Interim Agenda of the Laws and Regulations Committee

Joe Gomez, Chairman

New Mexico Weights and Measures

Reference

Key Number

**200 INTRODUCTION**

The Laws and Regulations Committee (Committee) will address the
following items at its Interim Meeting. Table A identifies agenda items
by Reference Key Number, title, and page number. The first three digits
of the Reference Key Numbers of the items are assigned from the subject
series listed below. The fact that an item may appear on the agenda does
not mean it will be presented to the NCWM for a vote, The Committee may
withdraw some items, present some items for information and further
study, issue interpretations, or make specific recommendations for
changes to the publications listed below. The recommendations presented
in this agenda are statements of proposal and not necessarily
recommendations of the Committee. The appendices to the report are
listed in Table B.

This agenda contains recommendations to amend National Institute of
Standards and Technology (NIST) Handbook 130, "Uniform Laws and
Regulations," 2004 edition, and NIST Handbook 133, "Checking the Net
Contents of Packaged Goods," Fourth Edition. Revisions proposed for the
handbooks are shown in **bold face print** by ~~crossing out~~
information to be deleted and [underlining]{.underline} information to
be added. Additions proposed for the handbooks are designated as such
and are shown in **bold face print**. Proposals presented for
information only are designated as such and are shown in *italic* type.
"SI" means the International System of Units. "FPLA" means the Fair
Packaging and Labeling Act. The section mark, "§," is used in most
references in the text and is followed by the section number and title,
(for example, § 1.2. Weight.) When used in this report, the term
"weight" means "mass."

#### Subject Series

Introduction 200 Series

**NIST Handbook 130** - General 210 Series

Uniform Laws 220 Series

Weights and Measures Law (WML) 221 Series

Weighmaster Law (WL) 222 Series

Engine Fuels, Petroleum Products, and Automotive Lubricants Inspection
Law (EFL) 223 Series

Uniform Regulations 230 Series

Packaging and Labeling Regulation (PLR) 231 Series

Method of Sale Regulation (MSR) 232 Series

Unit Pricing Regulation (UPR) 233 Series

Voluntary Registration Regulation (VRR) 234 Series

Open Dating Regulation (ODR) 235 Series

Uniform National Type Evaluation Regulation (UNTER) 236 Series

Engine Fuels, Petroleum Products, and Automotive Lubricants Regulation
(EFR) 237 Series

Examination Procedure for Price Verification 240 Series

Interpretations and Guidelines 250 Series

**NIST Handbook 133** 260 Series

Other Items 270 Series

**Table A**

**Index to Reference Key Items**

**Ref. Key No. Title of Item Page**

##  {#section .TOC-2}

##  {#section-1 .TOC-1 .unnumbered}

## [221 UNIFORM WEIGHTS AND MEASURES LAW 4](#uniform-weights-and-measures-law)[221-1 Update Terminology 4](#update-terminology) {#uniform-weights-and-measures-law-4221-1-update-terminology-4 .TOC-2}

## [232 METHOD OF SALE REGULATION 7](#method-of-sale-regulation) {#method-of-sale-regulation-7 .TOC-1}

## [232-1 Temperature Compensation for Petroleum Products 7](#temperature-compensation-for-petroleum-products) {#temperature-compensation-for-petroleum-products-7 .TOC-2}

## [234 UNIFORM REGULATION FOR THE VOLUNTARY REGISTRATION OF SERVICEPERSONS AND SERVICE AGENCIES 8](#uniform-regulation-for-the-voluntary-registration-of-servicepersons-and-service-agencies) {#uniform-regulation-for-the-voluntary-registration-of-servicepersons-and-service-agencies-8 .TOC-1}

## [234-1 Update Terminology 8](#update-terminology-1) {#update-terminology-8 .TOC-2}

## [237 ENGINE FUELS, PETROLEUM PRODUCTS, AND AUTOMOTIVE LUBRICANTS REGULATION 10](#engine-fuels-petroleum-products-and-automotive-lubricants-regulation) {#engine-fuels-petroleum-products-and-automotive-lubricants-regulation-10 .TOC-1}

## [237-1 Biodiesel Fuel Identification and Labeling 10](#biodiesel-fuel-identification-and-labeling) {#biodiesel-fuel-identification-and-labeling-10 .TOC-2}

## [237-2 Premium Diesel Lubricity 12](#premium-diesel-lubricity) {#premium-diesel-lubricity-12 .TOC-2}

## [260 NIST HANDBOOK 133, CHECKING THE NET CONTENTS OF PACKAGED GOODS 12](#nist-handbook-133-checking-the-net-contents-of-packaged-goods) {#nist-handbook-133-checking-the-net-contents-of-packaged-goods-12 .TOC-1}

## [260-1 Amend § 2.3 Basic Test Procedure, and Table 2-5 12](#amend-2.3-basic-test-procedure-and-table-2-5) {#amend-2.3-basic-test-procedure-and-table-2-5-12 .TOC-2}

## [260-2 Amend § 3.11 and MAV Table 2-10 13](#amend-3.11-and-mav-table-2-10) {#amend-3.11-and-mav-table-2-10-13 .TOC-2}

## [260-3 Work Group to Revise MAV Tables 14](#work-group-to-revise-mav-tables) {#work-group-to-revise-mav-tables-14 .TOC-2}

## [270 OTHER 14](#other) {#other-14 .TOC-1}

## [270-1 Tare on Case-Ready Packages of Meat 14](#tare-on-case-ready-packages-of-meat) {#tare-on-case-ready-packages-of-meat-14 .TOC-2}

**Table B**

**Appendices**

**Appendix Title Page**

[A Sample List of Documentary Standards for Item #221-1 A1](#AppendixA)

**Daily Schedule**

**Sunday, January 23**

**1:00 p.m. - 5:00 p.m. Committee Review Session:** This session is open
to all NCWM members but participation in the discussion is generally
limited to members of the Committee.

