |    | vehicles (this is called a      |                     |
|       |    | weigh-in/weigh-out procedure in |                     |
|       |    | the U.S.). A different issuing  |                     |
|       |    | authority stated that the tare  |                     |
|       |    | value should remain stored to   |                     |
|       |    | the internal resolution of the  |                     |
|       |    | instrument since tare was       |                     |
|       |    | determined on a tare weighing   |                     |
|       |    | device.                         |                     |
|       |    |                                 |                     |
|       |    | The U.S. agrees that a          |                     |
|       |    | predetermined tare introduced   |                     |
|       |    | into an instrument by means     |                     |
|       |    | such as keystroke, code, and    |                     |
|       |    | stored in memory for multiple   |                     |
|       |    | transactions should be          |                     |
|       |    | considered a preset tare value  |                     |
|       |    | and rounded to the value of the |                     |
|       |    | scale division. The U.S. also   |                     |
|       |    | agrees that a net weight can be |                     |
|       |    | calculated as the difference    |                     |
|       |    | the gross and tare weights      |                     |
|       |    | taken to the internal           |                     |
|       |    | resolution of the instrument.   |                     |
|       |    | However, we do not understand   |                     |
|       |    | the reason for the rounding of  |                     |
|       |    | tare weighing results that are  |                     |
|       |    | automatically entered into a    |                     |
|       |    | temporary memory, along with    |                     |
|       |    | other customer and transaction  |                     |
|       |    | information, when no rounding   |                     |
|       |    | is required for price computing |                     |
|       |    | instruments.                    |                     |
|       |    |                                 |                     |
|       |    | The U.S. recommends that tare   |                     |
|       |    | weighing values automatically   |                     |
|       |    | entered into a memory device    |                     |
|       |    | should not be considered as     |                     |
|       |    | preset tare values and requests |                     |
|       |    | that the Secretariat and the    |                     |
|       |    | members of TC9/SC1 consider     |                     |
|       |    | renumbering and amending sub    |                     |
|       |    | clause 4.14.4.3 as follows:     |                     |
|       |    |                                 |                     |
|       |    | > ~~4.14.4.3~~                  |                     |
|       |    | > [4.20]{.underline}            |                     |
|       |    | > Multi-vendor or multiple      |                     |
|       |    | > customer operation            |                     |
|       |    | > [\*)]{.underline}             |                     |
|       |    | >                               |                     |
|       |    | > An instrument may be designed |                     |
|       |    | > to be used by more than one   |                     |
|       |    | > vendor or to serve more than  |                     |
|       |    | > one customer at the same      |                     |
|       |    | > time, provided that the       |                     |
|       |    | > connection between the        |                     |
|       |    | > transactions and the relevant |                     |
|       |    | > vendor or customer is         |                     |
|       |    | > appropriately identified.     |                     |
|       |    |                                 |                     |
|       |    | An instrument may perform this  |                     |
|       |    | additional function only if all |                     |
|       |    | transactions performed by the   |                     |
|       |    | instrument or by connected      |                     |
|       |    | peripherals are printed on a    |                     |
|       |    | ticket or label intended for    |                     |
|       |    | the customer. This function     |                     |
|       |    | shall not lead to confusion     |                     |
|       |    | about the results of weighing   |                     |
|       |    | and transaction. *(Note:        |                     |
|       |    | Paraphrased from 4.14.4 Special |                     |
|       |    | applications of a price         |                     |
|       |    | computing instrument)*          |                     |
|       |    |                                 |                     |
|       |    | [\*) 4.7.1 does not apply to    |                     |
|       |    | tare weighing values in these   |                     |
|       |    | instruments.]{.underline}       |                     |
+-------+----+---------------------------------+---------------------+
| 4.16  | CN | > For this fixed values of      | P+ "Obviously" has  |
|       |    | > weight in 4.16 mentioned      | been added in 2CD   |
|       |    | > --"Printing of labels with    |                     |
|       |    | > fixed values of weight, unit  |                     |
|       |    | > price and price to pay is     |                     |
|       |    | > allowed provided that the     |                     |
|       |    | > weighing mode is made         |                     |
|       |    | > inoperative." When printing   |                     |
|       |    | > it is should expressed that   |                     |
|       |    | > the weight value is           |                     |
|       |    | > theoretical weight or the     |                     |
|       |    | > permissible deviation of      |                     |
|       |    | > weight.                       |                     |
+-------+----+---------------------------------+---------------------+
| 4     | CA | See also 3.9.1.1 Instruments    | P+, see also        |
| .18.1 |    | liable to be tilted.            | 3.9.1.1             |
|       |    |                                 |                     |
|       |    | The first sentence reads in     |                     |
|       |    | part:                           |                     |
|       |    |                                 |                     |
|       |    | "The instrument shall have      |                     |
|       |    | appropriate means to indicate   |                     |
|       |    | that ther limiting value has    |                     |
|       |    | been ~~reached or~~ exceeded."  |                     |
|       |    | As in 3.9.1.1, the *words       |                     |
|       |    | ~~reached or~~* should be       |                     |
|       |    | struck out and only *exceeded*  |                     |
|       |    | left in.                        |                     |
+-------+----+---------------------------------+---------------------+
| 4     | NL | > The last part of the          | P- See our response |
| .18.1 |    | > paragraph about the           | under "General"     |
|       |    | > [tests]{.underline} for the   |                     |
|       |    | > tilt sensor should be moved   |                     |
|       |    | > to clause 8                   |                     |
|       |    | >                               |                     |
|       |    | > Last sentence: *"The OIML     |                     |
|       |    | > Test Report \....*" should be |                     |
|       |    | > moved to Annex A.             |                     |
+-------+----+---------------------------------+---------------------+
| 4     | PL | > paragraph 7 line 2: one of    | P+                  |
| .18.1 |    | > double 'the' should be        |                     |
|       |    | > deleted                       |                     |
+-------+----+---------------------------------+---------------------+
| 4     | UK | > seventh paragraph: "\...the   | P+                  |
| .18.1 |    | > the\...".                     |                     |
|       |    | >                               | P+ "halls with      |
|       |    | > The \*footnote relating to    | uneven floors"      |
|       |    | > "fish auction halls" is too   |                     |
|       |    | > specific.                     | P+                  |
|       |    | >                               |                     |
|       |    | > In addition, "in-door" should |                     |
|       |    | > be the single word "indoor",  |                     |
|       |    | > as "in-door" suggests inside  |                     |
|       |    | > that it is inside a door.     |                     |
+-------+----+---------------------------------+---------------------+
| 4     | UK | > This should be re-written as  | P+ We propose,      |
| .18.2 |    | > at present it implies that    | however, a slightly |
|       |    | > other mobile instruments need | changed wording,    |
|       |    | > not have a levelling device.  | see 2CD             |
|       |    | > These instruments shall have  |                     |
|       |    | > a levelling device which can  |                     |
|       |    | > be operated easily without    |                     |
|       |    | > tools.                        |                     |
+-------+----+---------------------------------+---------------------+
| 4.19  | AT | > Portable                      | P+                  |
|       |    | > inst[r]{.underline}uments     |                     |
+-------+----+---------------------------------+---------------------+
| 4.19  | CA | > The second paragraph          | P+ Will be          |
|       |    | > specifies that the applicant  | considered,         |
|       |    | > must provide a description of | although wording    |
|       |    | > the appropriate mounting      | has already been    |
|       |    | > surface; however, the         | changed in the 1CD  |
|       |    | > appropriateness of such a     |                     |
|       |    | > mounting surface and other    | P- We understand    |
|       |    | > metrologically significant    | your point of view, |
|       |    | > installation-dependent        | but in order to     |
|       |    | > parameters (e.g. length and   | avoid possible      |
|       |    | > angle of approaches) should   | misunderstandings   |
|       |    | > be left to the discretion of  | the wording should  |
|       |    | > the national authority. This  | be kept.            |
|       |    | > should be specified in the    |                     |
|       |    | > Recommendation.               | P+                  |
|       |    | >                               |                     |
|       |    | > Canada agrees with            |                     |
|       |    | > Secretariat's response.       |                     |
|       |    | >                               |                     |
|       |    | > The two Notes in the 1 CD are |                     |
|       |    | > very 'wordy'. Would it simply |                     |
|       |    | > be better to state "the load  |                     |
|       |    | > must be entirely supported by |                     |
|       |    | > the load receiving            |                     |
|       |    | > element(s)"?                  |                     |
|       |    | >                               |                     |
|       |    | > Spelling 4.19 "Portable       |                     |
|       |    | > Weighing ~~instuments~~       |                     |
|       |    | > [instruments]{.underline} for |                     |
|       |    | > weighing road vehicles"       |                     |
+-------+----+---------------------------------+---------------------+
| 4.19  | CZ | > This section does not clearly | P- There was a      |
|       |    | > state the purpose of these    | clear vote to       |
|       |    | > instruments. Axle/Wheel       | integrate these     |
|       |    | > wheighers are originaly       | instruments into    |
|       |    | > designed for traffic control  | R76. By both        |
|       |    | > of road vehicles to determine | Terminology         |
|       |    | > not only the total load but   | T.1.2.12 and        |
|       |    | > also the axle loads. If only  | Chapter 4.19 we     |
|       |    | > instrument using groups of    | think it is         |
|       |    | > associated axle or wheel load | sufficiently clear  |
|       |    | > weighers that indicates only  | that R76 covers     |
|       |    | > total load of a vehicle is    | only weighbridges   |
|       |    | > allowed (and we understand    | and groups of       |
|       |    | > the paragraphs of this        | associated          |
|       |    | > section this way since it is  | non-automatic axle  |
|       |    | > not clear that also           | (or wheel) load     |
|       |    | > indication of axle loads is   | weighers that       |
|       |    | > legaly allowed) such          | determine           |
|       |    | > instrument is to be used for  | simultaneously the  |
|       |    | > trade purposes to determine   | mass of a road      |
|       |    | > mass of a vehicle only        | vehicle with        |
|       |    | > similary as, let us say,      | [all]{.underline}   |
|       |    | > common weighbridges. This     | axles (or wheels)   |
|       |    | > probabaly should not be the   | being               |
|       |    | > purpose of this section. On   | [simultan           |
|       |    | > the other hand we understand  | eously]{.underline} |
|       |    | > that to set up simple rules   | supported by        |
|       |    | > for this kind of instruments  | appropriate parts   |
|       |    | > to be legaly controled is     | of a load receptor. |
|       |    | > nearly impossible. From the   |                     |
|       |    | > reasons we think that         |                     |
|       |    | > treating of these instruments |                     |
|       |    | > should depend on national     |                     |
|       |    | > legislations and consequently |                     |
|       |    | > we propose to withdraw these  |                     |
|       |    | > instruments from the scope of |                     |
|       |    | > this recommendation and only  |                     |
|       |    | > mention in this section that  |                     |
|       |    | > the use and the requirements  |                     |
|       |    | > are covered by national       |                     |
|       |    | > legislations.                 |                     |
+-------+----+---------------------------------+---------------------+
| 4.19  | NL | > 1^st^ paragraph about         | P+ see 2 CD         |
|       |    | > application (**for approval   |                     |
|       |    | > or for verification?**) and   | P- see our response |
|       |    | > OIML certificate: This is not | in "General"        |
|       |    | > a requirement for the         |                     |
|       |    | > instrument (see title of      |                     |
|       |    | > clause 4).                    |                     |
|       |    | >                               |                     |
|       |    | > So this should be moved to    |                     |
|       |    | > chapter 8.                    |                     |
+-------+----+---------------------------------+---------------------+
| 4.19  | UK | > "instuments" should be        | P+                  |
|       |    | > "instruments".                |                     |
+-------+----+---------------------------------+---------------------+
| 5     | CA | **5 -- *Technical* Requirements | P+                  |
|       |    | for Electronic Instruments**    |                     |
|       |    |                                 |                     |
|       |    | Add the word "Technical" to the |                     |
|       |    | title to remain consistent with |                     |
|       |    | other sections.                 |                     |
|       |    |                                 |                     |
|       |    | **Canada agrees with            |                     |
|       |    | Secretariat's response.**       |                     |
+-------+----+---------------------------------+---------------------+
| 5.3.3 | NL | > *"shall be subjected to span  | Unambiguously for   |
|       |    | > stability test*" (**type test | type approval       |
|       |    | > and/or verification?**).      | testing only, not   |
|       |    | >                               | mentioned under     |
|       |    | > This first sentence should be | 8.3.3.              |
|       |    | > moved to clause 8.            |                     |
|       |    |                                 | P- Please refer to  |
|       |    |                                 | our response under  |
|       |    |                                 | "General" NL        |
+-------+----+---------------------------------+---------------------+
| 5.4   | NL | > These [tests]{.underline}     | P- See 5.3.3 NL     |
|       |    | > **(type tests or verification |                     |
|       |    | > ?**) should be moved to       |                     |
|       |    | > clause 8.                     |                     |
+-------+----+---------------------------------+---------------------+
| 5.4.3 | SI | > In Table 10 some tests from   | P+                  |
|       |    | > B.3 are missing: surge,       |                     |
|       |    | > immunity to radiated EMF and  |                     |
|       |    | > conducted disturbances        |                     |
|       |    | > (instead of electromagnetic   |                     |
|       |    | > susceptibility), transients.  |                     |
+-------+----+---------------------------------+---------------------+
| 5.5   | JP | > Should the title "Additional  | P- It is            |
|       |    | > requirements for              | sufficiently clear  |
|       |    | > software-controlled           | that R76 applies to |
|       |    | > electronic deices" be         | instruments under   |
|       |    | > "Additional requirements for  | legal control only  |
|       |    | > software-controlled           |                     |
|       |    | > electronic devices for legal  |                     |
|       |    | > metrology".                   |                     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | CA | Devices with embedded           | We don't think so.  |
| /     |    | software/Personal Computers ... | "Embedded software" |
| 5.5.2 |    | with loadable software          | clearly means the   |
|       |    |                                 | [so                 |
|       |    | The definitions for embedded    | ftware]{.underline} |
|       |    | software and loadable software  | itself which can,   |
|       |    | are somewhat confusing.         | of course, be       |
|       |    | Clearly, a ROM is embedded,     | stored in any       |
|       |    | however is an EEPROM embedded   | memory component    |
|       |    | or loadable? What about Flash   | (ROM, RAM, Flash    |
|       |    | RAM? Even newer PC's use Flash  | etc.).              |
|       |    | RAM for their BIOS settings.    |                     |
|       |    |                                 | We do not quite     |
|       |    | The phrase 'cannot be modified  | understand the      |
|       |    | or uploaded via any interface'  | concern, because    |
|       |    | also causes concern as all      | for the embedded    |
|       |    | types of PROM can be changed,   | software the        |
|       |    | although some more easily than  | consequence simply  |
|       |    | others -- most require external | is that the         |
|       |    | programmers. Flash RAM however  | hardware component  |
|       |    | can be changed within the       | (PROM etc.) in      |
|       |    | instrument/PC.                  | which it is stored  |
|       |    |                                 | must be             |
|       |    | > Unfortunately, as the         | appropriately       |
|       |    | > distinction between an        | secured so that     |
|       |    | > instrument and a PC continues | after securing the  |
|       |    | > to become less clear, it will | software can no     |
|       |    | > be more difficult to define   | longer be modified  |
|       |    | > each in legislation. Perhaps  | or uploaded.        |
|       |    | > this is best left to each     | Otherwise the       |
|       |    | > approval laboratory to        | software will no    |
|       |    | > define?                       | longer be           |
|       |    | >                               | "embedded" and para |
|       |    | > To clarify then, all software | 5.5.2 would apply.  |
|       |    | > that can be 'secured' is      |                     |
|       |    | > considered 'embedded' even if | P- We agree that    |
|       |    | > it can be changed after the   | the distinction     |
|       |    | > securing provision has been   | between a           |
|       |    | > by-passed? If this is true,   | "built-for-purpose" |
|       |    | > then why not simply state in  | instrument and a PC |
|       |    | > 5.5.1 that the software is    | continues to become |
|       |    | > 'secured' rather than         | less clear. We do   |
|       |    | > 'embedded'?                   | not agree, however, |
|       |    | >                               | that the definition |
|       |    | > The current wording seems to  | should be left to   |
|       |    | > indicate that there are only  | the approval        |
|       |    | > hard wired instruments and    | laboratory. We      |
|       |    | > PC's, when in fact many newer | think with the      |
|       |    | > devices are programmable      | addition to the     |
|       |    | > (with sealing &/or audit      | Note under 5.5.2 it |
|       |    | > trails), but would not be     | is now sufficiently |
|       |    | > considered PC's.              | clear that if the   |
|       |    | >                               | software is not     |
|       |    | > Perhaps it is the different   | "embedded" in the   |
|       |    | > securing philosophy that is   | sense of 5.5.1 the  |
|       |    | > causing issue. Canada does    | instrument is       |
|       |    | > not require that all          | considered as a     |
|       |    | > parameters be protected       | "PC" so that 5.5.2  |
|       |    | > against change, provided that | applies. It should  |