**Monday, January 24**

**8:30 a.m. - noon Committee Open Hearings:** Comments will be accepted
on the following topics:

> 221 Uniform Weights and Measures Law
>
> 232 Method of Sale Regulation
>
> 234 Uniform Regulation for the Voluntary Registration of
> Servicepersons and Service Agencies
>
> 237 Engine Fuels, Petroleum Products, and Automotive Lubricants
> Regulation
>
> 260 NIST Handbook 133
>
> 270 Other Items

**1:00 p.m. - 4:00 p.m.** Joint L&R and S&T Committees Open Hearing and
Discussion on Temperature Compensated Sales of Petroleum Products

**Tuesday, January 25**

**8:30 a.m. - noon Committee Open Hearings (continued):** Comments will
continue to be accepted on the above topics.

**1:00 p.m. - 5:00 p.m. Committee Work Session:** This session is open
to all NCWM members but participation in the discussion is generally
limited to members of the Committee.

**Wednesday, January 26**

**8:30 a.m. - 11:00 a.m. Committee Work Session:** This session is open
to all NCWM members but participation in the discussion is generally
limited to members of the Committee.

**11:00 a.m. - noon Joint Session with all Standing Committees**

**Details of all Items**

(In order by Reference Key Number)

###### 221 UNIFORM WEIGHTS AND MEASURES LAW

####### 221-1 Update Terminology

**Source:** Southern Weights and Measures Association (SWMA)

**Recommendation:** Amend and add to the following sections:

Amend the Table of Contents as follows:

> Table of Contents
>
> Section Page
>
> 1\. Definitions 21
>
> 1.4. **~~Primary~~** Standards**[, Primary]{.underline}** 21
>
> 1.5. **~~Secondary~~** Standards**[, Secondary]{.underline}** 21
>
> **[1.14. Standards, Field 23]{.underline}**
>
> **[1.15. Accreditation 23]{.underline}**
>
> **[1.16. Calibration 23]{.underline}**
>
> **[1.17. Traceability 23]{.underline}**
>
> **[1.18. Uncertainty 23]{.underline}**
>
> **[1.19. Verification 23]{.underline}**
>
> **[1.20. Recognition 23]{.underline}**
>
> **[1.21. Standards, Reference 23]{.underline}**
>
> **[1.22. Standards, Working 23]{.underline}**

Amend Sections 1.4 and 1.5 as follows:

> 1.4. **~~Primary~~** Standard~~s~~**[, Primary]{.underline}.** \--
> **~~The term "primary standards" means the physical standards of the
> State that serve as the legal reference from which all other standards
> for weights and measures are derived.~~ [A standard that is designated
> or widely acknowledged as having the highest metrological quality and
> whose value is accepted without reference to another standard of the
> same quantity.]{.underline}**
>
> **[(Amended 200X)]{.underline}**
>
> 1.5. **~~Secondary~~** Standard~~s~~**[, Secondary.]{.underline}** \--
> **~~The term "secondary standards" means the physical standards that
> are traceable to the primary standards through comparisons, using
> acceptable laboratory procedures, and used in the enforcement of
> weights and measures laws and regulations.~~ [A standard whose value
> is assigned by comparison with a primary standard of the same
> quantity. ]{.underline}**
>
> **[(Amended 200X)]{.underline}**

Add Sections 1.14, 1.15, 1.16, 1.17, 1.18, 1.19, 1.20, 1.21, and 1.22 as
follows:

> **[1.14. Standard, Field. \-- A physical standard that meet
> specifications and tolerances in NIST 105-series standards (or other
> suitable and designated standards) and is traceable to the reference
> or working standards through comparisons, using acceptable laboratory
> procedures, and used in conjunction with commercial weighing and
> measuring equipment (1.13).]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.15. Accreditation. \-- A formal recognition by a recognized
> Accreditation Body that a laboratory is competent to carry out
> specific tests or calibrations or types of tests or calibrations.
> NOTE: Accreditation does not ensure compliance of standards to
> appropriate specifications.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.16. Calibration. \-- A set of operations which establish, under
> specified conditions, the relationship between values indicated by a
> measuring instrument or measuring system, or values represented by a
> material measure, and the corresponding known values of a
> measurand.]{.underline}**
>
> **[Also: Comparison of a measurement standard or instrument with
> another standard or instrument to detect, correlate, report, or
> eliminate by adjustment any inaccuracy of the compared.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.17. Traceability. \-- The property of the result of a measurement
> or the value of a standard whereby it can be related to stated
> references, usually national or international standards, through an
> unbroken chain of comparisons all having stated
> uncertainties.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.18. Uncertainty. \-- A Parameter associated with the result of a
> measurement that characterizes the dispersion of the values that could
> reasonably be attributed to the measurance.]{.underline}**
>
> **[(Added 200X]{.underline})**
>
> **[1.19. Verification. \-- The formal evaluation of a standard or
> device against the specifications and tolerances for determining
> conformance.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.20. Recognition. \-- A formal recognition by NIST Weights and
> Measures Division that a laboratory has demonstrated the ability to
> provide traceable measurement results and is competent to carry out
> specific tests or calibrations or types of tests or
> calibrations.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.21. Standard, Reference. \-- A standard, generally of the highest
> metrological quality available at a given location, from which
> measurements made at that location are derived. The term "reference
> standards" means the physical standards of the State that serve as the
> legal reference from which all other standards for weights and
> measures within that State are derived.]{.underline}**
>
> **[(Added 200X)]{.underline}**
>
> **[1.22. Standard, Working. \-- A standard that is usually calibrated
> against a reference standard, and is used routinely to calibrate or
> check material measures, measuring instruments, or reference
> materials. The term "working standards" means the physical standards
> that are traceable to the reference standards through comparisons,
> using acceptable laboratory procedures, and used in the enforcement of
> weights and measures laws and regulations.]{.underline}**
>
> **[(Added 200X)]{.underline}**

Amend Section 3 as follows:

> Section 3. Physical Standards
>
> Weights and measures that are traceable to the U.S. prototype
> standards supplied by the Federal Government, or approved as being
> satisfactory by the National Institute of Standards and Technology,
> shall be the State **~~primary~~** **[reference and
> working]{.underline}** standards of weights and measures, and shall be
> maintained in such calibration as prescribed by the National Institute
> of Standards and Technology **[as demonstrated through laboratory
> accreditation or recognition.]{.underline}** All **~~secondary~~
> [field]{.underline}** standards may be prescribed by the director and
> shall be verified upon their initial receipt, and as often thereafter
> as deemed necessary by the director.
>
> **[(Amended 200X)]{.underline}**

Amend Sections 12a, 12h, and 12p as follows:

> Section 12. Powers and Duties of the Director
>
> The Director shall:
>
> a\. maintain traceability of the State standards **~~to the national
> standards in the possession of the National Institute of Standards and
> Technology~~ [as demonstrated through laboratory accreditation or
> recognition;]{.underline}**
>
> **[(Amended 200X)]{.underline}**
>
> h\. **~~test annually the~~ [verify the field]{.underline}** standards
> for weights and measures used by any **~~city or county~~
> [jurisdiction]{.underline}** within the State, **[before being put
> into service, tested annually or as often thereafter as deemed
> necessary by the director based on statistically evaluated
> data,]{.underline}** and approve the same when found to be correct;
>
> **[(Amended 200X)]{.underline}**
>
> p\. provide for the training of weights and measures personnel, and
> may establish minimum training and performance requirements which
> shall then be met by all weights and measures personnel, whether
> county, municipal, or State. The director may adopt the training
> standards of the National Conference on Weights and Measures' National
> Training Program **[and the laboratory metrology standards specified
> by the NIST accreditation and/or recognition
> requirements]{.underline}**; and
>
> **(Added 1991[; Amended 200X)]{.underline}**

**Discussion:** This item came to the Southern Weights and Measures
Association from the NIST Handbook Update Work Group in conjunction with
Item 234-1, and Specifications and Tolerances (S&T) Committee Item
360-2. It is the intent of the Work Group that these three items be
considered together.

One of the reasons for these proposals is to update the terminology used
in Handbooks 130 and 44 to conform to international definitions. Terms
such as "primary standard" and "secondary standard" have been updated to
reflect the international usage of these terms. Terms like "reference
standard," "field standard," "traceability," and "uncertainty" have been
added to reflect their use within these documents. The changes proposed
also allow state directors to exercise more discretion when evaluating
calibration intervals, referencing documentary standards, and accepting
calibration reports.

This particular proposal allows state directors to change the
calibration interval for field standards (which are now required to be
calibrated annually). This proposal permits a jurisdiction to collect
historical calibration data, including "as-found" measurements, to
evaluate whether or not an annual calibration interval is appropriate
for a particular type of standard. Based on a statistical analysis of
its historical data, a lab may find that its stainless steel field
weights only need to be calibrated once every 5 years, while their cast
iron weights need to be calibrated every 6 months. The intent is to save
jurisdictions time and money by setting calibration intervals at
suitable frequencies rather than at arbitrary fixed intervals. This
should also lead to improved inspection accuracy by ensuring field
standards are within tolerance during the entire calibration interval.
Laboratory metrologists should be familiar with adjusting calibration
intervals for laboratory standards, and may be a useful resource for
both providing data and doing the statistical analysis. Jurisdictions
that need more information or assistance with statistical approaches to
changing calibration intervals may consult the National Conference of
Standards Laboratories International (NCSLI) Recommended Practice (RP)
#1, "Establishment & Adjustment of Calibration Intervals."

These proposed changes would have relatively little effect on state and
local weights and measures programs. There is no mandate for a
jurisdiction to change the way that it currently operates. The proposed
changes would serve only to increase control and flexibility when
evaluating things like field standard calibration intervals and the
acceptance of accredited private lab calibration reports. Much of what
is being proposed reflects practices already occurring in jurisdictions
across the country.

###### 232 METHOD OF SALE REGULATION

####### 232-1 Temperature Compensation for Petroleum Products

Source: Southern Weights and Measures Association (SWMA). (See item
232-4 in the Report of the 89th NCWM Annual Meeting in 2004.)

Recommendation: Amend the Method of Sale Regulation in Handbook 130 by
adding the following:

> **[2.20.X. Petroleum Products. - Where not in conflict with other
> statutes or regulations, petroleum products delivered through a
> vehicle-tank meter or stationary meter shall be sold with the volume
> adjusted to compensate for temperature. When petroleum products are
> sold temperature compensated:]{.underline}**
>
> **[(1) All sales shall be in terms of liters or U.S. gallons at 15
> ^°^C (60 ^°^F);]{.underline}**
>
> **[(2) The temperature compensation shall be accomplished through
> adjustable automatic means;]{.underline}**
>
> **[(3) The primary indicating elements, recording elements, and all
> recorded representations (receipts, invoices, bills of lading, etc.)
> shall be clearly and conspicuously marked to show that the volume
> delivered has been adjusted to the volume at 15 ^°^C (60
> ^°^F);]{.underline}**
>
> **[(4) All sales by the same company over at least a consecutive
> 12-month period must be sold temperature compensated (i.e., a company
> may not choose to operate some devices with automatic temperature
> compensators and others without; nor may a company choose to engage
> the automatic temperature compensator on a device only during certain
> times of the year).]{.underline}**

**Discussion:** Selling fuel adjusted to the volume at 15 ^°^C (60 ^°^F)
throughout the distribution system is the most equitable way fuel can be
sold without the buyer or seller gaining a competitive advantage.
Allowing a distributor to buy product at wholesale by gross volume and
sell it at retail by net volume is not equitable. In addition, a single
method of sale should be required so a prospective customer can make
value comparisons between sellers. There is no practical way customers
can make value comparisons when some locations sell product temperature
compensated and other locations sell the same product without
temperature compensation.

This item is considered in conjunction with a temperature compensation
item that is before the Specifications and Tolerances (S&T) Committee,
Item 331-1, although the S&T Committee's item is limited to vehicle-tank
meters. The Committee believes this is an important issue that should be
given careful consideration. The Committee also believes this item needs
to be discussed with parties that may be affected by its adoption. The
Committee has requested authorization and funding from the Board of
Directors to establish a Work Group to bring together interested parties
and build a consensus on the best way to approach this issue.

A similar proposal was made by the NEWMA in 2000 that mirrored a
temperature compensation item before the S&T Committee at the time. In
2000 the NEWMA noted that Pennsylvania, New Hampshire, Maine, and Canada
permit temperature compensation in sales of products like home heating
fuel and retail gasoline. In 2001 the Committee withdrew this item after
hearing testimony from several jurisdictions that opposed it.