|       |    | > the change is identificable   | be sufficiently     |
|       |    | > as with an audit trail. The   | clear from the      |
|       |    | > wording in the CD seems to    | heading of 5.5.2    |
|       |    | > require these devices to be   | that this para not  |
|       |    | > treated as PC's.              | only covers "PCs"   |
|       |    |                                 | but also            |
|       |    |                                 | "instruments with   |
|       |    |                                 | PC components, and  |
|       |    |                                 | other instruments,  |
|       |    |                                 | devices, modules,   |
|       |    |                                 | and elements with   |
|       |    |                                 | programmable or     |
|       |    |                                 | loadable legally    |
|       |    |                                 | relevant software". |
|       |    |                                 |                     |
|       |    |                                 | "Embedded" (in      |
|       |    |                                 | 5.5.1) cannot be    |
|       |    |                                 | exchanged by        |
|       |    |                                 | "secured" because   |
|       |    |                                 | the software of     |
|       |    |                                 | "5.5.2 devices"     |
|       |    |                                 | must, of course, be |
|       |    |                                 | adequately secured, |
|       |    |                                 | too!                |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | C  | > Please add a third acceptable | P- The two          |
|       | EC | > solution: displaying the      | acceptable          |
|       | IP | > software identification at    | solutions provided  |
|       |    | > start-up of the instrument.   | seem to be          |
|       |    |                                 | sufficient. In      |
|       |    |                                 | addition,           |
|       |    |                                 | displaying the SW   |
|       |    |                                 | identification only |
|       |    |                                 | at start-up can     |
|       |    |                                 | normally not be     |
|       |    |                                 | considered          |
|       |    |                                 | sufficient, if      |
|       |    |                                 | there is no         |
|       |    |                                 | possibility to      |
|       |    |                                 | display the         |
|       |    |                                 | software            |
|       |    |                                 | identification also |
|       |    |                                 | in the normal       |
|       |    |                                 | operation mode.     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | CN | > Change"...by the instrument   | P+                  |
|       |    | > amd listed in the OIML        |                     |
|       |    | > \..."in 5.5.1 into"...by the  |                     |
|       |    | > instrument and listed in the  |                     |
|       |    | > OIML \...".                   |                     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | JP | > Should the title "Devices     | P- R76 concerns     |
|       |    | > with embedded software" be    | instruments under   |
|       |    | > "Devices with embedded        | legal control only  |
|       |    | > software for legal            |                     |
|       |    | > metrology"?                   | No, because the     |
|       |    | >                               | list has already    |
|       |    | > When software data related    | been reduced to the |
|       |    | > with legal functions are      | minimum.            |
|       |    | > stored in ROM with hardware   |                     |
|       |    | > protection means, could the   |                     |
|       |    | > contents of the documentation |                     |
|       |    | > required to submit be reduced |                     |
|       |    | > from those listed?            |                     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | NL | > The necessary                 | P- Please refer to  |
|       |    | > [tests]{.underline} and the   | our response under  |
|       |    | > [documentation]{.underline}   | "General" and 5.3.3 |
|       |    | > to be submitted (**for type   |                     |
|       |    | > tests or verification?**) are |                     |
|       |    | > no requirements for the       |                     |
|       |    | > device but a matter of        |                     |
|       |    | > tests/evaluation.             |                     |
|       |    | >                               |                     |
|       |    | > So this information should be |                     |
|       |    | > moved to clause 8.            |                     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | ZA | > Last sentence: ...by the      | P+                  |
|       |    | > instrument and ~~amd~~ listed |                     |
|       |    | > in the OIML Certificate.      |                     |
+-------+----+---------------------------------+---------------------+
| 5.5.1 | UK | > (line beginning "The software | P+                  |
|       |    | > identification\..."): "amd"   |                     |
|       |    | > should be "and".              | P- No software      |
|       |    | >                               | description is      |
|       |    | > Although this section refers  | required, but only  |
|       |    | > only to "embedded software"   | limited             |
|       |    | > which "\...cannot be modified | descriptions of the |
|       |    | > or uploaded\...", it then     | legally relevant    |
|       |    | > demands software              | [func               |
|       |    | > descriptions, identifications | tions]{.underline}, |
|       |    | > (continuously or on demand),  | software            |
|       |    | > and securing measures. Is     | [identifi           |
|       |    | > this necessary?               | cation]{.underline} |
|       |    |                                 | and [securing       |
|       |    |                                 | me                  |
|       |    |                                 | asures]{.underline} |
|       |    |                                 | are required. We    |
|       |    |                                 | think this is the   |
|       |    |                                 | absolute minimum    |
|       |    |                                 | that must be        |
|       |    |                                 | required for        |
|       |    |                                 | software-controlled |
|       |    |                                 | electronic          |
|       |    |                                 | instruments and     |
|       |    |                                 | devices.            |
+-------+----+---------------------------------+---------------------+
| 5.5.2 | JP | > According to the description  | We think there is a |
|       |    | > in this section, even the     | misunderstanding:   |
|       |    | > instruments combined with     | R76 does not define |
|       |    | > measuring modules and general | whether an          |
|       |    | > purpose PC's could be         | instrument is under |
|       |    | > understood to be legal        | legal control or    |
|       |    | > measuring instruments, when   | not. This is        |
|       |    | > they meet the requirements.   | defined by national |
|       |    | > With this expansion of the    | laws or             |
|       |    | > scope, is it possible to      | regulations. But if |
|       |    | > control those instruments     | national            |
|       |    | > legally?                      | regulations (based  |
|       |    |                                 | on R76) define that |
|       |    |                                 | a NAWI is under     |
|       |    |                                 | legal control for a |
|       |    |                                 | special             |
|       |    |                                 | application, then   |
|       |    |                                 | para 5.5.2 would    |
|       |    |                                 | apply for a "PC" or |
|       |    |                                 | similar             |
|       |    |                                 | software-controlled |
|       |    |                                 | device.             |
+-------+----+---------------------------------+---------------------+
| 5.5   | C  | > Category 3: Power supply as   | P+ See changes in   |
| .2.1\ | EC | > for category 2, other parts   | table 11            |
| Table | IP | > as for category 4             |                     |
| 11    |    |                                 |                     |
+-------+----+---------------------------------+---------------------+
| 5.5   | NL | > The necessary                 | P- Please refer to  |
| .2.1\ |    | > [tests]{.underline} and the   | our response under  |
| Ta    |    | > [documentation]{.underline}   | "General" and 5.3.3 |
| ble11 |    | > to be submitted (**for type   |                     |
|       |    | > tests or verification?**) are | P- No, it is really |
|       |    | > no requirements for the       | meant "pattern" for |
|       |    | > device but a matter of        | testing and not     |
|       |    | > tests/evaluation.             | "type"              |
|       |    | >                               |                     |
|       |    | > So this information should be |                     |
|       |    | > moved to clause 8.            |                     |
|       |    | >                               |                     |
|       |    | > The word "*pattern*" should   |                     |
|       |    | > be replaced by "*type*"       |                     |
|       |    | > (refer to VIML).              |                     |
+-------+----+---------------------------------+---------------------+
| 5.    | JP | > In item d, total 11 special   | P- The list is      |
| 5.2.2 |    | > software documents are        | already rather      |
|       |    | > required in addition to the   | long. It will not   |
|       |    | > documentation outlined in     | be possible to      |
|       |    | > 8.2.1.2. The contents of      | provide a complete  |
|       |    | > those 11 documentations       | list of all         |
|       |    | > should be specified in more   | necessary           |
|       |    | > details. There may be some    | documentation       |
|       |    | > documentation that could not  | because it depends  |
|       |    | > be submitted, as they are     | on the design of    |
|       |    | > corporate secret.             | the special         |
|       |    |                                 | instrument. In most |
|       |    |                                 | cases descriptions  |
|       |    |                                 | are required rather |
|       |    |                                 | than secret         |
|       |    |                                 | documents like      |
|       |    |                                 | listings of the     |
|       |    |                                 | software code etc.. |
|       |    |                                 | In addition,        |
|       |    |                                 | 8.2.1.2 requires    |
|       |    |                                 | that all documents  |
|       |    |                                 | shall be kept       |
|       |    |                                 | confidential by the |
|       |    |                                 | approving authority |
|       |    |                                 | without             |
|       |    |                                 | distributing it to  |
|       |    |                                 | others, except to   |
|       |    |                                 | the extent agreed   |
|       |    |                                 | with the            |
|       |    |                                 | manufacturer.       |
+-------+----+---------------------------------+---------------------+
| 5.    | C  | > The checksum or other         | P+ See change in    |
| 5.3.2 | EC | > signature of the legally      | 5.5.3.2             |
|       | IP | > relevant data defined in the  |                     |
|       |    | > note may not be used for the  |                     |
|       |    | > single data sets but for the  |                     |
|       |    | > complete data storage memory. |                     |
|       |    | > Please delete the word "set"  |                     |
|       |    | > and modify the note to "...of |                     |
|       |    | > the data stored". Or          |                     |
|       |    | > alternatively modify to "...  |                     |
|       |    | > of the data set stored or of  |                     |
|       |    | > the complete storage memory." |                     |
+-------+----+---------------------------------+---------------------+
| 5.    | UK | > What purpose is served by     | P- If stored        |
| 5.3.6 |    | > requiring the device that is  | weighing results    |
|       |    | > capable of displaying or      | (legally relevant   |
|       |    | > printing the data be subject  | data) shall be      |
|       |    | > to legal control. Surely it   | verified with a     |
|       |    | > is better that the data can   | display or printer, |
|       |    | > be displayed or printed on    | this device must be |
|       |    | > any suitable device, provided | subject to legal    |
|       |    | > that the display or print     | control! It is the  |
|       |    | > command does not also cause   | same principle as   |
|       |    | > the data to be deleted from   | if weighing results |
|       |    | > the storage device. Delete    | of a weighing       |
|       |    | > this section.                 | instrument are      |
|       |    |                                 | displayed or        |
|       |    |                                 | printed, it is      |
|       |    |                                 | evident that the    |
|       |    |                                 | instrument shall be |
|       |    |                                 | subject to legal    |
|       |    |                                 | control. Otherwise  |
|       |    |                                 | the whole procedure |
|       |    |                                 | is useless.         |
+-------+----+---------------------------------+---------------------+
| 6     | ZA | > Our request to change the     | P- For self- and    |
|       |    | > heading and first paragraph   | semi-self           |
|       |    | > of chapter 6 which was made   | indicating          |
|       |    | > in our comment on the working | instruments chapter |
|       |    | > draft was not accepted as the | 4 applies and       |
|       |    | > secretariat is not aware of   | instruments undergo |
|       |    | > misunderstandings in the past | type-approval       |
|       |    | > but this is what we are       | testing. Therefore  |
|       |    | > bringing to your attention.   | for knife edges,    |
|       |    | > From the further reasons      | bearings and        |
|       |    | > given we must deduct from     | friction plates of  |
|       |    | > your explanation that self-   | such instruments    |
|       |    | > and semi-self indicating      | the requirements of |
|       |    | > instruments are not included  | chapter 6 need not  |
|       |    | > in clause 6 and therefore an  | be applied Testing  |
|       |    | > instrument with a lever       | proves the          |
|       |    | > system, single load cell and  | suitability.        |
|       |    | > digital indication may have   |                     |
|       |    | > knife edges, bearings and     |                     |
|       |    | > friction plates of any        |                     |
|       |    | > hardness as there is no       |                     |
|       |    | > requirements for these. This  |                     |
|       |    | > cannot be the case because    |                     |
|       |    | > clause 4.2.5 refers to        |                     |
|       |    | > chapter 6 for compliance of   |                     |
|       |    | > poises and there are many     |                     |
|       |    | > other instances where chapter |                     |
|       |    | > 6 applies to self- and        |                     |
|       |    | > semi-self indicating          |                     |
|       |    | > instruments. This anomaly     |                     |
|       |    | > should then be resolved.      |                     |
+-------+----+---------------------------------+---------------------+
| 6.1   | NL | > The last sentence is [no      | P- Please refer to  |
|       |    | > requirement but a             | our response under  |
|       |    | > test]{.underline} **(type     | "General" NL        |
|       |    | > test or verification ?**).    |                     |
|       |    | >                               |                     |
|       |    | > So this should be moved to    |                     |
|       |    | > clause 8.                     |                     |
+-------+----+---------------------------------+---------------------+
| 6.3   | CH | > Some remaining constructional | P- 6.3 contains     |
|       |    | > design requirements should be | requirements for    |
|       |    | > removed (like for example in  | certain simple      |
|       |    | > 6.3).                         | instruments for     |
|       |    |                                 | submitting direct   |
|       |    |                                 | to initial          |
|       |    |                                 | verification        |
|       |    |                                 | (without type       |
|       |    |                                 | approval), and this |
|       |    |                                 | provisions shall    |
|       |    |                                 | not be removed.     |
+-------+----+---------------------------------+---------------------+
| 7     | ZA | 3.9.3 refers to "between the    | P+ See also 3.9.3   |
|       |    | lower and upper limit of the    | ZA                  |
|       |    | nominal voltage **marked** on   |                     |
|       |    | the instrument (U)....."        |                     |
|       |    |                                 |                     |
|       |    | In clause 7 there is not a      |                     |
|       |    | requirement for the nominal     |                     |
|       |    | voltage to be marked.           |                     |
|       |    |                                 |                     |
|       |    | Does this mean you don't have   |                     |
|       |    | to do the test if it is not     |                     |
|       |    | marked?                         |                     |
|       |    |                                 |                     |
|       |    | Suggestion: a) ....and upper    |                     |
|       |    | limit of the nominal voltage    |                     |
|       |    | ~~marked on~~ of the instrument |                     |
|       |    | (U)....                         |                     |
|       |    |                                 |                     |
|       |    | or                              |                     |
|       |    |                                 |                     |
|       |    | b\) In clause 7 make it         |                     |
|       |    | compulsory if applicable for    |                     |
|       |    | the nominal voltage (U) to be   |                     |
|       |    | marked on the instrument.       |                     |
+-------+----+---------------------------------+---------------------+
| 7.1.1 | CA | > Additional marking is         | P- No such markings |
|       |    | > necessary: n~max~ is required | have ever been      |
|       |    | > to be marked for indicators,  | required as         |
|       |    | > and power supply voltage is   | metrological        |
|       |    | > required to be marked for     | markings both for   |
|       |    | > indicators and complete       | complete            |
|       |    | > instruments.                  | instruments and     |
|       |    | >                               | indicators.         |
|       |    | > Canada defines Max in terms   |                     |
|       |    | > of mass (kg) while n~max~ is  | P- See 7.1.5.3      |
|       |    | > in terms of divisions (d).    |                     |
|       |    | > For instruments/modules,      |                     |
|       |    | > especially indicators, tested |                     |
|       |    | > separately, n~max~ should be  |                     |
|       |    | > required information.         |                     |
+-------+----+---------------------------------+---------------------+
| 7.1.2 | US | H): Typographical error in the  | P+                  |
|       |    | first bullet:                   |                     |
|       |    |                                 |                     |
|       |    | \- maximum safe load in the     |                     |
|       |    | form of Lim = . . .             |                     |
|       |    |                                 |                     |
|       |    | > (if the manufacturer ~~b~~has |                     |
|       |    | > provided for a maximum safe   |                     |
|       |    | > load of more than Max + T)    |                     |
+-------+----+---------------------------------+---------------------+
| 7.1.4 | AU | > 7.1.4 Presentation of         | P+ This is almost   |
|       |    | > descriptive markings          | in line with the    |
|       |    |                                 | new wording         |
|       |    | \(i\) We do not agree that only | proposed in the     |
|       |    | showing the Class, Max, Min, e  | 2CD: \"The          |
|       |    | values on a manual command is   | markings: Max, Min, |
|       |    | sufficient. These paramaters    | e =, and d (if d    |
|       |    | can influence the acceptability | unequal e) shall be |
|       |    | of an instrument for various    | shown at least in   |
|       |    | uses (according to national     | one place and       |
|       |    | regulations) and hence we       | [perma              |
|       |    | believe they should be visible  | nently]{.underline} |
|       |    | to the user and the customer.   | either on the       |
|       |    |                                 | display or near to  |
|       |    | > \(ii\) We are concerned that  | the display in a    |
|       |    | > if display of various items   | clearly visible     |
|       |    | > (markings and calibration     | position\...\" Only |
|       |    | > codes) is provided on manual  | the class will fall |
|       |    | > command, this is not          | under the other     |
|       |    | > sufficiently well defined. We | provision, see our  |
|       |    | > have seen a trend for access  | response to (ii).   |
|       |    | > to information (e.g.          |                     |
|       |    | > calibration code - but it is  | P+ Has been         |
|       |    | > a trend which could extend to | (almost) considered |
|       |    | > marking information) to be    | by the new wording: |
|       |    | > only accessible through a     | \"All additional    |
|       |    | > complex system of menus - the | information as      |
|       |    | > term \'manual command\' could | mentioned in B and  |
|       |    | > encompass this. This is       | G may be shown      |
|       |    | > unacceptable as neither an    | alternatively on a  |
|       |    | > unskilled operator, nor a     | plate or            |
|       |    | > weights and measures official | simultaneously      |
|       |    | > can be expected to negotiate  | displayed by a      |
|       |    | > their way through such        | software solution   |
|       |    | > complicated and differing     | either permanently  |
|       |    | > arrangements. We would        | [or accessed by a   |
|       |    | > suggest that for information  | simple manual       |
|       |    | > which may be acceptable to be | comm                |
|       |    | > accessed by a manual command  | and]{.underline}.\" |
|       |    | > (e.g. items other than in     |                     |
|       |    | > marking categories A & B, and | P- Concerning \"a   |
|       |    | > also including a calibration  | [                   |
|       |    | > code), the wording should be  | single]{.underline} |
|       |    | > \"accessed by a single simple | simple manual       |
|       |    | > manual command\".             | command\": This     |
|       |    |                                 | could lead to       |
|       |    |                                 | practical problems  |
|       |    |                                 | if you think e.g.   |
|       |    |                                 | of a menue function |
|       |    |                                 | button that will    |
|       |    |                                 | open an \"info      |
|       |    |                                 | menu\" offering the |
|       |    |                                 | additional          |
|       |    |                                 | information in      |
|       |    |                                 | question, which     |
|       |    |                                 | should be           |
|       |    |                                 | acceptable.         |
+-------+----+---------------------------------+---------------------+
| 7.1.4 | JP | > As the means of sealing or    | P+ See 2 CD         |
|       |    | > security, lead is             |                     |
|       |    | > recommended. However, as lead |                     |
|       |    | > is a hazardous substance,     |                     |
|       |    | > another way to express the    |                     |
|       |    | > recommendation should be      |                     |
|       |    | > considered, for example       |                     |
|       |    | > "...cap of suitable metal     |                     |
|       |    | > inserted ..." in the second   |                     |
|       |    | > sentence of item c in 7.1.4.  |                     |
+-------+----+---------------------------------+---------------------+
| 7.1.4 | UK | > This now appears to allow as  | No. See new wording |
|       |    | > an alternative Max, Min, e    | in 2CD which        |
|       |    | > (and d if appropriate) to be  | hopefully clarifies |
|       |    | > displayed on demand, and not  | your point.         |
|       |    | > permanently shown anywhere.   |                     |
|       |    | > Is this intended?             | Our intention was   |
|       |    | >                               | to say:             |
|       |    | > In addition, can the word     |                     |
|       |    | > "near", in relation to "near  | Max, Min, e= and d= |
|       |    | > or on the display" be         | (if de) have to be  |
|       |    | > clarified?                    | shown at least in   |
|       |    | >                               | one position and    |
|       |    | > c): The first sentence of     | permanently either  |
|       |    | > this section requires the use | on the display or   |
|       |    | > of at least one rivet made of | near to the display |
|       |    | > red copper. Why? Plates which | in a clearly        |
|       |    | > cannot be removed without     | visible position.   |
|       |    | > being destroyed have been     | Automatically       |
|       |    | > acceptable in the past, why   | scrolling (but not  |
|       |    | > should a requirement be       | on manual command)  |
|       |    | > introduced now that says such | is considered as    |
|       |    | > plates shall be riveted,      | "permanently".      |
|       |    | > screwed or otherwise secured  |                     |
|       |    | > using non-removable control   | P- 1. This is an    |
|       |    | > marks. Even where plates have | acceptable solution |
|       |    | > been riveted in the past      | rather than a       |
|       |    | > there has been no requirement | requirement. 2. The |
|       |    | > to use at least one red       | wording of this     |
|       |    | > copper rivet. This appears to | "old acceptable     |
|       |    | > be overkill. Delete the words | solution" has       |
|       |    | > "with one of the rivets being | already been        |
|       |    | > of red copper or material     | improved by         |
|       |    | > having qualities recognised   | introducing         |
|       |    | > as similar" and replace with  | "non-removable      |
|       |    | > "or by other means such as    | control marks"      |
|       |    | > being made of destructible    | instead of "red     |
|       |    | > material"                     | copper".            |
+-------+----+---------------------------------+---------------------+
| 7.1.4 | US | The U.S. recommends that;       | P- We do not think  |
|       |    |                                 | that we get         |
|       |    | 1.  \- the presentation of      | worldwide           |
|       |    |     7.1.3 Additional markings,  | acceptance of your  |
|       |    |                                 | proposal. However,  |
|       |    |     \- the identification mark  | we hope that the    |
|       |    |     on separate but associated  | new wording (see    |
|       |    |     units, and                  | 7.1.4 UK above) is  |
|       |    |                                 | an acceptable       |
|       |    |     \- the presentation of      | compromise for you. |
|       |    |     special limits              |                     |
|       |    |                                 | P- We think it is   |
|       |    | should be listed as acceptable  | useful to have the  |
|       |    | software solutions to physical  | information as far  |
|       |    | markings.                       | as possible grouped |
|       |    |                                 | together. We do not |
|       |    | > The U.S. is unaware of any    | see any practical   |
|       |    | > technical justification why   | problem to realise  |
|       |    | > the markings in 7.1.2. E      | that.               |
|       |    | > (identification mark if       |                     |
|       |    | > separate but associated       |                     |
|       |    | > units), F (approval mark),    |                     |
|       |    | > and H (special limits) may    |                     |
|       |    | > not be displayed in lieu of   |                     |
|       |    | > physical markings. Except for |                     |
|       |    | > the additional markings in    |                     |
|       |    | > 7.1.3, customers in direct    |                     |
|       |    | > sale transactions have no     |                     |
|       |    | > need to view the markings in  |                     |
|       |    | > E, F, and H. Additionally,    |                     |
|       |    | > the U.S. believes that the    |                     |
|       |    | > should not be required to be  |                     |
|       |    | > "simultaneously displayed."   |                     |
|       |    | > The language should permit    |                     |
|       |    | > the presentations of markings |                     |
|       |    | > to be scrolled or menu        |                     |
|       |    | > driven.                       |                     |
|       |    | >                               |                     |
|       |    | > As an alternative all         |                     |
|       |    | > applicable markings in B[, E, |                     |
|       |    | > F, G, and H]{.underline} may  |                     |
|       |    | > be ~~simultaneously~~         |                     |
|       |    | > displayed by a software       |                     |
|       |    | > solution either permanently   |                     |
|       |    | > or on manual command. In this |                     |
|       |    | > case the markings are         |                     |
|       |    | > considered as device-specific |                     |
|       |    | > parameters (see T.2.8.4,      |                     |
|       |    | > 4.1.2.4 and 5.5). [Additional |                     |
|       |    | > markings in 7.1.3 may be      |                     |
|       |    | > simultaneously displayed by a |                     |
|       |    | > software solution as an       |                     |
|       |    | > alternative to physical       |                     |
|       |    | > markings.]{.underline}        |                     |
|       |    | >                               |                     |
|       |    | > An alternate proposal would   |                     |
|       |    | > be to recognize that the      |                     |
|       |    | > markings in E, F, H, and also |                     |
|       |    | > D (serial number) could be    |                     |
|       |    | > provided by a software        |                     |
|       |    | > solution in the event that    |                     |
|       |    | > the markings are not located  |                     |
|       |    | > in a clearly visible location |                     |
|       |    | > (e.g. under an easily         |                     |
|       |    | > removable load receptor,      |                     |
|       |    | > bottom of the instrument,     |                     |
|       |    | > etc.).                        |                     |
|       |    |                                 |                     |
|       |    | Peripheral devices should not   |                     |
|       |    | be held to the same marking     |                     |
|       |    | visibility and grouping         |                     |
|       |    | requirements in 7.1.4 as        |                     |
|       |    | weighing instruments, main      |                     |
|       |    | devices, modules, and other     |                     |
|       |    | legally relevant devices.       |                     |
|       |    |                                 |                     |
|       |    | > The examples of peripheral    |                     |
|       |    | > devices in T.2.3.5 are not    |                     |
|       |    | > manufactured with the intent  |                     |
|       |    | > that they be used exclusively |                     |
|       |    | > or predominantly as a part of |                     |
|       |    | > a measuring instrument or     |                     |
|       |    | > module. Their markings are    |                     |
|       |    | > not always located together   |                     |
|       |    | > or as clearly visible as they |                     |
|       |    | > are for weighing instruments. |                     |
|       |    | > For example, video displays,  |                     |
|       |    | > PC computers, and printers    |                     |
|       |    | > may have the name of the      |                     |
|       |    | > manufacturer on the front of  |                     |
|       |    | > the device with the type      |                     |
|       |    | > designation, serial number,   |                     |
|       |    | > and other information         |                     |
|       |    | > including (i.e., CE, FCC, UL, |                     |
|       |    | > etc.) located on the back or  |                     |
|       |    | > bottom of the device.         |                     |
|       |    | >                               |                     |
|       |    | > The U.S. recommends that the  |                     |
|       |    | > language in 7.1.4 be amended  |                     |
|       |    | > as follows to clarify that    |                     |
|       |    | > peripheral devices do not     |                     |
|       |    | > have the same visibility and  |                     |
|       |    | > grouping marking requirements |                     |
|       |    | > as weighing instruments as    |                     |
|       |    | > follows:                      |                     |
|       |    | >                               |                     |
|       |    | > The descriptive markings      |                     |
|       |    | > shall be indelible and of a   |                     |
|       |    | > size, shape and clarity       |                     |
|       |    | > allowing easy reading.        |                     |
|       |    | >                               |                     |
|       |    | > [Except for the markings      |                     |
|       |    | > required for peripheral       |                     |
|       |    | > devices in 7.1.5.4, the       |                     |
|       |    | > descriptive                   |                     |
|       |    | > markings]{.underline}         |                     |
|       |    | > ~~They~~ shall be grouped in  |                     |
|       |    | > one or two clearly visible    |                     |
|       |    | > places either on a plate or   |                     |
|       |    | > sticker fixed permanently to  |                     |
|       |    | > the instrument, or on a       |                     |
|       |    | > non-removable part of the     |                     |
|       |    | > instrument itself. In case of |                     |
|       |    | > a plate or sticker which is   |                     |
|       |    | > not destroyed when removed, a |                     |
|       |    | > means of securing shall be    |                     |
|       |    | > provided, e.g. a control mark |                     |
|       |    | > that can be applied.          |                     |
+-------+----+---------------------------------+---------------------+
| 7.    | UK | > The word "viz" is slightly    | P+                  |
| 1.5.1 |    | > obscure. It would be better   |                     |
|       |    | > to replace it by some other   |                     |
|       |    | > word or phrase.               |                     |
+-------+----+---------------------------------+---------------------+
| 7.2   | JP | > As the means of sealing or    | P+ See 2 CD         |
|       |    | > security, lead is             |                     |
|       |    | > recommended. However, as lead |                     |
|       |    | > is a hazardous substance,     |                     |
|       |    | > another way to express the    |                     |
|       |    | > recommendation should be      |                     |
|       |    | > considered, for example       |                     |
|       |    | > "...cap of suitable metal     |                     |
|       |    | > inserted ..." in the second   |                     |
|       |    | > sentence of item c in 7.1.4.  |                     |
+-------+----+---------------------------------+---------------------+
| 7.2   | SI | > (acceptable solution) The     | P- R76 contains     |
|       |    | > sentence "These marks should  | requirements to be  |
|       |    | > be adequately durable for the | observed not only   |
|       |    | > intended use of the           | by manufacturers    |
|       |    | > instrument, e.g. by means of  | but also by         |
|       |    | > a suitable protection" shall  | authorities like    |
|       |    | > be deleted. This is not the   | type-approval       |
|       |    | > attribute of the instrument   | bodies and          |
|       |    | > and the producer of the       | verification        |
|       |    | > instrument doesn't have an    | authorities.        |
|       |    | > influence to the quality of   |                     |
|       |    | > the marks.                    |                     |
+-------+----+---------------------------------+---------------------+
| 8.1   | CA | > The third paragraph is        | P- As there was no  |
|       |    | > misleading and wording should | such request from   |
|       |    | > be changed as follows:        | any other TC9/SC1   |
|       |    | > "However, instruments         | member nor a vote   |
|       |    | > according to 6.4 through 6.9  | to change this      |
|       |    | > of this Recommendation shall  | para, it seems very |
|       |    | > not be subject to type        | unlikely that the   |
|       |    | > approval **according to this  | proposed change     |
|       |    | > Recommendation**, national    | will find the       |
|       |    | > legislation may provide for   | support of a        |
|       |    | > **type and** initial          | majority of TC9/SC1 |
|       |    | > verification for particular   | members.            |
|       |    | > instrument applications."     |                     |
|       |    | >                               |                     |
|       |    | > Canada worries that the first |                     |
|       |    | > half of this paragraph may be |                     |
|       |    | > interpreted to mean that all  |                     |
|       |    | > devices identified in         |                     |
|       |    | > sections 6.4-6.9 are          |                     |
|       |    | > automatically exempt from     |                     |
|       |    | > type approval. The second     |                     |
|       |    | > half which allows for         |                     |
|       |    | > national deviations is fine   |                     |
|       |    | > by us.                        |                     |
+-------+----+---------------------------------+---------------------+
| 8.1   | JP | > The term, "in-service", is    | P+                  |
|       |    | > used here and other places.   |                     |
|       |    | > This term was already         |                     |
|       |    | > proposed to be "service" by   |                     |
|       |    | > some countries in previous    |                     |
|       |    | > case. This word is to be      |                     |
|       |    | > revised to "service".         |                     |
+-------+----+---------------------------------+---------------------+
| 8.2.1 | UK | > "moduls" should be "modules". | P+                  |
+-------+----+---------------------------------+---------------------+
| 8.    | AU | > 8.2.1.2 Descriptive documents | P+ See 2 CD where   |
| 2.1.2 |    |                                 | we have changed the |
|       |    | Comment: We do not believe that | wording under No    |
|       |    | an OIML document should         | 8.2.1.2 / point 4.2 |
|       |    | specifically refer to CE        | into:               |
|       |    | marking as this is specific to  |                     |
|       |    | a limited range of member       | "...securing        |
|       |    | nations -- the term conformity  | elements;           |
|       |    | marks would seem sufficient --  | descriptive         |
|       |    | perhaps **conformity and/or     | markings,           |
|       |    | approval marks** would be       | identification,     |
|       |    | better.                         | confornity and / or |
|       |    |                                 | approval marks      |
|       |    | In addition whilst we recognise | (7.1, 7.2)"         |
|       |    | the need for confidentiality,   |                     |
|       |    | the final statement goes way    | P+ We propose,      |
|       |    | too far (it effectively         | however, just to    |
|       |    | suggests that the general       | add to the last     |
|       |    | characteristics at item 2 must  | sentence of para    |
|       |    | be kept confidential for        | 8.2.1.2 the         |
|       |    | example). The approving         | following:          |
|       |    | authority may legally (perhaps  |                     |
|       |    | not in Europe, but certainly    | "..., except to the |
|       |    | elsewhere) need to be in a      | extent agreed with  |
|       |    | position to write and publish   | the manufacturer."  |
|       |    | descriptions of the instrument  |                     |
|       |    | operation (including perhaps    | P- The chapter      |
|       |    | extracts of the material        | contains already a  |
|       |    | provided) so that               | very long list for  |
|       |    | verification/certification      | necessary           |
|       |    | personnel can identify the      | documents.          |
|       |    | approved instrument (and detect |                     |
|       |    | unapproved equipment). In       |                     |
|       |    | addition in a situation in      |                     |
|       |    | which non-conformity has been   |                     |
|       |    | detected an authority may need  |                     |
|       |    | to present any or all of the    |                     |
|       |    | material to legal authorities   |                     |
|       |    | to initiate prosecution.        |                     |
|       |    | Perhaps the sentence needs to   |                     |
|       |    | say **...shall normally be kept |                     |
|       |    | confidential by the approving   |                     |
|       |    | authority, except to the extent |                     |
|       |    | that elements of the material   |                     |
|       |    | may need to be included in      |                     |