###### 234 UNIFORM REGULATION FOR THE VOLUNTARY REGISTRATION OF SERVICEPERSONS AND SERVICE AGENCIES

####### 234-1 Update Terminology

**Source:** Southern Weights and Measures Association

**Recommendation:** Amend Sections 1 (Policy), 5 (Minimum Equipment), 8
(Placed in Service Report), and 9 (Examination of Calibration or
Certification of Standards and Testing Equipment) as follows:

> Section 1. Policy
>
> For the benefit of the users, manufacturers, and distributors of
> commercial weighing and measuring devices, it shall be the policy of
> the Director of Weights and Measures, hereinafter referred to as
> \"Director,\" to accept registration of (a) an individual and (b) an
> agency pro­viding acceptable evi­dence that he, she, or it is fully
> qualified by training or experience to install, service, repair, or
> re­condition a commercial weighing or measuring device; has a thorough
> working knowledge of all appropriate weights and measures laws,
> orders, rules, and regulations; and has possession of, or has
> available for use, and will use **[suitable and]{.underline}**
> calibrated weights and measures **[field]{.underline}** standards and
> testing equipment ap­propriate in design and adequate in amount.  (An
> employee of the government shall not be eligible for registration.)
>
> The Director will check the qualifications of each applicant. It will
> be necessary for an applicant to have available sufficient
> **[field]{.underline}** standards and equip­ment (see § 5).
>
> It shall also be the policy of the Department to issue to qualified
> applicants, whose ap­plications for registra­tion are approved, a
> \"Certificate of Regis­tration.\" This gives authority to remove
> rejection seals and tags placed on Commercial and Law‑Enforcement
> Weighing and Measuring Devices by authorized weights and measures
> officials, to place in service repaired devices that were rejected, or
> to place in service devices that have been newly installed.
>
> The Director is NOT guaranteeing the work or fair dealing of a
> Registered Serviceperson or Service Agency.  He will, however, remove
> from the registration list any Registered Service­person or Ser­vice
> Agency that per­forms unsatisfactory work or takes unfair advantage of
> a device owner.
>
> Registration with the Director shall be on a voluntary basis. The
> Director shall reserve the right to limit or reject the application of
> any Serviceperson or Service Agency and to revoke his, her, or its
> permit to remove rejection seals or tags for good cause.
>
> This policy shall in no way preclude or limit the right and privilege
> of any individual or agency not registered with the Director to
> install, service, repair, or recondition a commercial weighing or
> measur­ing device. (see § 7).
>
> (Added 1966; Amended 1984 **[and 200X]{.underline}**)­
>
> Section 5. Minimum Equipment
>
> Applicants must have available sufficient standards and equipment to
> ade­quately test devices as set forth in the Notes section of each
> applicable code in NIST Handbook 44, \"Specifications, Toleran­ces, and
> Other Technical Requirements for Weighing and Measuring Devices.\"
> **~~When applicable, t~~[T]{.underline}**his equip­ment will meet the
> specifica­tions of National Institute of Standards and Technology
> Handbook 105**‑ ~~1, "Specifications and Tolerances for Reference
> Standards and Field Standard Weights and Measures, Specifications and
> Tolerances for Field Standard Weights (NIST Class F)," National
> Institute of Standards and Technology Handbook~~** **~~105-2,
> "Specifications and Tolerances for Reference Standards and Field
> Standard Weights and Measures, Specifications and Tolerances for Field
> Standard Measuring Flasks," or National Institute of Standards and
> Technology Handbook 105-3, "Specifications and Tolerances for
> Reference Standards and Field Standard Weights and Measures,
> Specifications and Tolerances for Graduated Neck Type Volumetric Field
> Standards."~~ [series standards (or other suitable and designated
> standards).]{.underline} [This section shall not preclude the use of
> additional field standards and/or equipment, as approved by the
> Director, for uniform evaluation of device performance.]{.underline}**
> See also § 9.
>
> (Added 1984**[; Amended 200X]{.underline}**)
>
> Section 8. Placed in Service Report
>
> The Director shall furnish each Registered Serviceperson and
> Registered Service Agency with a sup­ply of report forms to be known as
> \"Placed in Service Reports.\" Such a form shall be executed in
> triplicate, shall include the assigned registration number, and shall
> be signed by a­ Registered Ser­vice­person or by a serviceperson
> represen­ting a Registered Agency for each rejected device restored to
> service and for each newly installed device placed in service.  Within
> 24 hours after a device is restored to service or placed in service,
> the original of the properly executed Placed in Service Re­port,
> together with any official rejection tag removed from the device,
> shall be **~~mailed~~ [forwarded]{.underline}** to the Direc­tor at
> [(address) .]{.underline}  The duplicate copy of the report shall be
> handed to the owner or operator of the device, and the triplicate copy
> of the report shall be retained by the Registered Serviceperson or
> Registered Service Agency.
>
> (Added 1966**[; Amended 200X]{.underline}**)
>
> Section 9. Examination and Calibration or Certification
>
> of Standards and Testing Equipment
>
> All **[field]{.underline}** standards that are used for servicing and
> testing weights and measures devices for which competence is
> registered shall be submitted to the Director for **[initial and
> subsequent]{.underline} ~~examination and certification~~
> [verification and calibration]{.underline}** at intervals determined
> by the director. A Registered Service­person or Registered Service
> Agency shall not use in servicing commercial weighing or measuring
> devices any **[field]{.underline}** standards or testing equipment
> that have not been **[~~certified~~ calibrated or
> verified]{.underline}** by the Director. **~~Equipment calibrated by
> another State weights and measures laboratory that can show evidence
> of measurement traceability to the National Institute of Standards and
> Technology will also be recognized as equipment that is suitable for
> use by Registered Servicepersons or Registered Service Agencies in
> this State.~~ [The Director may accept calibration and/or verification
> reports from any laboratory that is formally accredited or recognized.
> The Director shall maintain a list of organizations from whom the
> State will accept calibration reports under reciprocity agreements.
> The State shall retain the right under reciprocity agreements to
> periodically monitor calibration results and/or to verify field
> standard compliance to specifications and tolerances when field
> standards are initially placed into service or at any intermediate
> point between calibrations.]{.underline}**
>
> (Added 1966; Amended 1984**[,]{.underline} ~~and~~** 1999**[, and
> 200X]{.underline}**)

**Discussion:** This item came to the Southern Weights and Measures
Association from the NIST Handbook Update Work Group in conjunction with
Item 221-1, and Specifications and Tolerances (S&T) Committee Item
360-2. It is the intent of the Work Group that these three items be
considered together.