|       |    | approval documentation (with    |                     |
|       |    | the agreement of the            |                     |
|       |    | manufacturer/supplier). In      |                     |
|       |    | addition material may need to   |                     |
|       |    | be disclosed in the case of     |                     |
|       |    | legal action (for example       |                     |
|       |    | should non-conformity found).** |                     |
|       |    |                                 |                     |
|       |    | Also the list of descriptive    |                     |
|       |    | documents does not actually say |                     |
|       |    | what is to be supplied, perhaps |                     |
|       |    | the following needs to be       |                     |
|       |    | included prior to the list.     |                     |
|       |    | **Descriptive documents which   |                     |
|       |    | detail and explain aspects of   |                     |
|       |    | the instrument operation and    |                     |
|       |    | design, including how various   |                     |
|       |    | elements of this Recommendation |                     |
|       |    | are met shall be provided in    |                     |
|       |    | addition to operational and     |                     |
|       |    | technical manuals for the       |                     |
|       |    | instrument. In the case of a    |                     |
|       |    | family of instruments the       |                     |
|       |    | descriptive documents shall     |                     |
|       |    | address differences and         |                     |
|       |    | similarities between members of |                     |
|       |    | the family. The following is a  |                     |
|       |    | list of various aspects which   |                     |
|       |    | should be addressed.**          |                     |
+-------+----+---------------------------------+---------------------+
| 8.    | RO | > We think that the documents   | P- See response to  |
| 2.1.2 |    | > needed to check the           | comment AU above    |
|       |    | > conformity of the instrument  |                     |
|       |    | > (where there are doubts or as |                     |
|       |    | > provided at point 8.3 of the  |                     |
|       |    | > recommendation) should be     |                     |
|       |    | > made available in the annex   |                     |
|       |    | > to the OIML certificate. We   |                     |
|       |    | > understand the need of        |                     |
|       |    | > maximum confidentiality       |                     |
|       |    | > pending the placing on the    |                     |
|       |    | > market of a new type of       |                     |
|       |    | > instrument, but afterwards it |                     |
|       |    | > is necessary to provide       |                     |
|       |    | > protection against            |                     |
|       |    | > non-compliant or fake         |                     |
|       |    | > instruments. We suggest to    |                     |
|       |    | > re-phrase as follows: "*All   |                     |
|       |    | > documents of the weighing     |                     |
|       |    | > instrument (*which are not    |                     |
|       |    | > published by the producer)    |                     |
|       |    | > *shall be kept confidential   |                     |
|       |    | > by the approving authority,   |                     |
|       |    | > with the following            |                     |
|       |    | > exception:* *the documents    |                     |
|       |    | > needed to check conformity of |                     |
|       |    | > the instrument to the         |                     |
|       |    | > approved type shall be        |                     |
|       |    | > published in the annex of the |                     |
|       |    | > OIML certificate*".           |                     |
+-------+----+---------------------------------+---------------------+
| 8.    | SI | > Item 10: It is necessary to   | P+                  |
| 2.1.2 |    | > include the reference to      |                     |
|       |    | > 5.5.2.1 (Table 11).           |                     |
+-------+----+---------------------------------+---------------------+
| 8.    | UK | > Number 10: It would be better | P+                  |
| 2.1.2 |    | > to replace "acc." by the full |                     |
|       |    | > word. Also Section D.2.2 and  |                     |
|       |    | > D.3.                          |                     |
+-------+----+---------------------------------+---------------------+
| 8.2.2 | AU | > 8.2.2 Type evaluation         | P+ We cancelled the |
|       |    | >                               | word "spot" in 2 CD |
|       |    | > Replace the first two         | to follow the sense |
|       |    | > paragraphs with:              | of your proposal.   |
|       |    | >                               |                     |
|       |    | > **The submitted documents     |                     |
|       |    | > shall be examined to verify   |                     |
|       |    | > that the descriptions         |                     |
|       |    | > indicate compliance with the  |                     |
|       |    | > requirements of this          |                     |
|       |    | > Recommendation.**             |                     |
|       |    | >                               |                     |
|       |    | > **In addition checks shall be |                     |
|       |    | > performed to establish that   |                     |
|       |    | > the instrument(s) supplied    |                     |
|       |    | > comply with the requirements  |                     |
|       |    | > of this Recommendation, and   |                     |
|       |    | > also in accordance with the   |                     |
|       |    | > documents submitted. The      |                     |
|       |    | > checklist in R76-2 shall be   |                     |
|       |    | > used to record the results of |                     |
|       |    | > these checks. Reactions to    |                     |
|       |    | > significant faults need not   |                     |
|       |    | > be triggered.**               |                     |
|       |    |                                 |                     |
|       |    | Explanation: The term 'spot     |                     |
|       |    | checks' permits and indeed      |                     |
|       |    | encourages a less than thorough |                     |
|       |    | pattern evaluation. The         |                     |
|       |    | situation is developing where   |                     |
|       |    | on the basis of a single        |                     |
|       |    | evaluation of an instrument     |                     |
|       |    | (just one in a family) an       |                     |
|       |    | unlimited number of instruments |                     |
|       |    | may be distributed worldwide.   |                     |
|       |    | If that single evaluation is    |                     |
|       |    | not even to be carried out in a |                     |
|       |    | thorough manner then quite      |                     |
|       |    | simply the majority of the      |                     |
|       |    | requirements in this document   |                     |
|       |    | may as well simply be           |                     |
|       |    | eliminated. It is more          |                     |
|       |    | important that the instrument   |                     |
|       |    | does actually comply with the   |                     |
|       |    | Recommendation rather than just |                     |
|       |    | the documents (note that it is  |                     |
|       |    | stated elsewhere that the       |                     |
|       |    | documentation may be in a draft |                     |
|       |    | form), we believe this clause   |                     |
|       |    | should reflect that We have     |                     |
|       |    | encountered a number of cases   |                     |
|       |    | where authorities have          |                     |
|       |    | apparently granted approval on  |                     |
|       |    | the basis of documentation,     |                     |
|       |    | where the actual instrument did |                     |
|       |    | not comply.                     |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | AU | Comment: Matters of initial and | P+                  |
|       |    | subsequent verification are     |                     |
|       |    | highly dependent on local legal |                     |
|       |    | systems, rules and procedures.  |                     |
|       |    | In Australia certification      |                     |
|       |    | (similar to initial             |                     |
|       |    | verification) may be performed  |                     |
|       |    | by other than 'authorised       |                     |
|       |    | national bodies' or 'the        |                     |
|       |    | manufacturer' -- personnel of   |                     |
|       |    | licensed companies can carry    |                     |
|       |    | out this function. Such matters |                     |
|       |    | should be left to national      |                     |
|       |    | regulations. Hence we believe   |                     |
|       |    | the first paragraph should be   |                     |
|       |    | changed to **Initial            |                     |
|       |    | verification may be performed   |                     |
|       |    | by authorised personnel         |                     |
|       |    | according to national           |                     |
|       |    | regulations.** It should also   |                     |
|       |    | be recognised that in many      |                     |
|       |    | cases the manufacture may not   |                     |
|       |    | exist in the particular         |                     |
|       |    | jurisdiction in which the       |                     |
|       |    | instrument is to be installed.  |                     |
|       |    | Much of the material in this    |                     |
|       |    | section appears to be an        |                     |
|       |    | attempt to write European       |                     |
|       |    | procedures into the OIML        |                     |
|       |    | documents -- we do not support  |                     |
|       |    | this.                           |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | CA | Suggest remove everything after | P+ see 2 CD         |
|       |    | *authorized national bodies.*   |                     |
|       |    | This would include the          | P+ We propose the   |
|       |    | manufacturer if they are an     | following change:   |
|       |    | authorized national body.       | "...instrument      |
|       |    |                                 | meets the           |
|       |    | > Editorial Change, last        | respective national |
|       |    | > paragraph -- "...provided     | or regional         |
|       |    | > that the instrument meets all | requirements."      |
|       |    | > of the requirements within    |                     |
|       |    | > this zone."                   |                     |
|       |    | >                               |                     |
|       |    | > If a manufacturer's "quality  |                     |
|       |    | > system for production is      |                     |
|       |    | > acknowledged for this task",  |                     |
|       |    | > would that not make them      |                     |
|       |    | > 'authorized"?                 |                     |
|       |    | >                               |                     |
|       |    | > Canada agrees with the        |                     |
|       |    | > Secretariat's response.       |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | JP | > When national regulations are | P- We agree, but    |
|       |    | > identical, the products       | this proposal would |
|       |    | > approved at initial           | go beyond the scope |
|       |    | > verification should be        | of R76, and there   |
|       |    | > mutually accepted.            | was no such vote.   |
|       |    |                                 | Of course, any      |
|       |    |                                 | country is free to  |
|       |    |                                 | accept your         |
|       |    |                                 | proposal under its  |
|       |    |                                 | national            |
|       |    |                                 | regulations.        |
+-------+----+---------------------------------+---------------------+
| 8.3   | NL | > 5^th^ par:                    | P- Obviously, this  |
|       |    |                                 | is already possible |
|       |    | Add after "*The second stage    | now. It only        |
|       |    | shall be carried out at the     | requires a clear    |
|       |    | place of use of the             | description in the  |
|       |    | instrument.*":                  | respective          |
|       |    |                                 | Certificate.        |
|       |    | > *"If the instrument has a     |                     |
|       |    | > gravity compensation device   |                     |
|       |    | > all tests can be carried out  |                     |
|       |    | > in the first stage and in the |                     |
|       |    | > second stage the gravity      |                     |
|       |    | > compensation can be set*."    |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | PL | > the last paragraph:           | P+ We suggest,      |
|       |    | >                               | however, a slightly |
|       |    | > We propose to complete the    | modified wording,   |
|       |    | > sentence: 'Instead of a place | see 2 CD.           |
|       |    | > of use [or gravity value at   |                     |
|       |    | > the place]{.underline} a      |                     |
|       |    | > gravity zone\....'            |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | ZA | Initial verification by         | P+ See response to  |
|       |    | accredited facilities such as   | AU and 2 CD         |
|       |    | verification laboratories is    |                     |
|       |    | permitted in certain member     |                     |
|       |    | countries of the OIML and it is |                     |
|       |    | proposed that the first         |                     |
|       |    | paragraph be amended as         |                     |
|       |    | follows;                        |                     |
|       |    |                                 |                     |
|       |    | > Initial verification may be   |                     |
|       |    | > performed by authorised       |                     |
|       |    | > national bodies, by the       |                     |
|       |    | > manufacturer itself, [or by   |                     |
|       |    | > accredited organisations      |                     |
|       |    | > authorised or registered by   |                     |
|       |    | > authorised national           |                     |
|       |    | > bodies]{.mark} provided that- |                     |
|       |    | > according to national rules   |                     |
|       |    | > -- their management /quality  |                     |
|       |    | > systems for production or     |                     |
|       |    | > verification are acknowledged |                     |
|       |    | > for this task.                |                     |
+-------+----+---------------------------------+---------------------+
| 8.3   | UK | The first sentence has no place | P+ See response to  |
|       |    | in this Recommendation. Who     | AU and 2 CD         |
|       |    | carries out initial             |                     |
|       |    | verification is a matter for    | P+                  |
|       |    | national legislation not this   |                     |
|       |    | Recommendation. Authorised      |                     |
|       |    | national bodies and             |                     |
|       |    | manufacturers with              |                     |
|       |    | "acknowledged" (inappropriate   |                     |
|       |    | term?) quality systems are      |                     |
|       |    | merely examples of who may be   |                     |
|       |    | permitted under national        |                     |
|       |    | legislation, there are many     |                     |
|       |    | other possibilities including   |                     |
|       |    | for example independent third   |                     |
|       |    | parties who may be economic     |                     |
|       |    | operators. Delete this          |                     |
|       |    | sentence.                       |                     |
|       |    |                                 |                     |
|       |    | The first sentence of second    |                     |
|       |    | paragraph of this section is    |                     |
|       |    | also too restrictive. Who       |                     |
|       |    | establishes conformity to the   |                     |
|       |    | approved type and what criteria |                     |
|       |    | are used to evaluate their      |                     |
|       |    | suitability to make such a      |                     |
|       |    | judgement is a matter for       |                     |
|       |    | national legislation. As worded |                     |
|       |    | the sentence restricts initial  |                     |
|       |    | verification to bodies/ people  |                     |
|       |    | that are the responsibility of  |                     |
|       |    | another authorised body. Delete |                     |
|       |    | the words "under the            |                     |
|       |    | responsibility of an authorised |                     |
|       |    | body" from the first sentence   |                     |
|       |    | of the second paragraph.        |                     |
|       |    |                                 |                     |
|       |    | If the above is not accepted:   |                     |
|       |    |                                 |                     |
|       |    | In the first paragraph, replace |                     |
|       |    | "acknowledged" with "accredited |                     |
|       |    | \[or certified\]". Also, after  |                     |
|       |    | the word "production" add the   |                     |
|       |    | words "and verification". Also  |                     |
|       |    | in the last paragraph, replace  |                     |
|       |    | "data" with "parameters".       |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.1 | AU | *Comment: We do not understand  | P+ See 2 CD         |
|       |    | the meaning of 'The body in     |                     |
|       |    | charge of the tests ...'        |                     |
|       |    | perhaps this again reflects     |                     |
|       |    | some procedures in the European |                     |
|       |    | system with which we are not    |                     |
|       |    | familiar.*                      |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.2 | UK | As there is a comma at the end  | P+                  |
|       |    | of the first bullet point,      |                     |
|       |    | there should be commas at the   |                     |
|       |    | ends of the second and third    |                     |
|       |    | bullet points too.              |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.3 | CA | We do not understand the        | The test loads must |
|       |    | limitation to test loads ≥ 100  | be chosen acc. to   |
|       |    | mg, and why the discrimination  | A.4.4.1, but it is  |
|       |    | test is not to be performed on  | not important and   |
|       |    | instruments with digital        | not useful to       |
|       |    | indications.                    | include Min if Min  |
|       |    |                                 | \< 100 mg.          |
|       |    | > The fourth paragraph mentions |                     |
|       |    | > that the error limits shall   | The discrimination  |
|       |    | > be the maximum permissible    | test is not         |
|       |    | > errors (mpe) upon initial     | necessary, because  |
|       |    | > verification; however, Canada | the discrimination  |
|       |    | > suggests that the error limit | threshold at        |
|       |    | > for the repeatability test    | verification should |
|       |    | > should be the **absolute      | be the same as at   |
|       |    | > value** of this mpe.          | type approval.      |
|       |    | >                               |                     |
|       |    | > Canada agrees with the        | P+ because of 3.6.1 |
|       |    | > Secratariat's response.       |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.3 | FR | Third hyphen , read : "3.6.1 :  | P+ Change to        |
|       |    | repeatability (refer to A.4.10, | "(A.4.10, 3^rd^     |
|       |    | 2^nd^ paragraph).               | paragraph)"         |
|       |    |                                 |                     |
|       |    | > In initial verification of a  | P+ See NL below     |
|       |    | > mobile instrument, a test of  |                     |
|       |    | > tilting should be included    |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.3 | NL | Add one more item:              | P+ See change in    |
|       |    |                                 | 8.3.3.              |
|       |    | > *- 4.19 **tilt** in case of   |                     |
|       |    | > mobile instruments.*          | P- In special cases |
|       |    | >                               | the OIML            |
|       |    | > OIML certificates do not      | certificates may    |
|       |    | > include descriptions of       | and even should     |
|       |    | > tests. So delete this         | include             |
|       |    | > sentence.                     | descriptions of     |
|       |    |                                 | tests, e.g. the     |
|       |    |                                 | tilting test for    |
|       |    |                                 | mobile instruments. |
+-------+----+---------------------------------+---------------------+
| 8.3.3 | UK | > In the sentence "The          | P+                  |
|       |    | > authority responsible\..."    |                     |
|       |    | > delete the word "from".       |                     |
+-------+----+---------------------------------+---------------------+
| 8.3.4 | CA | **Stamping**                    | P+ However , we     |
|       |    |                                 | suggest the shorter |
|       |    | Suggest that the title of this  | title "Marking and  |
|       |    | section should be something     | securing"           |
|       |    | other than 'stamping' to better |                     |
|       |    | reflect the intent of the       | P- We suggest,      |
|       |    | section. '*Initial Verification | however, to add a   |
|       |    | marking and securing'* would be | reference to 7.2    |
|       |    | acceptable.                     | under 8.3.4, see    |
|       |    |                                 | 2CD.                |
|       |    | > Would this entire section not |                     |
|       |    | > be better situated under      |                     |
|       |    | > section 7.2 Verification      |                     |
|       |    | > Marks??                       |                     |
|       |    | >                               |                     |
|       |    | > **Canada agrees with the      |                     |
|       |    | > Secratariat's response.**     |                     |
+-------+----+---------------------------------+---------------------+
| 8.4.1 | ZA | Subsequent verification by      | P+ However, we      |
|       |    | accredited facilities such as   | suggest in analogy  |
|       |    | verification laboratories is    | to 8.3 a shorter    |
|       |    | permitted in certain member     | and more general    |
|       |    | countries of the OIML and it is | wording, see 2CD.   |
|       |    | proposed that clause 8.4.1 the  |                     |
|       |    | first paragraph be amended as   |                     |
|       |    | follows;                        |                     |
|       |    |                                 |                     |
|       |    | Subsequent verification may be  |                     |
|       |    | performed by authorised         |                     |
|       |    | national bodies, or by          |                     |
|       |    | accredited organisations        |                     |
|       |    | authorised or registered by     |                     |
|       |    | authorised national bodies      |                     |
|       |    | provided that- according to     |                     |
|       |    | national rules -- their         |                     |
|       |    | management /quality systems for |                     |
|       |    | production or verification are  |                     |
|       |    | acknowledged for this task.     |                     |
+-------+----+---------------------------------+---------------------+
| A     | UK | > Heading: Has "NONAUTOMATIC",  | P+ It is changed to |
|       |    | > but elsewhere this is         | "non-automatic"     |
|       |    | > hyphenated as                 |                     |
|       |    | > "non-automatic". It should be |                     |
|       |    | > consistent (preferably        |                     |
|       |    | > hyphenated).                  |                     |
+-------+----+---------------------------------+---------------------+
| A.    | SI | > We suggest slight             | P- See A.4.1.1 UK   |
| 4.1.1 |    | > modification of the last      |                     |
|       |    | > sentence in order to clarify  |                     |
|       |    | > its meaning: "For instruments |                     |
|       |    | > of class (I) all necessary    |                     |
|       |    | > corrections of the mass of    |                     |
|       |    | > the test load with respect to |                     |
|       |    | > influence factors shall be    |                     |
|       |    | > applied."                     |                     |
+-------+----+---------------------------------+---------------------+
| A.    | UK | A clarification of the sentence | P+ We add at the    |
| 4.1.1 |    | beginning with "For instruments | end of the          |
|       |    | of Class I\..." is required.    | sentence: "i.e.     |
|       |    |                                 | influence of air    |
|       |    |                                 | buoyancy"           |
+-------+----+---------------------------------+---------------------+
| A.4.2 | CN | > Can the test for initial      | P- We cannot agree  |
| .1.1\ |    | > negative zero-setting range   | with this proposal  |
| A.4.2 |    | > be omitted?                   | because we have     |
| .1.2\ |    | >                               | made the experience |
| A.4.  |    | > Is it suitable that the test  | that there can be a |
| 2.1.3 |    | > for negative zero-setting     | problem with the    |
|       |    | > range should first load more  | software which      |
|       |    | > than 5 percent of Max on      | could only be       |
|       |    | > receptor and initial          | detected by         |
|       |    | > zero-setting then test        | testing.            |
|       |    | > negative zero-setting range   |                     |
|       |    | > in A.4.2.1.2 and A.4.2.1.3.   |                     |
+-------+----+---------------------------------+---------------------+
| A.4.3 | CN | For A.4.3, whether or not add a | P- This is not      |
|       |    | kind of method to determine the | necessary here,     |
|       |    | zero point:                     | because A.4.3 deals |
|       |    |                                 | with the setting to |
|       |    | > c\) For the weighing          | zero before         |
|       |    | > instruments with d0.2e can    | loading, not with   |
|       |    | > directly numerate the error   | the error of zero.  |
|       |    | > of zero.                      |                     |
+-------+----+---------------------------------+---------------------+
| A.    | CA | > In brackets (Min only if Min  | P+ However it must  |
| 4.4.1 |    | > ≥1mg) should read (Min only   | be changed to "Min  |
|       |    | > if **e** ≥ 1mg)?              | only if Min 100 mg" |
|       |    | >                               | because of 8.3.3.   |
|       |    | > Canada agrees with the        | Has been changed    |
|       |    | > Secratariat's response.       | also in A.4.6.1     |
+-------+----+---------------------------------+---------------------+
| A.    | ZA | In case of 8.3 and 8.4 the      | P- The simulation   |
| 4.6.1 |    | practical test may be           | may save time, an   |
|       |    | alternatively replaced by other | additional complete |
|       |    | appropriate procedures, e.g. by | weighing test with  |
|       |    | numerical or graphical          | tare may not be     |
|       |    | considerations. Simulation of a | necessary.          |
|       |    | tare-balancing operation by     | Numerical or        |
|       |    | displacement (shifting) of the  | graphical           |
|       |    | error limits (mpe) to any       | considerations are  |
|       |    | points of the error curve (=    | possible and are    |
|       |    | curve of weighing test          | state of the art    |
|       |    | results). Checking if the error | already. In case of |
|       |    | curve and hysteresis are inside | doubt the full test |
|       |    | the mpe at every point.         | can and shall be    |
|       |    |                                 | carried out.        |
|       |    | 3^rd^ Par: The additional       |                     |
|       |    | sentence adds to clarify the    |                     |
|       |    | first sentence creates further  |                     |
|       |    | confusion as it is not clear    |                     |
|       |    | what the simulation actually    |                     |
|       |    | entails Is the simulation a     |                     |
|       |    | numerical or graphical          |                     |
|       |    | consideration? We are not       |                     |
|       |    | convinced that this is          |                     |
|       |    | practical in the field and can  |                     |
|       |    | guarantee accuracy of weighing. |                     |
+-------+----+---------------------------------+---------------------+
| A.    | UK | > The sentence "The steps shall | P+ See our response |
| 4.6.1 |    | > include values close to Min   | to A.4.4.1 CA.      |
|       |    | > (Min only if Min ≥ 1 mg)\..." |                     |
|       |    | > is ambiguous, as it could     | P- We are convinced |
|       |    | > easily be read to mean that   | that two tests are  |
|       |    | > if Min ≥ 1 mg then            | necessary, one at   |
|       |    | > *only*values close to Min are | 1/3 and one at 3/3. |
|       |    | > taken!                        |                     |
|       |    | >                               |                     |
|       |    | > For additive tare, is the     |                     |
|       |    | > term "3/3" the most suitable? |                     |
|       |    | > Also, in the new text, the    |                     |
|       |    | > wording could be improved.    |                     |
+-------+----+---------------------------------+---------------------+
| A.4.7 | CA | > Eccentricity tests            | P- The test load    |
|       |    | >                               | shall be a known    |
|       |    | > The statement *"It is         | load, because "...  |
|       |    | > sufficient to apply the load  | the indications for |
|       |    | > only to the eccentric         | different positions |
|       |    | > segment, not to the centre of | of a load shall     |
|       |    | > the load receptor"* assumes   | meet the maximum    |
|       |    | > that the load is always a     | permissible errors" |
|       |    | > 'known load'. If the load is  | (3.6.2). This means |
|       |    | > an 'unknown load', it should  | you have to         |
|       |    | > be applied to the centre of   | determine the       |
|       |    | > the platform to establish a   | deviation against   |
|       |    | > refence weight. Failing to do | the nominal weight  |
|       |    | > so may result in uncertainty  | value on all        |
|       |    | > in establishing the           | positions and not   |
|       |    | > applicable limit of error.    | just the deviations |
|       |    | > This is only applicable in    | between center and  |
|       |    | > the few instances where the   | corners.            |
|       |    | > load is very near the limit   |                     |
|       |    | > of error change value.\       |                     |
|       |    | > Why does this statement need  |                     |
|       |    | > to be in the Recommendation?  |                     |
|       |    | > We suggest it be removed.     |                     |
+-------+----+---------------------------------+---------------------+
| A.4.7 | SI | > It is necessary to replace    | P+ We changed it as |
|       |    | > the wording "bad results" in  | proposed            |
|       |    | > the last sentence of the      |                     |
|       |    | > fourth paragraph to something |                     |
|       |    | > metrologicaly more            |                     |
|       |    | > appropriate, e.g. "However in |                     |
|       |    | > case of exceeding mpe the     |                     |
|       |    | > test with zero error prior to |                     |
|       |    | > each loading is necessary."   |                     |
+-------+----+---------------------------------+---------------------+
| A.4.7 | UK | > The new sentence starting     | P+ See A.4.7 SI     |
|       |    | > "However in case of bad       |                     |
|       |    | > results\..." could be         |                     |
|       |    | > improved along the lines of   |                     |
|       |    | > "However, should a failure    |                     |
|       |    | > occur ...".                   |                     |
+-------+----+---------------------------------+---------------------+
| A.    | CA | Instrument used for weighing    | P+: Yes we agree,   |
| 4.7.4 |    | rolling loads (3.6.2.4)         | because these       |
|       |    |                                 | instruments are     |
|       |    | > We must restate our concern   | similar to          |
|       |    | > with this section. Although   | multirange          |
|       |    | > the test may be valid, it     | instruments. See    |
|       |    | > appears incomplete.           | new wording in 2CD. |
|       |    | > Individual 'sections' of the  |                     |
|       |    | > scale are never tested using  |                     |
|       |    | > this method. It would only    |                     |
|       |    | > work on a scale of 2-3        |                     |
|       |    | > sections, for scales of 4 or  |                     |
|       |    | > more sections, the test       |                     |
|       |    | > pattern is incomplete.        |                     |
+-------+----+---------------------------------+---------------------+
| A.    | FR | > 1^st^ line : read : "A        | P+                  |
| 4.7.4 |    | > ~~rolling~~ load shall be     |                     |
|       |    | > ..."*.*                       |                     |
+-------+----+---------------------------------+---------------------+
| A.    | CA | > **Eccentricity for mobile     | P+ See 2CD, A.4.7   |
| 4.7.5 |    | > instrument**                  |                     |
|       |    | >                               |                     |
|       |    | > This section contains a       |                     |
|       |    | > sentence which states "If     |                     |
|       |    | > operating conditions are such |                     |
|       |    | > that no eccentricity can      |                     |
|       |    | > occur, eccentricity tests     |                     |
|       |    | > need not be performed."       |                     |
|       |    | >                               |                     |
|       |    | > Canada feels that this is a   |                     |
|       |    | > general statement regarding   |                     |
|       |    | > eccentricity and it should be |                     |
|       |    | > applicable to all devices,    |                     |
|       |    | > not simply portable devices.  |                     |
|       |    | > This statement should be      |                     |
|       |    | > moved to section A.4.7.       |                     |
+-------+----+---------------------------------+---------------------+
| A.    | FR | For the same reason than those  | P- Please refer to  |
| 4.8.2 |    | concerning 3.8, the first       | 3.8 FR              |
|       |    | sentence shall be changed into  |                     |
|       |    | : "This test applies only to    |                     |
|       |    | type examination ~~and to       |                     |
|       |    | instruments with d 5 mg~~".     |                     |
+-------+----+---------------------------------+---------------------+
| A.    | NL | The word "*replaced* " in the   | P+ See new text in  |
| 4.8.2 |    | sentence: "*One of the          | 2CD.                |
|       |    | additional weights shall be     |                     |
|       |    | replaced and a load ...*" could | P- The indication   |
|       |    | be misread as "exchanged".      | may, but need not,  |
|       |    |                                 | increase by one     |
|       |    | Furthermore, it is not clear    | scale interval.     |
|       |    | that when this additional       |                     |
|       |    | weight is placed back the       |                     |
|       |    | indication should increase      |                     |
|       |    | again.                          |                     |
|       |    |                                 |                     |
|       |    | We propose to change the        |                     |
|       |    | wording to: "*One of the        |                     |
|       |    | additional weights shall be     |                     |
|       |    | placed back (Indication         |                     |
|       |    | increases one scale interval)   |                     |
|       |    | and a load ..."*                |                     |
+-------+----+---------------------------------+---------------------+
| A     | UK | > In the new last sentence,     | P+                  |
| .4.10 |    | > beginning "3 weighings        |                     |
|       |    | > on\...", change "3" to        |                     |
|       |    | > "Three", and then to be       |                     |
|       |    | > consistent change "6" to      |                     |
|       |    | > "six".                        |                     |
+-------+----+---------------------------------+---------------------+
| A     | C  | It is not acceptable that a     | P+: See 2CD,        |
| .4.12 | EC | detailed description of the     | slightly modified.  |
|       | IP | stable equilibrium or any other |                     |
|       |    | function design is required.    | The functionality   |
|       |    | There may exist an unlimited    | of the instrument   |
|       |    | number of different technical   | must be             |
|       |    | solutions from different        | sufficiently        |
|       |    | manufacturers that the notified | described anyway.   |
|       |    | bodies will not be able to      |                     |
|       |    | estimate all these solutions.   |                     |
|       |    | There will be not guarantee     |                     |
|       |    | that different notified bodies  |                     |
|       |    | will come to the same objective |                     |
|       |    | decision. Any examination of a  |                     |
|       |    | NAWI has to take the instrument |                     |
|       |    | as a "black box" and shall      |                     |
|       |    | compare the reaction and        |                     |
|       |    | accuracy of the instrument      |                     |
|       |    | against the requirements. The   |                     |
|       |    | technical way that was chosen   |                     |
|       |    | by a manufacturer to meet a     |                     |
|       |    | requirement is nonessential.    |                     |
|       |    | There is also no sense to       |                     |
|       |    | define a "worst case". A.4.12   |                     |
|       |    | has only to define a test       |                     |
|       |    | method, nothing else. Please    |                     |
|       |    | delete the first part of A.4.12 |                     |
|       |    | completely.                     |                     |
+-------+----+---------------------------------+---------------------+
| A     | SI | Clause 4.4.2 defines that in    | P- It is not always |
| .4.12 |    | case of printing and/or data    | possible to get the |
|       |    | storage we compare the printed  | final weighing      |
|       |    | or stored weighing values with  | value during normal |
|       |    | [the final weighing             | operation.          |
|       |    | value]{.underline}, but A.4.12  |                     |
|       |    | requires the comparison between |                     |
|       |    | printed or stored weighing      |                     |
|       |    | values and [the indicated value |                     |
|       |    | over a period of 5 seconds      |                     |
|       |    | following                       |                     |
|       |    | print-out]{.underline}.         |                     |
|       |    |                                 |                     |
|       |    | We propose to rearrange         |                     |
|       |    | sentences                       |                     |
|       |    |                                 |                     |
|       |    | "In the case of printing or     |                     |
|       |    | data storage, read the          |                     |
|       |    | indicated value over a period   |                     |
|       |    | of 5 seconds following          |                     |
|       |    | print-out. Stable equilibrium   |                     |
|       |    | is considered to be achieved    |                     |
|       |    | when no more than two adjacent  |                     |
|       |    | values are indicated, one of    |                     |
|       |    | which being the printed value." |                     |
|       |    |                                 |                     |
|       |    | in a view of provisions of      |                     |
|       |    | clause 4.4.2 to                 |                     |
|       |    |                                 |                     |
|       |    | > "In the case of printing or   |                     |
|       |    | > data storage, read the final  |                     |
|       |    | > weigh value. Stable           |                     |
|       |    | > equilibrium is considered to  |                     |
|       |    | > be achieved when the printed  |                     |
|       |    | > or stored weighing values do  |                     |
|       |    | > not deviate more than 1 e     |                     |
|       |    | > from the final weighing value |                     |
|       |    | > (i.e. two adjacent values are |                     |
|       |    | > allowed)."                    |                     |
+-------+----+---------------------------------+---------------------+
| A     | UK | > (line beginning "- Definition | P+                  |
| .4.12 |    | > of\..."): "\...the the\...".  |                     |
+-------+----+---------------------------------+---------------------+
| A     | UK | > The sentence "There could be  | P+ See 2CD          |
| .4.13 |    | > more or less\..." should be   |                     |
|       |    | > re-worded to improve          |                     |
|       |    | > understanding.                |                     |
+-------+----+---------------------------------+---------------------+
| A.    | UK | > Health and safety             | P-: R76 considers   |
| 5.1.3 |    | > considerations need to be     | only metrological   |
|       |    | > taken into account when tilt  | requirements        |
|       |    | > testing high-sided or similar |                     |
|       |    | > vehicles.                     | P+                  |
|       |    | >                               |                     |
|       |    | > Also, in the new paragraph,   |                     |