One of the reasons for these proposals is to update the terminology used
in Handbooks 130 and 44 to conform to international definitions. Terms
such as "primary standard" and "secondary standard" have been updated to
reflect the international usage of these terms. Terms like "reference
standard," "field standard," "traceability," and "uncertainty" have been
added to reflect their use within these documents. The changes proposed
allow state directors to exercise additional discretion when evaluating
calibration intervals, referencing documentary standards, and accepting
calibration reports.

This particular proposal grants state directors the freedom to reference
ASTM, OIML, or other suitable documentary standards, in addition to NIST
documents, when defining specifications for field standards. Currently,
some standards being used in the field have no corresponding NIST
document defining their specifications. Allowing ASTM, OIML, or other
suitable documentary standards to be referenced would fill this void.
State directors must be able to evaluate the impact of a field standard
that deviates from documentary standards and assess how it might affect
measurement results, functionality, efficiency, and safety. State
directors would have the authority and flexibility to accept and
designate field standards and to grandfather or otherwise allow
deviations from standard specifications. State directors may choose to
require unique calibration intervals for these deviant field standards,
or they may reject and/or confiscate the deviant standard based on
evaluation results. For further guidance on documentary standards that
may be used as specifications and tolerances for field standards, please
see Appendix A.

This particular proposal would also allow state directors to accept
calibration reports from accredited industry laboratories in addition to
NIST/WMD-recognized state laboratories. If a private laboratory is
accredited by a National Cooperation for Laboratory Accreditation
(NACLA)-approved accreditation body, or recognized by NIST/WMD as
capable of providing traceable measurement results, a state director may
decide whether or not s/he wants to accept the calibration reports of
the lab after evaluating the scope of accreditation and assessing the
lab's measurement uncertainty. Initial verification of field standards
may still be required, however, since a calibration report provides no
guarantee the equipment meets specifications. Accreditation is not
conformity assessment and should not be used for that purpose. State
metrologists and technical experts at NIST may be able to assist in
evaluating the acceptability of outside calibration reports.

These proposed changes would have relatively little effect on state and
local weights and measures programs. There is no mandate for a
jurisdiction to change the way that it currently operates. The proposed
changes would serve only to increase local control and flexibility when
evaluating things like field standard calibration intervals and the
acceptance of accredited private lab calibration reports. Much of what
is being proposed reflects practices already occurring in jurisdictions
across the country.

###### 237 ENGINE FUELS, PETROLEUM PRODUCTS, AND AUTOMOTIVE LUBRICANTS REGULATION

####### 

####### 237-1 Biodiesel Fuel Identification and Labeling

**Source:** Central Weights and Measures Association (CWMA). (See item
237-3B in the Report of the 89th NCWM Annual Meeting in 2004.)

**Recommendation:** Amend the Handbook 130 Engine Fuels, Petroleum
Products, and Automotive Lubricants Regulation by adding the following.

> **[3.15. Biodiesel.]{.underline}**
>
> **[3.15.1. Identification of Product. - Biodiesel and biodiesel blends
> shall be identified by the capital letter B followed by the numerical
> value representing the volume percentage of biodiesel fuel. (Examples:
> B100; B20)]{.underline}**
>
> **[3.15.2. Labeling of Retail Dispensers of Biodiesel and Biodiesel
> Blends. - Each retail dispenser of biodiesel or biodiesel blend shall
> be labeled with the capital letter B followed by the numerical value
> representing the volume percentage of biodiesel fuel and ending with
> the word 'biodiesel.' (Examples: B100 biodiesel; B20
> biodiesel)]{.underline}**
>
> **[3.15.3. Documentation for Dispenser Labeling Purposes. - The
> retailer shall be provided, at the time of delivery of the fuel, with
> a declaration of the volume percent biodiesel on an invoice, bill of
> lading, shipping paper, or other document. This documentation is for
> dispenser labeling purposes only; it is the responsibility of any
> potential blender to determine the amount of biodiesel in the diesel
> fuel prior to blending.]{.underline}**
>
> **[3.15.4. Exemption. - Biodiesel blends containing 5 ° or less
> biodiesel by volume are exempted from requirements 3.15.1., 3.15.2.,
> and 3.15.3.]{.underline}**

**Discussion:** The Committee has been working on this item since 2002
and has been monitoring the activities of ASTM with regard to biodiesel
fuels. The Committee has decided to continue moving forward with
identification and labeling requirements for biodiesel blends containing
more than 5 % biodiesel by volume despite ASTM's indecision on this
topic. The Committee feels it is important for consumers to be properly
informed about what is being offered for sale so they can make informed
purchases. The Committee has been informed that ASTM is considering
changing the "Fill and Go" specifications in D 975 to include biodiesel
blends of 20 % or less. If this is the direction ASTM ultimately adopts,
the Committee may need to re-evaluate the requirements for fuels between
5 % and 20 % biodiesel.

**Background:** Existing laws and regulations require accurate and
adequate information to be placed on commodities to allow consumers to
make price and quantity comparisons. For our economy to function
properly, consumers must also be able to rely on manufacturers' product
"claims." Products must meet manufacturer specifications and claims.

When ASTM first developed the biodiesel specification in 1993 it
proposed a specification for biodiesel used as a pure fuel, called B100.
However, several engine manufacturers had reservations about B100
biodiesel because they had no experience using blends over 20 % (B20).
Engine manufacturers recommend that users consult with their engine
manufacturer before using biodiesel blends above 5 % (B5) as concerns
related to costs, rubber and gasket compatibility, and cold flow
properties exist with these blends. While experience over the last 10
years and 40 million on-road miles has shown that biodiesel blends of up
to 20 % (B20) do not require modifications to the fuel systems of
conventional diesel engines, the manufacturers of these engines still
promote caution when using biodiesel blends over 5 % (B5).

ASTM is considering classifying biodiesel blends between B5 and B20
"Fill and Go" since they do not generally require changes to the engine
or fuel system. However, biodiesel levels higher than B20 may need to
have different gaskets and hoses. While blends of biodiesel over 20 %
are not readily available in today's market place, they may be in the
not too distant future. Therefore, the biodiesel industry supports
accurate labeling for all fuel dispensers and encourages the NCWM to
adopt these recommendations.

An issue that remains, however, is the opportunity for the facilitation
of fraud by claiming inaccurate percentages of biodiesel. Biodiesel
blends cost significantly more than conventional diesel fuels. As such,
there is the possibility that unscrupulous fuel distributors may
advertise a higher concentration of biodiesel than they are delivering
and thus derive undue profits. If a distributor claims that they are
selling B20 and they are putting in only 1 % the distributor is
misrepresenting the product. The biodiesel industry claims this is not a
pump labeling issue but an enforcement issue.

Part of the problem with a strict percentage labeling requirement is
that as biodiesel blends become more "mainstream" the percentage of
biodiesel added may vary from day-to-day depending on the needs of the
distributor. Currently this practice is discouraged by the relatively
high cost of biodiesel. However, as the price of biodiesel moves closer
to the price of diesel fuel it becomes just one of the myriad of
compounds which could make up conventional diesel fuel. Refiners could
blend in biodiesel to reduce the sulfur content or aromatic content of
the finished blend. They could use it to replace their existing
lubricity additives. If the price of biodiesel was more equal to diesel
they may add 1 % today, 5 % the next day, and 20 % the following day.
Theoretically, as long as the finished blend meets the ASTM D 975 "Fill
and Go" specification the level of biodiesel could range as high as 20 %
without consequence. Labeling requirements that are too restrictive
would eliminate the flexibility of the "Fill and Go" concept and could
significantly reduce the amount of biodiesel that is eventually used.

ASTM is currently developing a Biodiesel "Fill and Go" specification for
D 975 that is not based on the parent fuels, but on the finished fuel
and what is satisfactory for operation in a diesel engine. This may also
mean changes to D 6751, which is a stand-alone specification. The
current thinking is that the upper biodiesel concentration limit for the
D 975 "Fill and Go" specification will be 20 % although it is possible
that it could ultimately be higher or lower. Whatever the concentration
of biodiesel, if the finished blend meets the D 975 "Fill and Go"
specification the fuel is D 975-grade diesel fuel and would have to be
labeled as such. Some industry members believe that existing labeling
requirements in Handbook 130 are sufficient to address this situation.

####### 237-2 Premium Diesel Lubricity

**Source:** Southern Weights and Measures Association (SWMA)

**Recommendation:** Amend § 2.2.1. as follows:

> 2.2.1. Premium Diesel Fuel - All diesel fuels identified on retail
> dispensers, bills of lading, invoices, shipping papers, or other
> documentation with terms such a premium, super, supreme, plus, or
> premier must conform to the following requirements:
>
> \(a\) Cetane Number - A minimum cetane number of 47.0 as determined by
> ASTM Standard Test Method D 613.
>
> \(b\) Low Temperature Operability - A cold flow performance
> measurement which meets the ASTM D 975 tenth percentile minimum
> ambient air temperature charts and maps by either ASTM Standard Test
> Method D 2500 (Cloud Point) or ASTM Standard Test Method D 4539 (Low
> Temperature Flow Test, LTFT). Low temperature operability is only
> applicable October 1 - March 31 of each year.
>
> \(c\) Thermal Stability - A minimum reflectance measurement of 80 % as
> determined by ASTM Standard Test Method D 6468 (180 min, 150 ^°^C).
>
> \(d\) Lubricity - A maximum wear scar diameter of 520 μm as determined
> by ASTM D 6079. **~~If an enforcement jurisdiction's singe test of
> more than 560 μm is determined, a second test shall be conducted. If
> the average of the two tests is more than 560 μm, the sample does not
> conform to the requirements of this part.~~**

**Discussion:** The test tolerance for lubricity on premium diesel
specified in 2.2.1.(d) is inconsistent with that for regular diesel.
Effective January 1, 2005 the test tolerance for regular diesel
lubricity will be the ASTM D 6070 reproducibility of 136 μm (see ASTM D
975-04b). The NCWM has chosen to accept the ASTM reproducibility limits
for all diesel (D 975) and gasoline (D 4814) properties (see § 7.2.2.,
Reproducibility) but has chosen a different reproducibility limit for
premium diesel lubricity without providing any explanation as to why the
ASTM reproducibility limit is insufficient. If the NCWM intends to
impose a stricter lubricity requirement for premium diesel it should
designate a tighter specification for this property instead of a
different test tolerance (e.g., for regular and premium gasoline,
premium has a different octane specification than regular but the test
tolerance is the same). ASTM reproducibility limits are, by definition,
based on establishing a 95 % probability that product that should pass,
will pass. Applying an average test as specified in 2.2.1.(d) reduces
this probability to only 80 %.

###### 260 NIST HANDBOOK 133, CHECKING THE NET CONTENTs OF PACKAGED GOODS

####### 260-1 Amend § 2.3 Basic Test Procedure, and Table 2-5

**Source[:]{.smallcaps}** Central Weights and Measures Association
(CWMA). (See item 260-4 in the Report of the 89th NCWM Annual Meeting in
2004.)

**Recommendation:** Amend Handbook 133 § 2.3 as follows:

> ***Where are Maximum Allowable Variations found?***
>
> Find the MAV values for packages labeled by weight, volume, count, and
> measure in the tables listed below in Appendix A.

+----------------------------------------------------------+-----------+
| -   Packages labeled by weight                           | **See     |
|                                                          | Table     |
|                                                          | 2-5**     |
+----------------------------------------------------------+-----------+
| -   Packages labeled by volume liquid or dry             | **See     |
|                                                          | Table     |
|                                                          | 2-6**     |
+----------------------------------------------------------+-----------+
| -   Packages labeled by count                            | **See     |
|                                                          | Table     |
|                                                          | 2-7**     |
+----------------------------------------------------------+-----------+
| -   Packages labeled by length (width), or area          | **See     |
|                                                          | Table     |
|                                                          | 2-8**     |
+----------------------------------------------------------+-----------+
| -   Packages ~~labeled with~~ **[bearing                 | **See     |
|     a]{.underline}** USDA seal of inspection - Meat and  | Table     |
|     Poultry **[when labeled weight is provided by the    | 2-9**     |
|     USDA inspected facility]{.underline}**               |           |
+----------------------------------------------------------+-----------+
| -   Textiles, polyethylene sheeting and film, mulch and  | **See     |
|     soil labeled by volume, packaged firewood, and       | Table     |
|     packages labeled by count with less than 50 items    | 2-10**    |
+----------------------------------------------------------+-----------+

Amend the Header of Table 2-5 as follows:

> Table 2-5. Maximum Allowable Variations (MAVs) for Packages Labeled by
> Weight
>
> **~~Do Not Use This Table f~~[F]{.underline}**or Meat and Poultry
> Products **~~subject to USDA Regulations~~** **[when Labeled Weight is
> Provided by USDA-Inspected Facility]{.underline}** -- Use Table 2-9
>
> For Polyethylene Sheeting and Film, see Table 2-10. Exceptions to the
> MAVs.