|       |    | > the text should read "... the |                     |
|       |    | > load receptor comes into      |                     |
|       |    | > contact with the ..."         |                     |
+-------+----+---------------------------------+---------------------+
| A.    | CN | Whether or not change "-at a    | P- The test at 5°C  |
| 5.3.1 |    | temperature of 5 °C, if the     | is necessary to     |
|       |    | specified low temperature is    | check for           |
|       |    |  0 °C, ..."in A.5.3.1 into "-at | condensation        |
|       |    | a temperature of 5 °C, if the   | problems when       |
|       |    | specified low temperature is    | coming from low     |
|       |    | \< 0 °C, ...", because 0° and   | temperature. This   |
|       |    | 5° is quite near, it is not     | is important even   |
|       |    | necessary.                      | if the low          |
|       |    |                                 | temperature is 0°C. |
+-------+----+---------------------------------+---------------------+
| A.    | NL | Temperature effect on no-load:  | P- This has never   |
| 5.3.2 |    |                                 | been a serious      |
|       |    | This comment is based on        | problem in the past |
|       |    | combined Temperature effect on  | and thus does not   |
|       |    | no-load indication and Static   | need to be          |
|       |    | temperatures test.              | regulated. The      |
|       |    |                                 | notified body will  |
|       |    | During this test zero-track and | always be able to   |
|       |    | automatic zero-setting has to   | decide how to       |
|       |    | be switched off. However the    | determine the zero  |
|       |    | purpose of this test is to      | error, with or      |
|       |    | determine the behaviour of the  | without             |
|       |    | instrument during a **change**  | zero-setting.       |
|       |    | of temperature.                 |                     |
|       |    |                                 |                     |
|       |    | Sometimes the instrument is     |                     |
|       |    | being set to zero during the    |                     |
|       |    | measurement. For example with a |                     |
|       |    | zero-drift of more than 9e, the |                     |
|       |    | instrument needs to be set to   |                     |
|       |    | zero in order to perform the    |                     |
|       |    | static temperature test at Max. |                     |
|       |    | In this case the complete       |                     |
|       |    | Temperature effect on no-load   |                     |
|       |    | indication has to be repeated.  |                     |
|       |    |                                 |                     |
|       |    | Since the error at zero-load is |                     |
|       |    | determined before and after the |                     |
|       |    | static temperature measurements |                     |
|       |    | it is not important if these    |                     |
|       |    | zero-load values differ         |                     |
|       |    | significantly (due to           |                     |
|       |    | zero-setting) because the       |                     |
|       |    | temperature is constant during  |                     |
|       |    | this test. During the change of |                     |
|       |    | temperature the zero-setting    |                     |
|       |    | and zero-tracking needs to be   |                     |
|       |    | disabled.                       |                     |
|       |    |                                 |                     |
|       |    | We would like to have the       |                     |
|       |    | possibility to set the          |                     |
|       |    | instrument to zero provided     |                     |
|       |    | that the errors on no-load are  |                     |
|       |    | determined before and after the |                     |
|       |    | setting to zero and the         |                     |
|       |    | temperature is constant.        |                     |
|       |    |                                 |                     |
|       |    | Proposed addition: *Zero        |                     |
|       |    | setting allowed when before and |                     |
|       |    | after the zero-setting          |                     |
|       |    | operation the error of the zero |                     |
|       |    | indication is determined and    |                     |
|       |    | the temperature during this     |                     |
|       |    | period has not changed.*        |                     |
+-------+----+---------------------------------+---------------------+
| A.5.4 | NL | > Consider to perform this test | P- In contrast to   |
|       |    | > only with 10e.                | the EMC tests the   |
|       |    |                                 | mpe apply here.     |
+-------+----+---------------------------------+---------------------+
| A.5.4 | UK | > The sentence "The test        | P+ See 2CD          |
|       |    | > consists\..." should be       |                     |
|       |    | > re-worded to say that the     |                     |
|       |    | > appropriate variation should  |                     |
|       |    | > be applied. It currently      |                     |
|       |    | > implies that the EUT should   |                     |
|       |    | > be subjected to all of these  |                     |
|       |    | > variations.                   |                     |
+-------+----+---------------------------------+---------------------+
| A.    | NL | > This is not in line with D11  | See also 3.9.3 NL   |
| 5.4.2 |    | > for battery operated          |                     |
|       |    | > instruments                   | P+ We agree, and    |
|       |    | >                               | have changed the    |
|       |    | > For the normal (disposable)   | wording so that     |
|       |    | > batteries, we do not see any  | this requirement is |
|       |    | > justification for requiring   | valid only for      |
|       |    | > 1,2 *U* for battery supply.   | instruments that    |
|       |    |                                 | are powered with    |
|       |    |                                 | rechargeable        |
|       |    |                                 | batteries or        |
|       |    |                                 | batteries for road  |
|       |    |                                 | vehicles. In that   |
|       |    |                                 | case 1,2 U is       |
|       |    |                                 | easily possible     |
|       |    |                                 | just after          |
|       |    |                                 | charging.           |
|       |    |                                 |                     |
|       |    |                                 | In addition         |
|       |    |                                 | "Battery operated   |
|       |    |                                 | instruments" has    |
|       |    |                                 | been exchanged by   |
|       |    |                                 | "Battery powered    |
|       |    |                                 | instruments" in the |
|       |    |                                 | entire document.    |
+-------+----+---------------------------------+---------------------+
| B     | CA | > Canada questions why this     | P- See our response |
|       |    | > Annex is included in the      | under "General"     |
|       |    | > recommendation. The           | CA.\                |
|       |    | > preliminary note at the       | (D11 requires       |
|       |    | > beginning of the Annex states | "implementation"    |
|       |    | > that the latest draft         | into the specific   |
|       |    | > revision of D11 has been      | Recommendation!)    |
|       |    | > taken into consideration in   |                     |
|       |    | > development of the Annex.     |                     |
|       |    |                                 |                     |
|       |    | This is cause for concern. If   |                     |
|       |    | D-11 changes, R76 will no       |                     |
|       |    | longer be in harmony with D-11. |                     |
|       |    | We suggest that R76 merely      |                     |
|       |    | reference D-11 rather than      |                     |
|       |    | incorporate it.                 |                     |
+-------+----+---------------------------------+---------------------+
| B     | CN | > EMC (Electromagnetic          | P- EMC is used in   |
|       |    | > Compatibility) tests consist  | accordance with     |
|       |    | > of EMS (Electromagnetic       | OIML D11 (2004) and |
|       |    | > Susceptibility) and EMI       | International (IEC  |
|       |    | > (Electromagnetic              | / ISO) Standards    |
|       |    | > Interference). Tests for      | which must be used  |
|       |    | > disturbances not only EMS     | as reference        |
|       |    | > (according with IEC 61000),   | documents here.     |
|       |    | > but also EMI (according with  | Other (regional)    |
|       |    | > CISPR 22 ).                   | standards cannot be |
|       |    | >                               | used in this        |
|       |    | > We suggest that the tests for | context.            |
|       |    | > disturbances of "Instrument   |                     |
|       |    | > for direct sales to the       | We assume that by   |
|       |    | > public" and "Hanging (Crane)  | "EMI" you           |
|       |    | > Instrument " should be added  | understand          |
|       |    | > in EMI (according with CISPR  | "electromagnetic    |
|       |    | > 22).                          | emission". This is, |
|       |    | >                               | however, not under  |
|       |    | > The International Standard is | the scope of OIML   |
|       |    | > as follows: CISPR 22:1997 \<  | (neither D11 nor    |
|       |    | > Information technology        | R76). It might be   |
|       |    | > equipment - Radio disturbance | regulated under     |
|       |    | > characteristics - Limits and  | national or         |
|       |    | > methods of measurement \>     | regional            |
|       |    |                                 | legislation.        |
|       |    |                                 |                     |
|       |    |                                 | P- We can also not  |
|       |    |                                 | agree for "direct   |
|       |    |                                 | sales scales" and   |
|       |    |                                 | "hanging crane"     |
|       |    |                                 | scales, because     |
|       |    |                                 | except for some     |
|       |    |                                 | tests (eccentricity |
|       |    |                                 | and tilting) R76    |
|       |    |                                 | requires these      |
|       |    |                                 | tests for           |
|       |    |                                 | [all]{.underline}   |
|       |    |                                 | NAWIS.              |
+-------+----+---------------------------------+---------------------+
| B     | JP | > The numbering of referred     | P+ Both the         |
|       |    | > standards should be reviewed  | Bibliography and    |
|       |    | > and those should be referred  | all references in   |
|       |    | > in the text correctly.        | the document have   |
|       |    |                                 | been completely     |
|       |    |                                 | revised and         |
|       |    |                                 | updated.            |
+-------+----+---------------------------------+---------------------+
| B     | UK | The very first note:            | P+: See also under  |
|       |    |                                 | "Contents" UK       |
|       |    | > The text "... conducted on    |                     |
|       |    | > the basis of most recent      |                     |
|       |    | > versions valid at the time of |                     |
|       |    | > testing" could pose problems  |                     |
|       |    | > in actually determining if    |                     |
|       |    | > the most recent version was   |                     |
|       |    | > actually used. The sentiment  |                     |
|       |    | > is understood, but a          |                     |
|       |    | > practical solution is         |                     |
|       |    | > required.                     |                     |
+-------+----+---------------------------------+---------------------+
| B.1   | CA | > This entire Annex should be   | Each test is        |
|       |    | > limited to modules of any     | difficult for       |
|       |    | > capacity, except weighing     | instruments with a  |
|       |    | > modules, and complete         | large Max. In       |
|       |    | > instruments having a Maximum  | nearly all cases it |
|       |    | > capacity no greater than 1    | would be possible   |
|       |    | > 000 kg. It is very unlikely   | to perform the      |
|       |    | > that these tests could be     | tests on an         |
|       |    | > performed on large            | indicator with a    |
|       |    | > instruments.                  | small weighbridge.  |
|       |    |                                 | For high capacity   |
|       |    | If the Recommendation is to be  | weighing            |
|       |    | applied consistently, how do    | instruments one can |
|       |    | you reconcile the fact that     | also make use of    |
|       |    | larger instruments may not be   | the modular         |
|       |    | subjected to the tests as       | concept.            |
|       |    | outlined in this Annex? We are  |                     |
|       |    | thinking of large weighing      | These instruments   |
|       |    | element specifically -- perhaps | are not exempt from |
|       |    | they are already exempt from    | these tests. If it  |
|       |    | these test?                     | is not possible to  |
|       |    |                                 | perform the tests   |
|       |    |                                 | on large            |
|       |    |                                 | instruments then    |
|       |    |                                 | modules of the      |
|       |    |                                 | instrument shall be |
|       |    |                                 | tested separately.  |
+-------+----+---------------------------------+---------------------+
| B.1   | UK | > Says "EUT" stands for         | P+ We have deleted  |
|       |    | > "electronic instruments under | "(EUT)" in the      |
|       |    | > test", which doesn't fit the  | heading of B.1,     |
|       |    | > acronym. However T7 on Page   | because "EUT" will  |
|       |    | > 21, and Section 3.10.4, say   | now only be used    |
|       |    | > the usual "equipment under    | for "equipment      |
|       |    | > test".                        | under test" (see    |
|       |    |                                 | also "Contents" UK) |
+-------+----+---------------------------------+---------------------+
| B.3   | SI | > Add "as it is defined in      | P+ See 2CD          |
|       |    | > B.3.7." at the end of the     |                     |
|       |    | > last paragraph.               |                     |
+-------+----+---------------------------------+---------------------+
| B.3.1 | UK | > Now says that the "test       | P+ See 2CD          |
|       |    | > generator shall be            |                     |
|       |    | > verified\...". Could          | Changes also in     |
|       |    | > "verified" be replaced by     | B.3.2, B.3.3 and    |
|       |    | > some other word, to avoid     | B.3.4               |
|       |    | > confusion? Similarly Section  |                     |
|       |    | > B.3.2, B.3.3 and B.3.4.       |                     |
+-------+----+---------------------------------+---------------------+
| B.3.3 | C  | > Industrial customers force    | P- There was a vote |
|       | EC | > the manufacturers of          | to upgrade EMC      |
|       | IP | > instruments to meet not only  | testing acc. to the |
|       |    | > the product related standards | development of      |
|       |    | > like R76 but also generic IEC | International       |
|       |    | > standards for compliance with | Standards. In       |
|       |    | > electromagnetic effects.      | addition "Surge" is |
|       |    | > Therefore OIML should avoid   | already included in |
|       |    | > starting to copy any EMC      | other               |
|       |    | > standard existing in the      | O                   |
|       |    | > world. That is not possible   | IML-Recommendations |
|       |    | > and useful. As Dutch NMI      | concerning weighing |
|       |    | > pointed out a surge testing   | instruments (e.g.   |
|       |    | > is not essential for normal   | R51); therefore it  |
|       |    | > industrial applications. In   | cannot be deleted   |
|       |    | > extreme cases the general     | here.               |
|       |    | > clause 4.1.1.1 or 5.1.1 comes |                     |
|       |    | > into force. Please delete     |                     |
|       |    | > B.3.3 completely.             |                     |
+-------+----+---------------------------------+---------------------+
| B.3.3 | JP | > Maximum allowable variations: | P- There is no      |
|       |    | > "The difference ... shall not | reason to deviate   |
|       |    | > exceed e..." is too severe.   | from T.5.5.6,       |
|       |    | > "...the instrument shall      | especially because  |
|       |    | > detect and react to a         | the test is         |
|       |    | > significant fault" is short   | conducted with a    |
|       |    | > on specifics and different    | small test load.    |
|       |    | > interpretation might be       | Please refer also   |
|       |    | > developed. The description    | to the examples of  |
|       |    | > for this point should be made | non-significant     |
|       |    | > clearer and more concrete. In | faults given in     |
|       |    | > addition, the definition for  | T.5.5.6.            |
|       |    | > indoor and outdoor use should |                     |
|       |    | > be also specified.            | In addition we      |
|       |    |                                 | think that with the |
|       |    |                                 | introductory note   |
|       |    |                                 | left at the         |
|       |    |                                 | beginning of B.3.3, |
|       |    |                                 | indoor and outdoor  |
|       |    |                                 | situations are now  |
|       |    |                                 | defined             |
|       |    |                                 | sufficiently clear. |
+-------+----+---------------------------------+---------------------+
| B.3.4 | CN | > In B.3.4, we propose to       | P- We should keep   |
|       |    | > change "The time interval     | in line with D11    |
|       |    | > between successive discharges | (2004) which        |
|       |    | > shall be at least 10          | requires at least   |
|       |    | > seconds." into "The time      | 10 seconds.         |
|       |    | > interval between successive   |                     |
|       |    | > discharges shall be at least  |                     |
|       |    | > 1 second.".                   |                     |
+-------+----+---------------------------------+---------------------+
| B.3.5 | C  | > It is not acceptable to       | P+ See 2CD          |
|       | EC | > separate different test       |                     |
|       | IP | > severity levels for           |                     |
|       |    | > instruments used in household |                     |
|       |    | > or in industrial              |                     |
|       |    | > applications. As long as      |                     |
|       |    | > there is no descriptive       |                     |
|       |    | > marking on an instrument      |                     |
|       |    | > informing the user about the  |                     |
|       |    | > allowed location all          |                     |
|       |    | > instruments have to be        |                     |
|       |    | > examined with the same test   |                     |
|       |    | > severity level. That means    |                     |
|       |    | > all instruments have to be    |                     |
|       |    | > examined with either with 10  |                     |
|       |    | > V/m or all with 3 V/m.        |                     |
+-------+----+---------------------------------+---------------------+
| B.3.5 | UK | > For retail applications it    | This is, indeed,    |
|       |    | > now appears to be saying that | not correct. B.3.5  |
|       |    | > 3 V/m on one face only is     | has therefore been  |
|       |    | > acceptable. Is this correct?  | corrected and is    |
|       |    |                                 | now in line with    |
|       |    |                                 | D11 (12.1)          |
+-------+----+---------------------------------+---------------------+
| B.3.6 | C  | > It is not acceptable to       | P+ According to     |
|       | EC | > separate different test       | 61000-4-6 conducted |
|       | IP | > severity levels for           | and radiated field  |
|       |    | > instruments used in household | strength shall be   |
|       |    | > or in industrial              | equal. Following    |
|       |    | > applications. As long as      | change in B.3.5 we  |
|       |    | > there is no descriptive       | have chosen 10 V/m. |
|       |    | > marking on an instrument      |                     |
|       |    | > informing the user about the  | Remark: EN61326 is  |
|       |    | > allowed location all          | only a (regional)   |
|       |    | > instruments have to be        | product family      |
|       |    | > examined with the same test   | standard for        |
|       |    | > severity level. That means    | electrical          |
|       |    | > all instruments have to be    | measuring, control  |
|       |    | > examined with either with 10  | and laboratory      |
|       |    | > V/m or all with 3 V/m.        | instruments.        |
|       |    |                                 |                     |
|       |    | For information: In the         |                     |
|       |    | European Standard EN61326 the   |                     |
|       |    | test level was reduced from 10V |                     |