**Discussion:** This proposal was originally intended to more clearly
define when the USDA lower limits should apply (Table 2-9) and when MAVs
should apply (Table 2-5) to packages of meat and poultry. This item was
informational on the Committee's agenda in 2004 and NIST was granted
editorial privileges to amend Handbook 133 to include this proposal.
However, after researching the issue NIST believes that this proposal is
in conflict with language adopted by the USDA. The USDA requires that
the Table 2-9 lower limits be applied to any "meat and poultry product
subject to USDA requirements." The language adopted by the USDA does not
distinguish between packages packed and weighed at a USDA plant and
packages packed at a USDA plant but weighed elsewhere; it simply
requires that any package subject to USDA jurisdiction be tested with
the USDA lower limits. NIST cannot include language in Handbook 133 that
is in conflict with federal regulations.

####### 260-2 Amend § 3.11 and MAV Table 2-10

Source: Western Weights and Measures Association (WWMA). (See item 260-6
in the Report of the 89th NCWM Annual Meeting in 2004.)

**Recommendation:** Amend the application and header of Handbook 133
Table 2-10 as follows to allow the MAVs that apply to Mulch and Soil to
also apply to similar products, such as Wood Shavings and Animal
Bedding:

> Table 2-10. Exceptions to the Maximum Allowable Variations for
>
> Textiles, Polyethylene Sheeting and Film, Mulch ~~and~~[,]{.underline}
> Soil**[, and Other Similar Products]{.underline}** Labeled by Volume,
> Packaged Firewood, and
>
> Packages Labeled by Count with Less than 50 Items

Amend Handbook 133 § 3.11 to read:

> 3.11. Mulch ~~and~~[,]{.underline} Soil**[, and Other Similar
> Products]{.underline}** Labeled by Volume

**Discussion:** A manufacturer of wood fiber products believes wood
shavings, labeled by volume, should receive the same MAV exceptions as
mulch and soils or peat moss. The wood fiber products in question could
conceivably be used as animal bedding, insulation, mulch (a
horticultural above-ground dressing), etc. The reasons for establishing
expanded MAVs for Mulch and Soil may also apply to other similar
products. Item 250-10, which was adopted at the 83rd National Conference
on Weights and Measures in 1998 and was entitled "Bark Mulch, an Other
Organic Products - Maximum Allowable Variations," discussed the
reasoning and the necessity for expanded MAVs in certain circumstances.

The Committee is concerned that the manufacturer who is seeking this
additional allowance has not provided sufficient data to support their
position. There is an established procedure for evaluating MAVs and the
manufacturer has not followed it. The Committee feels this item needs to
be further developed by the manufacturer in conjunction with a
regulatory agency to provide the Committee with reliable data upon which
to base any decision.

In addition, concerns have been raised about the expansion of the mulch,
soil, and peat moss sections to "Other Similar Products." What are
"Other Similar Products?" Are they products that are used in similar
applications? If so, and "Other Similar Products" is intended to extend
to pet beddings made of wood shavings, should it also be extended to pet
beddings made of paper (also a wood product)? What about pet beddings
made from other substances (clay, straw, etc.)? It is believed that the
language proposed is overly broad and needs to be better defined to
capture the product under consideration without including products that
do not require the larger MAV.

####### 260-3 Work Group to Revise MAV Tables

**Source:** Northeast Weights and Measures Association (NEWMA)

**Recommendation:** The NCWM should establish a work group to revise the
MAV tables in Handbook 133

**Discussion:** The following information was provided to the Committee
by the original proponent of this item: Current MAV values in Handbook
133 are not in harmony with the Canadian and European standards. MAV
values used by U.S. companies should be acceptable in international
commerce. There are inconsistencies between the MAVs applied to USDA
products and the MAVs applied to all other products. These
inconsistencies need to be reconciled. The present MAVs need to be
updated to reflect modern packaging technology. Industry standards today
are capable of holding to stricter tolerances and the MAV values in
Handbook 133 should reflect this.

Unfortunately, an effort of this type will require a significant
investment of both time and money. The current MAV values were
established from extensive data collected in the 1970s. This data was
collected over a number of years by looking at vast quantities of a wide
variety of products. While this data is undoubtedly somewhat outdated,
the overriding question is whether or not any improvement in the values
will justify the money and resources necessary to compile the data. It
is important to note that the data upon which the Canadian and European
standards are based is no more recent that our own.

###### 270 OTHER

####### 270-1 Tare on Case-Ready Packages of Meat

**Source:** Central Weights and Measures Association (CWMA)

**Recommendation:** The NCWM should petition the USDA to request a rule
change that would require packers of case-ready consumer-sized packages
of beef and pork to print the individual consumer package tare weights
on the outside of the shipping case.

**Discussion:** For several years now the USDA has required packers of
case-ready poultry to print the individual consumer package tare weights
on the outside of the shipping case. This proposal would extend this
requirement to packers of case-ready meat (beef and pork) products.

As retail stores eliminate butcher shops, weights and measures officials
are seeing more packages of meat that are shipped case-ready (i.e., the
meat is already portioned into individual packages, wrapped, and labeled
with all required information except weight). Retailers are required to
label these packages with the correct weight before making them
available for sale. However, retailers don't know what tare deduction to
take and are reluctant to open a reasonable sample of packages to
determine an average tare weight. This has led to inaccurate tares being
used with these products.

Unfortunately, the implementation of this requirement for poultry has
taught us that placing tare weights on shipping cases is an imperfect
system that poses several challenges. First, inspections have shown that
the tare weights printed on poultry shipping cases are often inaccurate
\-- packers use unused dry tare for this determination and don't appear
to include the weight of all the tare materials. Retailers often rely on
these tares to their detriment. The inaccuracy of these tares may leave
a jurisdiction with the difficult decision of who to prosecute \-- the
retailer (for selling a short-weight product) or the packer (for
declaring an inaccurate tare). The fact that the packer falls under USDA
jurisdiction and oversight may also cause additional hurdles for a
jurisdiction that wants to prosecute. Second, inspectors often
mistakenly rely on the accuracy of these tares when performing
inspections. If the tares are inaccurate but inspectors rely on them to
perform audit tests, will the inaccuracy ever be discovered? Inspectors
must remain vigilant about checking the actual tare of these packages
and not rely on the packer for this information. Enforcement action must
only be taken on packages where the average used or unused dry tare has
been determined.

[^1]

[]{#AppendixA .anchor}Appendix A

**Sample List of Documentary Standards for Item #221-1**

+------------------+----------+------------------+-----------+-------+
| **Physical       | **Doc    | **Device**       | **Ca      | **No  |
| Standard**       | umentary |                  | libration | tes** |
|                  | St       |                  | I         |       |
|                  | andard** |                  | nterval** |       |
+------------------+----------+------------------+-----------+-------+
| Cast Iron        | Handbook | Class III, III   | 6 months  |       |
| Weights          | 105-1    | L, IV scales     | to 1 year |       |
+------------------+----------+------------------+-----------+-------+
| Stainless Steel  | Handbook | Class III, III   | 5 years   |       |
| Weights          | 105-1    | L, IV scales     |           |       |
+------------------+----------+------------------+-----------+-------+
| Class F1 Weights | OIML     | Class II scales  | 1 year    |       |
|                  | R111     |                  |           |       |
| Class 2 Weights  |          |                  |           |       |
|                  | ASTM E   |                  |           |       |
|                  | 617-97   |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Glassware        | Handbook | Package testing  | 10 years  |       |
|                  | 105-2    |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Test Measures    | Handbook | Gas pumps        | 1 year    |       |
| (hand-held and   | 105-3    |                  |           |       |
| 5-gallon truck   |          |                  |           |       |
| or trailer       |          |                  |           |       |
| mounted)         |          |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Large Provers    | Handbook | Meters           | 1 year    |       |
|                  | 105-3    |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| LPG Provers      | Handbook | LPG meters       | 1 year    |       |
|                  | 105-4    |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Stopwatches      | Handbook | Taxi meters,     | 1 year    |       |
|                  | 105-5    | timing devices,  |           |       |
|                  |          | parking meters,  |           |       |
|                  |          | laundromats      |           |       |
+------------------+----------+------------------+-----------+-------+
| Thermometers     | Handbook | Temperature      | 5 years   | A     |
|                  | 105-6    | corrections,     |           | nnual |
|                  |          | refrigeration    |           | inspe |
|                  |          | specifications,  |           | ction |
|                  |          | package checking |           | req   |
|                  |          |                  |           | uired |
+------------------+----------+------------------+-----------+-------+
| Small Volume     | Handbook | Meters           | 6 months  | Need  |
| Provers          | 105-7    |                  | to 1 year | EPO   |
|                  |          |                  |           | for   |
|                  |          |                  |           | field |
|                  |          |                  |           | te    |
|                  |          |                  |           | sting |
+------------------+----------+------------------+-----------+-------+
| Master Meters    | API      | Master meters    |           |       |
|                  | document | for petroleum    |           |       |
|                  | in       |                  |           |       |
|                  | dev      |                  |           |       |
|                  | elopment |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Proving Rings    | ASTM E   | Wheel load       | Rings: 5  | De    |
| and Load Cells   | 74       | weighers, weight | years     | pends |
|                  |          | carts, large     |           | on    |
|                  |          | mass standards   | Cells: 6  | use   |
|                  |          |                  | months if |       |
|                  |          |                  | used for  |       |
|                  |          |                  | wheel     |       |
|                  |          |                  | load      |       |
|                  |          |                  | weighers; |       |
|                  |          |                  | evaluate  |       |
|                  |          |                  | with use  |       |
|                  |          |                  | for       |       |
|                  |          |                  | sub       |       |
|                  |          |                  | stitution |       |
|                  |          |                  | weighing  |       |
+------------------+----------+------------------+-----------+-------+
| Weight Carts     | Handbook | Vehicle scales   | 6 months  | Needs |
|                  | 105-8    |                  | to 1 year | to be |
|                  |          |                  |           | re    |
|                  |          |                  |           | calib |
|                  |          |                  |           | rated |
|                  |          |                  |           | with  |
|                  |          |                  |           | any   |
|                  |          |                  |           | re    |
|                  |          |                  |           | pair. |
|                  |          |                  |           | Need  |
|                  |          |                  |           | EPO   |
|                  |          |                  |           | for   |
|                  |          |                  |           | field |
|                  |          |                  |           | use   |
+------------------+----------+------------------+-----------+-------+
| Hydrometers      | ASTM E   | Petroleum        | 1 year    |       |
|                  | 100      | products; bulk   |           |       |
|                  |          | oil meters       |           |       |
+------------------+----------+------------------+-----------+-------+
| Length           | GGG-     | Taxi meters,     | 5 years   | In    |
| Standards, Tapes | standard | fabric scale     |           | spect |
|                  |          | decks, firewood, |           | b     |
|                  |          | lobster gauges   |           | efore |
|                  |          |                  |           | use   |
+------------------+----------+------------------+-----------+-------+
| Containers       | Handbook | Bulk mulch       |           |       |
|                  | 133      |                  |           |       |
+------------------+----------+------------------+-----------+-------+
| Berry Baskets    | Handbook | Berry quantity   |           |       |
|                  | 44       |                  |           |       |
+------------------+----------+------------------+-----------+-------+

[^1]: ^^Joe Gomez, New Mexico, Chairman

    Joe Benavides, Texas

    James Cassidy, Cambridge, Massachusetts

    Vicky Dempsey, Montgomery County, Ohio

    Dennis Johannes, California

    Vince Orr, ConAgra Foods, Associate Member Representative

    Brian Lemon, Canada, Technical Advisor

    Doug Hutchinson, Canada, Technical Advisor

    Kathryn Dresser, NIST, Technical Advisor

    **Committee on Laws and Regulations**