|       |    | to 3V with the following        |                     |
|       |    | comment:                        |                     |
|       |    |                                 |                     |
|       |    | > The test level for the        |                     |
|       |    | > conducted RF test is lower    |                     |
|       |    | > than the level for the        |                     |
|       |    | > radiated RF test because the  |                     |
|       |    | > conducted RF test simulates   |                     |
|       |    | > the resonance condition at    |                     |
|       |    | > each frequency and is thus a  |                     |
|       |    | > more severe test.             |                     |
+-------+----+---------------------------------+---------------------+
| B.3.6 | UK | > "acccording" should be        | P+                  |
|       |    | > "according".                  |                     |
+-------+----+---------------------------------+---------------------+
| B.3.7 | NL | > Replace ISO 7637-2.3 by ISO   | P+ See 2CD          |
|       |    | > 7637-2 (2004).                |                     |
|       |    | >                               | P+ See 2CD          |
|       |    | > Delete test pulse 1 and       |                     |
|       |    | > reconsider the application of |                     |
|       |    | > test pulse 2b (see the final  |                     |
|       |    | > version 2004 of D11).         |                     |
+-------+----+---------------------------------+---------------------+
| B.3.7 | SI | > For better clarity replace    | P+ See 2CD          |
|       |    | > the heading "Special EMC      |                     |
|       |    | > requirements for road         |                     |
|       |    | > vehicles" with "Special EMC   |                     |
|       |    | > requirements for NAWI powered |                     |
|       |    | > from vehicle battery".        |                     |
+-------+----+---------------------------------+---------------------+
| B.4   | JP | > For the test sequence, it is  | P- No change. This  |
|       |    | > specified as "Automatic       | is a contradiction  |
|       |    | > zero-tracking shall be made   | to A.4.1.8. The     |
|       |    | > inoperative and automatic     | behaviour of the    |
|       |    | > built-in span adjustment      | user (in this case  |
|       |    | > device shall be made          | releasing an        |
|       |    | > operative". As the same can   | adjustment) shall   |
|       |    | > be said to semi-automatic     | not be part of a    |
|       |    | > built-in span adjustment      | test. It is not     |
|       |    | > device, "Semi-automatic       | guaranteed that     |
|       |    | > built-in span adjustment      | this device will    |
|       |    | > device shall be made          | ever be used so the |
|       |    | > operative before testing"     | worst case needs to |
|       |    | > should be added.              | be covered. An      |
|       |    |                                 | automatic built-in  |
|       |    |                                 | span adjustment     |
|       |    |                                 | device works fully  |
|       |    |                                 | automatically       |
|       |    |                                 | during normal use.  |
+-------+----+---------------------------------+---------------------+
| C.1   | UK | Line 3.9.3: "suply" should be   | P+                  |
|       |    | "supply".                       |                     |
|       |    |                                 | P+                  |
|       |    | Line 4.7: Uses "preset-tare",   |                     |
|       |    | but elsewhere it is "preset     | P+                  |
|       |    | tare" without the hyphen.       |                     |
|       |    |                                 |                     |
|       |    | Line 4.9: Has "removeable", but |                     |
|       |    | this spelling is rare;          |                     |
|       |    | "removable" is much more common |                     |
|       |    | and is used in the actual       |                     |
|       |    | Section 4.9.                    |                     |
+-------+----+---------------------------------+---------------------+
| C.1   | US | > The U.S. recommends that the  | P- No change, 4.5.1 |
|       |    | > list of applicable            | is included in      |
|       |    | > requirements include 4.5.1.   | "4.5"               |
|       |    | > Maximum effect (of range of   |                     |
|       |    | > the initial zero setting      |                     |
|       |    | > device).                      |                     |
+-------+----+---------------------------------+---------------------+
| C.1.1 | CA | > May conflict with section     | P+ See 2CD          |
|       |    | > D.1.2.2                       |                     |
|       |    | >                               |                     |
|       |    | > Indicator Accuracy Class must |                     |
|       |    | > be same as weighing element.  |                     |
|       |    | > However, D.1.2.2 allows       |                     |
|       |    | > exception to this. Is this a  |                     |
|       |    | > problem? Suggest that wording |                     |
|       |    | > be changed to state: "*The    |                     |
|       |    | > indicator shall be of the     |                     |
|       |    | > same accuracy class or a      |                     |
|       |    | > higher accuracy class, than   |                     |
|       |    | > the weighing instrument it is |                     |
|       |    | > intended to be used with.*"   |                     |
+-------+----+---------------------------------+---------------------+
| C.1.1 | CN | > We suggest changing "The      | P+ see C.1.1 CA     |
|       |    | > indicator shall have the same |                     |
|       |    | > accuracy class as the         |                     |
|       |    | > weighing instrument it is     |                     |
|       |    | > intended to be used with." in |                     |
|       |    | > C.1.1 into "The indicator     |                     |
|       |    | > shall have the same accuracy  |                     |
|       |    | > class or higher accuracy      |                     |
|       |    | > class as the weighing         |                     |
|       |    | > instrument it is intended to  |                     |
|       |    | > be used with."(see also       |                     |
|       |    | > E.3.1).                       |                     |
+-------+----+---------------------------------+---------------------+
| C.1.2 | CA | > Conflicts with section        | P- No change. These |
|       |    | > D.1.2.3                       | chapters concerns   |
|       |    | >                               | several modules,    |
|       |    | > Both sections require the     | e.g. an indicator   |
|       |    | > same or higher number of      | with 6000 e can be  |
|       |    | > verification scale intervals. | used in an          |
|       |    | > This effectively means they   | instrument with     |
|       |    | > must both have the same       | only 3000 e.        |
|       |    | > number of verification scale  |                     |
|       |    | > intervals. Suggest that the   |                     |
|       |    | > section D.1.2.3 need not be   |                     |
|       |    | > included.                     |                     |
+-------+----+---------------------------------+---------------------+
| C.1.3 | CA | > Conflicts with section        | P- No change. These |
|       |    | > D.1.2.4                       | chapters concerns   |
|       |    | >                               | several modules,    |
|       |    | > Both sections require the     | e.g. an indicator   |
|       |    | > same or larger temperature    | of class III with   |
|       |    | > range than the other. This    | ‑10°C to 40°C can   |
|       |    | > effectively means that the    | be used in an       |
|       |    | > temperature range must be     | instrument with 0°C |
|       |    | > identical. One should         | to 30°C.            |
|       |    | > supercede the other.          |                     |
+-------+----+---------------------------------+---------------------+
| C.1.6 | CN | > For the problem of range of   | P- No change,       |
|       |    | > load cell impedance (C.1.6),  | "impedance" is      |
|       |    | > whether the input impedance   | correct.            |
|       |    | > can be expressed as the       |                     |
|       |    | > maximum current of            |                     |
|       |    | > excitation.                   |                     |
+-------+----+---------------------------------+---------------------+
| C.1.7 | SI | > Start the first sentence with | P+ See 2CD          |
|       |    | > "Only indicators\..." to      |                     |
|       |    | > stress that only 6-wire       |                     |
|       |    | > technology is allowed.        |                     |
+-------+----+---------------------------------+---------------------+
| C.2.2 | CN | For C.2.2: Table 12             | P.  We understand   |
|       |    |                                 |     your point of   |
|       |    | *B.3.1*                         |     view, but in    |
|       |    |                                 |     practice the    |
|       |    | *Short time power reduction*    |     tests B.3.1 to  |
|       |    |                                 |     B.3.5 are       |
|       |    | *1*                             |     applied with    |
|       |    |                                 |     the same test   |
|       |    | *[high\*)]{.mark}*              |     equipment and   |
|       |    |                                 |     the same load   |
|       |    | *min*                           |     cell.           |
|       |    |                                 |                     |
|       |    | > Whether [*high\**)]{.mark} is | For simplifying the |
|       |    | > *[low\*)]{.mark}*？           | procedure the test  |
|       |    | >                               | B.3.1 shall be done |
|       |    | > It is not right that the      | with the same test  |
|       |    | > impedance of the load cell    | set up.             |
|       |    | > only refer to the input       |                     |
|       |    | > impedance of it. For the      |                     |
|       |    | > great impedance, the interior |                     |
|       |    | > impedance of signal source in |                     |
|       |    | > indicator, that is, the       |                     |
|       |    | > output impedance of the load  |                     |
|       |    | > cell has the larger influence |                     |
|       |    | > to indicator. The input       |                     |
|       |    | > impedance of one load cell is |                     |
|       |    | > equal to the output impedance |                     |
|       |    | > of it, whose expression is    |                     |
|       |    | > not mathematical. To limit    |                     |
|       |    | > the (equivalent) minimum      |                     |
|       |    | > input impedance is more       |                     |
|       |    | > suitable than to do the       |                     |
|       |    | > (equivalent) maximum input    |                     |
|       |    | > impedance. Here, is that      |                     |
|       |    | > 'equivalent' indicates        |                     |
|       |    | > impedance from the angel of   |                     |
|       |    | > indicator fit?                |                     |
+-------+----+---------------------------------+---------------------+
| C.2.2 | JP | > In Table 12, B.3.3 should be  | P+ See 2CD          |
|       |    | > changed to B.3.4 and B.3.4 to |                     |
|       |    | > B.3.5.                        | Yes                 |
|       |    | >                               |                     |
|       |    | > Aren't the tests in B.3.3,    |                     |
|       |    | > B.3.6 and B.3.7 required?     |                     |
+-------+----+---------------------------------+---------------------+
| C.2.2 | SI | > Revise Table 12 with EMC      | P+ See C.2.2 JP     |
|       |    | > tests as defined in B.3       |                     |
|       |    | > (surge, immunity to radiated  |                     |
|       |    | > EMF and conducted             |                     |
|       |    | > disturbances, transients).    |                     |
+-------+----+---------------------------------+---------------------+
| C.2.7 | UK | Sentence beginning "The         | P+                  |
|       |    | manufacturer has to fix\...:    |                     |
|       |    |                                 |                     |
|       |    | > "than" should be "then". Also |                     |
|       |    | > remove "to" from              |                     |
|       |    | > "\...assigned to".            |                     |
+-------+----+---------------------------------+---------------------+
| C.3   | JP | > In C.3, item 4.12.3 listed    | P+                  |
|       |    | > does not exist. Item 4.14.10  |                     |
|       |    | > may be 4.13.10. Please        |                     |
|       |    | > confirm.                      |                     |
+-------+----+---------------------------------+---------------------+
| C.    | CN | > On P111, in C.3.1.1 (e), P~i~ | P+                  |
| 3.1.1 |    | > × 1e / 5K shall be revised    |                     |
|       |    | > into P~i~ × e / 5K;           |                     |
+-------+----+---------------------------------+---------------------+
| C.    | SI | > An explanation is missing     | P+ See 2CD          |
| 3.1.1 |    | > whether the procedure         |                     |
|       |    | > described from (a) to (f)     |                     |
|       |    | > refers to indicators with     |                     |
|       |    | > verification scale interval   |                     |
|       |    | > more, equal or less than 1    |                     |
|       |    | > µV. It is also not clear if   |                     |
|       |    | > this procedure is the         |                     |
|       |    | > acceptable solution or the    |                     |
|       |    | > prescribed testing procedure. |                     |
+-------+----+---------------------------------+---------------------+
| C.    | SI | > The first sentence is not     | P+                  |
| 3.3.1 |    | > complete and not              |                     |
|       |    | > understandable.               |                     |
+-------+----+---------------------------------+---------------------+
| C.    | UK | > The wording of the first      | P+                  |
| 3.3.1 |    | > sentence needs to be changed. |                     |
+-------+----+---------------------------------+---------------------+
| C.    | US | Typographical error:            | P+                  |
| 3.3.1 |    |                                 |                     |
|       |    | > C.3.3.1 Scope                 |                     |
|       |    | >                               |                     |
|       |    | > Indicators intended for       |                     |
|       |    | > connection of strain [gauge   |                     |
|       |    | > load cells employ the 4- or   |                     |
|       |    | > the 6-wire principle of the   |                     |
|       |    | > load cell connection. When    |                     |
|       |    | > 4-wire                        |                     |
|       |    | > tec]{.underline}hnology is    |                     |
|       |    | > used[,]{.underline}           |                     |
|       |    | > lengthening ~~cable~~ the     |                     |
|       |    | > load cell cable or using a    |                     |
|       |    | > separate load cell junction   |                     |
|       |    | > box with an extra cable is    |                     |
|       |    | > not allowed at all. . .       |                     |
+-------+----+---------------------------------+---------------------+
| C.    | UK | > Change the word "charge" to   | P+                  |
| 3.3.2 |    | > "value".                      |                     |
+-------+----+---------------------------------+---------------------+
| C.    | DK | > Please add the following very | P- There was no     |
| 3.3.2 |    | > important test:               | TC9/SC1 vote for    |
|       |    | >                               | introducing such a  |
|       |    | > The sense circuit shall also  | new test            |
|       |    | > be tested under conditions    |                     |
|       |    | > where the connections of the  |                     |
|       |    | > sense wires are interrupted   |                     |
|       |    | > one after the other. The      |                     |
|       |    | > difference in indication with |                     |
|       |    | > sense and no-sense shall not  |                     |
|       |    | > exceed mpe or the exceeding   |                     |
|       |    | > shall be so large that it is  |                     |
|       |    | > evident for the user that     |                     |
|       |    | > something is wrong (more than |                     |
|       |    | > 10% wrong indication).        |                     |
+-------+----+---------------------------------+---------------------+
| C.3.  | UK | > "\...in parallel to\..."      | P+                  |
| 3.2.1 |    | > should be "\...in parallel    |                     |
|       |    | > with\...".                    |                     |
+-------+----+---------------------------------+---------------------+
| C.3.  | UK | > Replace the word              | P+                  |
| 3.2.2 |    | > "neglectable" with            |                     |
|       |    | > "negligible".                 |                     |
+-------+----+---------------------------------+---------------------+
| C.3.  | UK | > Replace "readjusted" with     | P- The indicator    |
| 3.2.3 |    | > "re-calibrated"               | shall be adjusted,  |
|       |    | >                               | not calibrated      |
|       |    | > and replace "placed" with     |                     |
|       |    | > wither "adjusted" or "set".   | P+ See 2CD          |
+-------+----+---------------------------------+---------------------+
| C.4.1 | FR | > First sentence of the second  | P+                  |
|       |    | > paragraph, read : "... under  |                     |
|       |    | > "Identification of the        |                     |
|       |    | > certified ~~type~~ module":". |                     |
+-------+----+---------------------------------+---------------------+
| C.4.1 | UK | > "\...intervals,minimum\..."   | P+                  |
|       |    | > should have a space after the |                     |
|       |    | > comma.                        |                     |
+-------+----+---------------------------------+---------------------+
| D.2.2 | ZA | > Last Par: We suggest to       | P+ Has been changed |
|       |    | > change the sentence from "An  | to: "The indicating |
|       |    | > any case the indicating       | device should       |
|       |    | > device should allow..." to    | preferably allow    |
|       |    | > "The indicating device shall  | indication to a     |
|       |    | > allow indication to a higher  | higher              |
|       |    | > resolution to determine the   | resolution...", see |
|       |    | > error, e.g. in a special      | 2CD.\               |
|       |    | > service mode.                 | " Shall" cannot be  |
|       |    |                                 | required, see D.2.2 |
|       |    |                                 | UK.                 |
+-------+----+---------------------------------+---------------------+
| D.2.2 | UK | Sentence beginning "An any      | P+ See 2CD          |
|       |    | case":                          |                     |
|       |    |                                 |                     |
|       |    | > Is it really intended that a  |                     |
|       |    | > high resolution mode be       |                     |
|       |    | > compulsory? This sentence     |                     |
|       |    | > needs to be re-worded.        |                     |
+-------+----+---------------------------------+---------------------+
| D.4.2 | UK | Line numbered 2: "Weighing      | P+                  |
|       |    | instrument" should be "module", |                     |
|       |    | as in C.4.2.                    | P+                  |
|       |    |                                 |                     |
|       |    | > Line 7: "srew" should be      |                     |
|       |    | > "screw".                      |                     |
+-------+----+---------------------------------+---------------------+
| E     | FR | > In the list of necessary data | P+ Has been added   |
|       |    | > to check the compatibility,   |                     |
|       |    | > add the humidity evaluation   |                     |
|       |    | > symbol (NH, SH, CH or no      |                     |
|       |    | > symbol) of the load cells.    |                     |
+-------+----+---------------------------------+---------------------+
| E.1   | CA | > There is a question mark "?"  | P+                  |
|       |    | > after the phrase "Connecting  |                     |
|       |    | > system, 6 wire system?" Does  |                     |
|       |    | > this belong here?             |                     |
|       |    | >                               |                     |
|       |    | > Canada agrees with the        |                     |
|       |    | > Secratariat's response.       |                     |
+-------+----+---------------------------------+---------------------+
| E.1   | UK | > Add "The" to the sentence     | P+                  |
|       |    | > "Following metrological\..."  |                     |
|       |    | > to make "The following        | P+                  |
|       |    | > metrological\..."             |                     |
|       |    | >                               | P+                  |
|       |    | > Line starting "*DL\...*"):    |                     |
|       |    | > "himself" should be "itself". |                     |
|       |    | >                               |                     |
|       |    | > Replace "... and additional   |                     |
|       |    | > fix mounted constructions on  |                     |
|       |    | > the load receptor." with "... |                     |
|       |    | > and any additional            |                     |
|       |    | > construction mounted on the   |                     |
|       |    | > load receptor.".              |                     |
+-------+----+---------------------------------+---------------------+
| E.1   | US | Insert the word "the" at the    | P+                  |
|       |    | beginning of the sentence as    |                     |
|       |    | follows:                        |                     |
|       |    |                                 |                     |
|       |    | > The ~~F~~following            |                     |
|       |    | > metrological and technical    |                     |
|       |    | > data of the weighing          |                     |
|       |    | > instrument are necessary for  |                     |
|       |    | > the check of compatibility:   |                     |
+-------+----+---------------------------------+---------------------+
| E.2.1 | CN | > The format of table 13 in     | P+                  |
|       |    | > E.2.1can be amended as        |                     |
|       |    | > follows:                      | P+                  |
|       |    |                                 |                     |
|       |    |   ---- --------                 |                     |
|       |    | ------------------------------- |                     |
|       |    | --- --------------------------- |                     |
|       |    | --------------- --------------- |                     |
|       |    | ------------------------------- |                     |
|       |    | ------- ----------------------- |                     |
|       |    | ------------------- ----------- |                     |
|       |    |        Accura                   |                     |
|       |    | cy                              |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                       Reference |                     |
|       |    |                                 |                     |
|       |    |   WI   ![](m                    |                     |
|       |    | edia/image7.jpeg){width="0.2562 |                     |
|       |    | 5in"   ![](media/image8.jpeg){w |                     |
|       |    | idth="0.25625in"   ![](media/im |                     |
|       |    | age9.png){width="0.255555555555 |                     |
|       |    | 55554in"   ![](media/image10.pn |                     |
|       |    | g){width="0.25625in"   OIML R76 |                     |
|       |    |                                 |                     |
|       |    |    height="0.1388888888888889in |                     |
|       |    | "}             height="0.146527 |                     |
|       |    | 77777777778in"}            heig |                     |
|       |    | ht="0.13472222222222222in"}     |                     |
|       |    |                    height="0.14 |                     |
|       |    | 097222222222222in"}             |                     |
|       |    |                                 |                     |
|       |    |   LC   A                        |                     |
|       |    |                                 |                     |
|       |    |        A\*), B                  |                     |
|       |    |                    B\*), C      |                     |
|       |    |                                 |                     |
|       |    |            C, D                 |                     |
|       |    |                        OIML R60 |                     |
|       |    |   ---- --------                 |                     |
|       |    | ------------------------------- |                     |
|       |    | --- --------------------------- |                     |
|       |    | --------------- --------------- |                     |
|       |    | ------------------------------- |                     |
|       |    | ------- ----------------------- |                     |
|       |    | ------------------- ----------- |                     |
|       |    |                                 |                     |
|       |    | Changed:                        |                     |
|       |    |                                 |                     |
|       |    |   ---- --------                 |                     |
|       |    | ------------------------------- |                     |
|       |    | --- --------------------------- |                     |
|       |    | --------------- --------------- |                     |
|       |    | ------------------------------- |                     |
|       |    | ------- ----------------------- |                     |
|       |    | ------------------- ----------- |                     |
|       |    |        Accura                   |                     |
|       |    | cy                              |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                                 |                     |
|       |    |                       Reference |                     |
|       |    |                                 |                     |
|       |    |   WI   ![](m                    |                     |
|       |    | edia/image7.jpeg){width="0.2562 |                     |
|       |    | 5in"   ![](media/image8.jpeg){w |                     |
|       |    | idth="0.25625in"   ![](media/im |                     |
|       |    | age9.png){width="0.255555555555 |                     |
|       |    | 55554in"   ![](media/image10.pn |                     |
|       |    | g){width="0.25625in"   OIML R76 |                     |
|       |    |                                 |                     |
|       |    |    height="0.1388888888888889in |                     |
|       |    | "}             height="0.146527 |                     |
|       |    | 77777777778in"}            heig |                     |
|       |    | ht="0.13472222222222222in"}     |                     |
|       |    |                    height="0.14 |                     |
|       |    | 097222222222222in"}             |                     |
|       |    |                                 |                     |
|       |    |   LC   A                        |                     |
|       |    |                                 |                     |
|       |    |        A\*), B                  |                     |
|       |    |                    B\*), C      |                     |
|       |    |                                 |                     |
|       |    |            C, D                 |                     |
|       |    |                        OIML R60 |                     |
|       |    |   ---- --------                 |                     |
|       |    | ------------------------------- |                     |
|       |    | --- --------------------------- |                     |
|       |    | --------------- --------------- |                     |
|       |    | ------------------------------- |                     |
|       |    | ------- ----------------------- |                     |
|       |    | ------------------- ----------- |                     |
|       |    |                                 |                     |
|       |    | > The format of table 14 in     |                     |
|       |    | > E.3.1 is amended the same as  |                     |
|       |    | > table 13.                     |                     |
+-------+----+---------------------------------+---------------------+
| E.    | CA | > Since OIMLR60 approved load   | P+ for NH load      |
| 2.3.X |    | > cells can be approved with    | cells / P- for CH   |
|       |    | > either steady-state humidity, | load cells          |
|       |    | > cyclic humidity or no         |                     |
|       |    | > humidity testing, a           | We think, because   |
|       |    | > requirement is needed to      | of the note to      |
|       |    | > specify that only load cells  | Table 7, there is a |
|       |    | > having the "SH"               | misunderstanding    |
|       |    | > classification can be used as | that CH load cells  |
|       |    | > a module for a non-automatic  | are worse compared  |
|       |    | > weighing instrument. This is  | to SH tested load   |
|       |    | > briefly mentioned in the note | cells which is not  |
|       |    | > to Table 7. Load cells with   | the case! Normally  |
|       |    | > the "CH" classification       | CH tested load      |
|       |    | > should not be deemed as       | cells meet the      |
|       |    | > meeting the damp heat         | requirements for SH |
|       |    | > requirements of section       | tested load cells,  |
|       |    | > B.2.2.                        | because the CH test |
|       |    | >                               | cycles include e.g. |
|       |    | > **\<\<Pending comments\>\>**  | a kind of           |
|       |    |                                 | "durability test"   |
|       |    |                                 | which is more than  |
|       |    |                                 | just a simple       |
|       |    |                                 | "humidity test". In |
|       |    |                                 | order to avoid      |
|       |    |                                 | misunderstandings   |
|       |    |                                 | we therefore        |
|       |    |                                 | suggest to change   |
|       |    |                                 | the 1CD as          |
|       |    |                                 | follows:\           |
|       |    |                                 | \                   |
|       |    |                                 | 1. Delete in Table  |
|       |    |                                 | 7 the second part   |
|       |    |                                 | of note (\*\*):     |
|       |    |                                 | "\... but not for   |
|       |    |                                 | CH tested load      |
|       |    |                                 | cells (pLC=1)"      |
|       |    |                                 | because Table 7     |
|       |    |                                 | just presents       |
|       |    |                                 | examples and the    |
|       |    |                                 | factor pLC=0,7      |
|       |    |                                 | applies to SH       |
|       |    |                                 | tested load cells   |
|       |    |                                 | only.               |
|       |    |                                 |                     |
|       |    |                                 | 2\. Add in 3.10.2.4 |
|       |    |                                 | under "- Load cells |
|       |    |                                 | \..." that only SH  |
|       |    |                                 | or CH tested load   |
|       |    |                                 | cells are allowed   |
|       |    |                                 | but no NH marked    |
|       |    |                                 | load cells.         |
|       |    |                                 |                     |
|       |    |                                 | 3\. Add a similar   |
|       |    |                                 | sentence under E.2  |
|       |    |                                 | (new F.2): SH and   |
|       |    |                                 | CH allowed under    |
|       |    |                                 | the modular         |
|       |    |                                 | approach, but no NH |
|       |    |                                 | load cells          |
+-------+----+---------------------------------+---------------------+
| E.2.5 | UK | > Should be "\...must equal or  | P+                  |
|       |    | > exceed\..." (or could be      |                     |
|       |    | > "\...must be equal to or      |                     |
|       |    | > exceed\...").                 |                     |
+-------+----+---------------------------------+---------------------+
| E.2.6 | CN | On the issue of relation        | P.  Within the      |
|       |    | between load cell (n~LC~) and   |     compatibility   |
|       |    | weighing instrument (n) (E.2.6) |     test it is      |
|       |    |                                 |     stated, that    |
|       |    | Temperature ranges and the      |     any module must |
|       |    | evaluation of stability against |     have the same   |
|       |    | humidity and creep of load      |     or a better     |
|       |    | cell(s) (LC) must meet the      |     accuracy than   |
|       |    | requirements for the weighing   |     the weighing    |
|       |    | instrument (WI). For each load  |     instrument.     |
|       |    | cell the maximum number of load |                     |
|       |    | cell intervals *n*~LC~ shall    | > A correction of a |
|       |    | not be less than the number of  | > load cell (e.g.   |
|       |    | verification scale intervals n  | > linearity) using  |
|       |    | of the instrument.              | > an appropriate    |
|       |    |                                 | > indicator is not  |
|       |    | > Since OIML R60 International  | > the intention of  |
|       |    | > Recommendation on Load Cell   | > the modular       |
|       |    | > points out: The               | > approach.         |
|       |    | > classification of load cells  |                     |
|       |    | > into specific accuracy        |                     |
|       |    | > classes is provided to        |                     |
|       |    | > facilitate their application  |                     |
|       |    | > to various mass measuring     |                     |
|       |    | > systems. In the application   |                     |
|       |    | > of this Recommendation, it    |                     |
|       |    | > should be recognized that the |                     |
|       |    | > effective performance of a    |                     |
|       |    | > particular load cell may be   |                     |
|       |    | > improved by compensation      |                     |
|       |    | > within the measuring system   |                     |
|       |    | > with which it is applied.     |                     |
|       |    | > Therefore, it is not the      |                     |
|       |    | > intent of this Recommendation |                     |
|       |    | > to require that a load cell   |                     |
|       |    | > be of the same accuracy class |                     |
|       |    | > as the measuring system in    |                     |
|       |    | > which it may be used. Nor     |                     |
|       |    | > does it require that a        |                     |
|       |    | > measuring instrument, giving  |                     |
|       |    | > indications of mass, use a    |                     |
|       |    | > load cell which has been      |                     |
|       |    | > separately approved.          |                     |
+-------+----+---------------------------------+---------------------+
| E.2.7 | CN | > On Page 121, in E.2.7, the    | P+                  |
|       |    | > sentence of "electrical data  |                     |
|       |    | > with regard to the weighing   |                     |
|       |    | > instrument " shall be the     |                     |
|       |    | > contents of E.3.5             |                     |
+-------+----+---------------------------------+---------------------+
| E.3   | US | > There is no compatibility     | P- See A.4.2.1.1    |
|       |    | > check for IZSR between        |                     |
|       |    | > separately tested indicators  |                     |
|       |    | > and weighing instruments      |                     |
|       |    | > (combination of load cell and |                     |
|       |    | > connecting elements). The     |                     |
|       |    | > IZSR of the separable         |                     |
|       |    | > indicator may be configured   |                     |
|       |    | > so that it is larger than the |                     |
|       |    | > IZSR of the weighing          |                     |
|       |    | > instrument.                   |                     |
+-------+----+---------------------------------+---------------------+
| E.3.1 | CN | On expressing method of         | P.  We understand   |
|       |    | accuracy class of indicator     |     your point of   |
|       |    | (E.3.1)                         |     view but there  |
|       |    |                                 |     is no vote for  |
|       |    | > In order to be different from |     changing the    |
|       |    | > accuracy class of weighing    |     symbols.        |
|       |    | > instrument, whether accuracy  |                     |
|       |    | > class of indicator can be     | Otherwise both      |
|       |    | > expressed by Class 1, Class   | weighing            |
|       |    | > 2, Class 3 and Class 4        | instruments and     |
|       |    | > separately.                   | indicators are      |
|       |    |                                 | considered in the   |
|       |    |                                 | same OIML           |
|       |    |                                 | Recommendation.     |
|       |    |                                 | Furthermore the     |
|       |    |                                 | metrological        |
|       |    |                                 | characteristics are |
|       |    |                                 | identical in all    |
|       |    |                                 | accuracy classes    |
|       |    |                                 | with the exception  |
|       |    |                                 | of pi for           |
|       |    |                                 | indicators.         |
|       |    |                                 |                     |
|       |    |                                 | Therefore we think  |
|       |    |                                 | this does not lead  |
|       |    |                                 | to a confusion.     |
+-------+----+---------------------------------+---------------------+
| E.3.5 | JP | > For items "(mV) Measuring     | P+ See 2CD          |
|       |    | > range minimum voltage" and    |                     |
|       |    | > "(mV) Measuring range maximum | P+ See list of      |
|       |    | > voltage", the symbols may be  | abbreviations (T.9) |
|       |    | > necessary.                    |                     |
|       |    | >                               |                     |
|       |    | > In addition, the definition   |                     |
|       |    | > for C in the equation of Δu   |                     |
|       |    | > is short.                     |                     |
+-------+----+---------------------------------+---------------------+
| E.5   | C  | > For a digital load cell the   | P+ See 2CD          |
|       | EC | > maximum cable length is not   |                     |
|       | IP | > of interest. See the          |                     |
|       |    | > definition of a digital load  |                     |
|       |    | > cell in T.2.2.                |                     |
+-------+----+---------------------------------+---------------------+
| E.6.1 | CA | > Temperature range is shown as | P+ Has been changed |
| /     |    | > -10°C 40°C. This is clearly   | to "--10 °C to +40  |
| E.6.2 |    | > not desirable and must be     | °C"\                |
|       |    | > corrected.                    | in order to avoid   |
|       |    | >                               | further problems    |
|       |    | > **Clarification:              | with ASCII symbols  |
|       |    | > Typographical error. Symbol   |                     |
|       |    | > is incorrect (divided by)     |                     |
|       |    | > should be -- (dash) Also      |                     |
|       |    | > found in section E.6.2**      |                     |
+-------+----+---------------------------------+---------------------+
| E.6.1 | CN | > On Page 126 and Page 128,     | P+ See CA           |
|       |    | > -10°÷40° shall be revised     |                     |
|       |    | > into -10°\~+40°               |                     |
+-------+----+---------------------------------+---------------------+
| E.6.1 | UK | > Is it worth having an example | We think that the   |
|       |    | > which shows that the modules  | existing two        |
|       |    | > are not compatible?           | examples are        |
|       |    |                                 | sufficient.         |
+-------+----+---------------------------------+---------------------+
| F     | CA | Canada would like to see        | P- With the         |
|       |    | *'Software'* (this entire       | reasoning given in  |
|       |    | Annex) removed from R76 and     | our response to CA  |
|       |    | kept as a second document       | comment under       |
|       |    | (D-­SW?) which would be          | "General"           |
|       |    | referenced. In this way, the    |                     |
|       |    | relevant tests would not need   |                     |
|       |    | to be duplicated by each        |                     |
|       |    | Recommendation. This would make |                     |
|       |    | ongoing maintenance and         |                     |
|       |    | updating of all documents much  |                     |
|       |    | easier and would eliminate the  |                     |
|       |    | concern of developing           |                     |
|       |    | conflicting requirements in the |                     |
|       |    | future.                         |                     |
+-------+----+---------------------------------+---------------------+
| F.    | UK | > "spotcheck" should be "spot   | P+                  |
| 2.2.3 |    | > check" (two words).           |                     |
+-------+----+---------------------------------+---------------------+
| F.2.4 | UK | > "spotcheck" should be "spot   | P+                  |
|       |    | > check" (two words).           |                     |
+-------+----+---------------------------------+---------------------+
| Bi    | NL | > /5/ The new OIML D 11 and ISO | P+ The respective   |
| bliog |    | > 7637-2 have been published in | requirements,       |
| raphy |    | > the meantime.                 | testing procedures, |
|       |    |                                 | references, and the |
|       |    |                                 | Bibliography of the |
|       |    |                                 | 2CD have been       |
|       |    |                                 | completely revised  |
|       |    |                                 | and updated         |
|       |    |                                 | according to the    |
|       |    |                                 | new OIML D11        |
|       |    |                                 | document.           |
+-------+----+---------------------------------+---------------------+